You can find Sniph’s Terms & Conditions here
EFFECTIVE AS OF 25 MAY 2018
2. About this Policy
3. Your rights and your preferences: Giving you choice and control
4. How do we collect your personal data?
5. What personal data do we collect from you?
6. What do we use your personal data for?
7. Sharing your personal data
8. Data retention and deletion
9. Transfer to other countries
10. Keeping your data safe
11. Age limit
13. How to contact us
Thank you for wanting to become a part of Sniph!
At Sniph, we want to give you the best possible experience to ensure that you enjoy our service today, tomorrow and in the future. To do this we need to understand your perfume habits so we can deliver an exceptional and personalized service specifically for you. That being said, your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data – as well as outline the controls and choices you have around when and how you choose to share your personal data.
2. ABOUT THIS POLICY
This Policy sets out the essential details relating to your personal data relationship with Sniph AB. The Policy applies to all Sniph services and any associated services (referred to as the ‘Sniph Service’). The terms governing your use of the Sniph Service are defined in our Terms and Conditions (the “Terms and Conditions”).
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
The aim of this Policy is to:
- Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
- Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Sniph Service; and
- Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ Section 13 below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Sniph Service.
3. YOUR RIGHTS AND YOUR PREFERENCES: GIVING YOU CHOICE AND CONTROL
You may be aware that a European Union law, called the General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and access controls in our Privacy Center and Privacy Settings to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access – the right to be informed of and request access to the personal data we process about you;
- Right to Rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure – the right to request that we delete your personal data;
- Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object – the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
- Right not to be subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to enable you to exercise these rights with ease and to record your preferences in relation to how Sniph uses your personal data, we provide you with access to settings via your Account Settings page on the Sniph service, in e-mails sent to you and by contacting us via our site, e-mail, social media or letters. We will continuously add more functionality to make it easy for you to manage your settings, give and withdraw your consent.
If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you receive from Sniph (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).
You can find out more about the GDPR rights described above and the controls we provide to all Sniph users with respect to these rights in the ‘Your Rights’ section contained in the Privacy Center. If you have any questions about your privacy, your rights, or how to exercise them, please contact us at [email protected]. We will respond to your request within a reasonable period of time upon verification of your identity. If you are unhappy with the way we are using your personal data you can also contact and are free to lodge a complaint with the Swedish Data Protection Authority (Datainspektionen) or your local Data Protection Authority.
4. HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data in the following ways:
- When you sign up for the Sniph Service – when you sign up to the Sniph Service, we collect certain personal data so you can use the Sniph Service such as your email address, birth date, gender, and country.
- Through your use of the Sniph Service – when you use the Sniph Service, we collect personal data about your use of the Sniph Service, such as what perfumes you liked.
- Personal data collected that enables us to provide you with additional features/functionality – from time to time, you also may provide us with additional personal data or give us your permission to collect additional personal data e.g. to provide you with more features or functionality. You always will have the option to change your mind and withdraw your consent at any time.
- From third parties – we will receive personal data about you and your activity from third parties, including advertisers and partners we work with in order to provide you with the Sniph Service (please see ‘Sharing your personal data’ Section 7 below). We will use this personal data either where you have provided your consent to the third party or to Sniph to that data sharing taking place or where Sniph has a legitimate interest to use the personal data in order to provide you with the Sniph Service.
We use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving the Sniph Service, and developing new features and functionality within the Sniph Service.
5.WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
We have set out below the categories of personal data we collect and use about you:
Personal data collected when you sign up for the Sniph Service:
Account Registration Data
This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Sniph Service. This includes your email address, birth date, gender, postal code, and country.
Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal data in order to make your account more personalized.
The exact personal data we will collect depends on the type of Sniph Service plan you sign up for and whether or not you use a Third Party Service (such as Facebook) to sign up and use the Sniph Service. If you use a Third Party Service to create an account, we will receive personal data via that Third Party Service but only when you have consented to that Third Party Service sharing your personal data with us.
Personal data collected through your use of the Sniph Service:
Sniph Service Usage Data
This is the personal data that is collected about you when you are using the Sniph Service – this may include:
- Information about your type of Sniph Service plan.
- Information about your interactions with the Sniph Service which includes the date and time of any requests you make and your interactions with other Sniph users. This also may include details of your use of Third Party Applications and advertising you receive.
- User Content you post to Sniph including messages you send and/or receive via Sniph and your interactions with the Sniph Customer Service team.
- Technical Data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Sniph Service, browser type, language and operating system. Further details about the technical data that is processed by us can be found in our Cookies Policy.
Personal data collected with your permission that enables us to provide you with additional features/functionality:
We may collect such personal data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the Terms and Conditions) or make other purchases through the Sniph Service. The exact personal data collected will vary depending on the payment method but will include information such as:
- Date of birth
- Credit or debit card type, expiration date, and certain digits of your card number
- Postal code
- Mobile phone number
- Details of your transaction history
If you choose to pay by invoice, we will provide your personal data to our payment processors to enable them to complete a credit check and to send you invoices.
Contests, Surveys and Sweepstakes Data
This personal data is used to allow you to sign up and participate in these types of promotions. The exact personal data collected will vary depending on the promotion.
This personal data is used to enable Sniph and our partners / service providers to send you marketing communications either:
- Via email
- Whilst using the Sniph Service
- Direct from the third party
6. WHAT DO WE USE YOUR PERSONAL DATA FOR?
When you use or interact with the Sniph Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 5 ‘What personal data do we collect from you?’) used for these purposes:
If you require further information about the balancing considerations that Sniph has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 13 ‘How to contact us’ for further details on how to contact us.
7. SHARING YOUR PERSONAL DATA
The following personal data will only be shared with the categories of recipients outlined in the table below if:
- you choose to make use of a specific Sniph Service feature where sharing of particular personal data is required for the proper use of the Sniph Service feature; or
- you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Sniph Service.
Learn more about how to manage notifications, your publicly available information, and what you share with others in the ‘Your rights and your preferences: Giving you choice and control’ Section 3 of this Policy.
Information we may share:
8. DATA RETENTION AND DELETION
We keep your personal data only as long as necessary to provide you with the Sniph Service and for legitimate and essential business purposes, such as maintaining the performance of the Sniph Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Sniph Service, regardless of if your are a paying customer or a registered member using our services available free of charge. For example, we keep your fragrance wardrobe, your ratings and account information. This is done make it possible for you to pause your subscriptions and purchases while still getting the recommendations and other function the Sniph Service provides all its members.
If you request or if you are inactive for a long period, normally 36 months, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
- If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
- Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
9. TRANSFER TO OTHER COUNTRIES
Sniph shares your personal data globally with other companies in the Sniph Group in order to carry out the activities specified in this Policy. This includes to Sniph Group companies in the following countries: Sweden and United Kingdom. Sniph may also subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.
Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances Sniph shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.
For further details of the security measures we use to protect your personal data, please see the ‘Keeping your personal data safe’ Section 11 of this Policy.
10. KEEPING YOUR PERSONAL DATA SAFE
We are committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Sniph Service.
11. AGE LIMIT
The Sniph Service is not directed to people under the age of 18 years.
We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Sniph Service, and do not provide any personal data to us.
If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Sniph, please contact us via [email protected], and you may request exercise of your applicable rights detailed in the ‘Your rights and your preferences: Giving you choice and control’ Section 3 of this Policy.
If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the Sniph account for that child.
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Sniph Service or by sending you an email. We may notify you in advance.
Please, therefore, make sure you read any such notice carefully.
13. HOW TO CONTACT US
112 49 Stockholm
Sniph AB is the data controller for the purposes of the personal data processed under this Policy.
We hope you will enjoy Sniph!
1. What are cookies and other similar technologies?
3. How to manage your cookie preferences
4. Updates to this Policy
5. How to contact us
The objective of this Policy is to provide you, as a user of Sniph’s services, with clear and accessible information about the cookies that Sniph uses, the role they play in helping us provide the best possible experience to you and the choices you have when it comes to your cookie settings.
1. WHAT ARE COOKIES AND OTHER SIMILAR TECHNOLOGIES?
Cookies are text files which are downloaded to your device when you visit a website. They are useful because they allow a website to recognise a user’s device. You can find more information about cookies at: www.allaboutcookies.org or www.youronlinechoices.eu.
The term cookie actually describes a range of technologies, including:
- pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed),
- mobile device identifiers, and
- web storage used in desktop software or mobile devices.
We’ll use the term cookie throughout this Policy to cover all of these technologies, but we’ll make sure we provide you with clear details about them all so that you can make informed choices about your cookie settings.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. They can also help to ensure that ads you see online are more relevant to you and your interests.
There are a few different categories of cookies, including:
Session and Persistent Cookies
- Session Cookies – these are cookies which expire once you close your web browser; and
- Persistent Cookies – these are cookies which stay on your device for a set period of time or until you delete them.
First and Third Party Cookies
- First-party cookies – these are cookies set by the website that you are visiting at that time, either by us, or by a third party at our request;
- Third-party cookies – these are cookies that are set by a party other than that of the website you are visiting. If you visit the Sniph website or use the Sniph Service and another party sets a cookie through that website this would be a third-party cookie.
Cookies also differ depending on the purpose they are used for, including:
Sniph, or our service providers acting on our behalf, uses the types of cookies identified in Section 1 above in the following ways:
3. How to manage your cookie preferences
On your mobile device, your operating system may provide you with additional options to opt out of interest based advertising or to otherwise reset your mobile identifiers. For example, you may use the “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.
Certain targeted advertisements that we (or a service provider acting on our behalf) display to you based on information about your online activities across websites and other interactive properties operated by third parties may include the “Ad Choices” icon or another mechanism to opt out of receiving interest-based advertisements. You may click on the AdChoices icon or visit aboutads.info to receive more information about the collection and use of information about your online activities for interest based advertising or to learn how to opt out of having your data used for interest based advertising by Digital Advertising Alliance (DAA) participating companies.
- European users can also visit youronlinechoices.com to learn how to opt out of having their data used for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) member companies.
- The Network Advertising Initiative’s (NAI) Opt-Out Tool at networkadvertising.org/choices allows you to opt out from the use of information about your online activities for interest based advertising by NAI member companies.
4. Updates to this Policy
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice e.g., by displaying a prominent notice within the Sniph Service or by sending you an email. We may notify you in advance.
5. How to contact us
Sibyllegatan 18, 114 42 Stockholm
We hope you enjoy Sniph!