Privacy Policy

You can find Sniph’s Terms & Conditions here

EFFECTIVE AS OF 25 MAY 2018

1. Introduction

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

12. Changes to this Privacy Policy

13. How to contact us

1. INTRODUCTION

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.

That is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.

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:

  1. 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;
  2. 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
  3. 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:

  1. 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.
  2. 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.
  3. 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.
  4. 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:

Payment Data

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:

  • Name
  • 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.

Marketing Data

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:

Description of why Sniph processes your personal data (‘processing purpose’): To provide, personalize, and improve your experience with the Sniph Service and other services and products provided by Sniph, for example by providing customized, personalized, or localized content, recommendations, features, and advertising on or outside of the Sniph Service (including for third party products and services). Legal Basis for the processing purpose: Performance of a Contract Legitimate Interest. Categories of personal data used by Sniph for the processing purpose: Account Registration Data Service Usage Data.
To understand how you access and use the Sniph Service to ensure technical functionality of the Sniph Service, develop new products and services, and analyze your use of the Sniph Service, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Sniph Service. Performance of a Contract Legitimate Interest Account Registration Data Service Usage Data
To communicate with you for Sniph Service-related purposes. Performance of a Contract Legitimate Interest Account Registration Data Service Usage Data
To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of the Sniph Service. Performance of a Contract Compliance with legal obligations Legitimate Interest Payment Data
To communicate with you, either directly or through one of our partners, for: marketing, research, participation in contests, surveys and sweepstakes, promotional purposes, via emails, notifications, or other messages, consistent with any permissions you may have communicated to us (e.g., through your Account Settings page). Consent Legitimate Interest Contests, Surveys and Sweepstakes Data Marketing Data

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.
Categories of Recipients: Other Sniph members Perfume producers and brands Reason for sharing: There also may be times when you want us to share certain Service Usage Data, specifically information about your use of Sniph, with other Sniph users known as ‘Your Sniph Followers’. For example, when you rate perfumes, you might want those perfumes to be visible to others on the Sniph Service, but you can also make your list of perfumes private at any time. You can ask us to share personal data (like your email address) with perfume producers, brands, or other partners who may want to directly send you news or promotional offers, but you can also revoke that consent at any time.

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:

Categories of Recipients Reason for sharing Service Providers and Others We use technical service providers which may operate the technical infrastructure that we need to provide the Sniph Service, in particular providers which host, store, manage, and maintain the Sniph application, its content and the data we process. We use technical service providers to help us communicate with you, as described in Section 6 of this Policy. We use marketing and advertising partners to show you more tailored content, or to help us understand your use of the Sniph Service, to provide you with a better service. We also may share personal data with certain marketing and advertising partners to send you promotional communications about Sniph.
Sniph Partners If you access the Sniph Service through an offer that you received or purchased from a third party such as an online store, we share personal data with that third party about your use of the Sniph Service, such as whether and to what extent you have used the offer, activated a Sniph account, or actively used the Sniph Service. Depending on how you sign up for the Sniph Service (e.g. through a third party service or an online store), we share your Sniph username or other Account Registration Data as necessary to enable your account. We also may share your personal data in a pseudonymised format with our perfume industry partners to help them understand how the products they provide to us is received and to enable you to get these products via the Sniph Service. We also share your personal data in a pseudonymised format with marketing partners who help us with promotional efforts.
Academic Researchers We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format.
Other Sniph Group Companies We will share your personal data with other Sniph Group companies to carry out our daily business operations and to enable us to maintain and provide the Sniph Service to you.
Law Enforcement and Data Protection Authorities We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also will share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Sniph will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different Privacy Policy.

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.

12. CHANGES TO THIS PRIVACY POLICY

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

Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact our Data Protection Officer by sending an e-mail to [email protected] or by writing to us at the following address:

Sniph AB

Igeldammsgatan 22B

112 49 Stockholm

Sweden

Sniph AB is the data controller for the purposes of the personal data processed under this Policy.

We hope you will enjoy Sniph!

SNIPH COOKIE POLICY

1. What are cookies and other similar technologies?

2. How does Sniph use cookies?

3. How to manage your cookie preferences

4. Updates to this Policy

5. How to contact us

Hello, and welcome to Sniph’s Cookie Policy (“Policy”).

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:

Strictly Necessary Cookies These cookies are essential in order to enable you to use the features of our services, such as maintaining your playlist. Without these cookies, services you have asked for e.g., e-billing, cannot be provided. In summary, these cookies enable services you have specifically asked for and make using our services possible.
Performance Cookies These cookies collect information about how visitors use our services, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies collect anonymous information on the pages visited. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how our services perform. Web analytics that use cookies to gather data to enhance the performance of a website fall into this category. For example, they may be used for testing designs and ensuring a consistent look and feel is maintained for the user. This category does not include cookies used for behavioural/targeted advertising networks.
Functionality Cookies These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These cookies remember choices you make to improve your experience. If the same cookie is used for re-targeting they must be included in the ‘Targeting or advertising cookies’ category as well. It might also include cookies that are used to deliver a specific function, but where that function includes cookies used for behavioural/targeted advertising networks they must be included in the ‘Targeting or advertising cookies’ category as well as this category.
Targeting or advertising Cookies These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisations. These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests.

2. HOW DOES SNIPH USE COOKIES?

Sniph, or our service providers acting on our behalf, uses the types of cookies identified in Section 1 above in the following ways:

Strictly Necessary These cookies are necessary to allow us to operate the Sniph Service as you have requested. For example, they let us recognise what type of subscriber you are and then provide you with services accordingly.
Performance / Analytics We use cookies and other similar technologies to analyse how the Sniph Service is accessed, is used, or is performing. We use this information to maintain, operate, and continually improve the Sniph Service. We may also obtain information from our email newsletters or other communications we send to you, including whether you opened or forwarded a newsletter or clicked on any of its content. This information tells us about our newsletters' effectiveness and helps us ensure that we're delivering information that you find interesting.
Functional These cookies let us operate the Sniph Service according to your preferences. For example, when you continue to use or come back to the Sniph Service, we can provide you with our services based on information you provide to us, such as remembering your username, how you have customised our services, and reminding you of perfumes you have enjoyed previously.
Targeted Advertising We use these cookies and other similar technologies to serve you with advertisements that may be relevant to you and your interests, including interest-based advertising. The information may also be used to record how many times you’ve been served a particular advertisement and to ensure we do not display the same advertisement to you repeatedly, and to otherwise help us measure their effectiveness.
Third Party We may allow our business partners to use cookies or other similar technologies on or outside the Sniph Service for the same purposes identified above, including collecting information about your online activities over time and across different websites, applications, and/or devices.
Sniph Ads We work with website publishers, application developers, advertising networks, and service providers to deliver advertisements and other content promoting Sniph on other web sites and services. Cookies and other similar technologies may be used to serve you with advertisements that may be relevant to you and your interests on other websites, applications, and devices, and to regulate the advertisements you receive and measure their effectiveness.

3. How to manage your cookie preferences

Browser Cookies

You can withdraw or modify your consent to our use of cookies at any time. If you no longer wish to receive cookies you can use your web browser settings to accept, refuse and delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings).

Please note that if you set your browser to refuse cookies, you may not be able to use all the features of the Sniph website. To find out more information, you can visit www.allaboutcookies.org.

Mobile Identifiers

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.

Interest-Based Advertising

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

Thank you for reading our Cookie Policy. If you have any questions about this Cookie Policy, please contact us by e-mail at [email protected] or by writing to us at the following address:

Sniph AB

Sibyllegatan 18, 114 42 Stockholm

Sweden

We hope you enjoy Sniph!