Owner and Data Controller
Snowcountry B.V.
Astronaut 10
3824 MJ Amersfoort
Netherlands
Owner contact email: helpdesk@snowcountry.eu
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Cookies; Usage Data; first name; email address; various types of Data; last name; country; address; phone number; User ID; Universally unique identifier (UUID); unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); number of Users; city; device information; session statistics; browser information; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Handling payments, Contacting the User, Data transfer outside the EU, Displaying content from external platforms, Registration and authentication, Interaction with external social networks and platforms, Managing support and contact requests, Advertising, Tag Management, Remarketing and behavioral targeting, Backup saving and management and SPAM protection.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Microsoft Advertising (Microsoft Corporation)
Microsoft Advertising is an advertising service provided by Microsoft Corporation.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Google Ads conversion tracking (Google Ireland Limited)
Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Microsoft Advertising Universal Event Tracking (Microsoft Corporation)
Microsoft Advertising Universal Event Tracking is an analytics service provided by Microsoft Corporation that connects data from the Microsoft Advertising network with actions performed on this Website.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta Audience Network with actions performed on this Website. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Ad Manager (Google Ireland Limited)
Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to understand Google's use of Data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Google Ads Similar audiences (Google Ireland Limited)
Similar audiences is an advertising and behavioral targeting service provided by Google Ireland Limited that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Website.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.
Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Universal Analytics) with anonymized IP
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Analytics (Universal Analytics) (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Google Analytics Demographics and Interests reports (Google Ireland Limited)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: browser information; city; device information; number of Users; session statistics; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Backup saving and management
This type of service allows the Owner to save and manage backups of this Website on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Website.
Backup on Google Drive (Google Ireland Limited)
Google Drive is a service to save and manage backups provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: address; country; email address; first name; last name; Usage Data.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts
Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Maps widget
Google Maps is a maps visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
YouTube video widget
YouTube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Handling payments
Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Adyen (Adyen B.V.)
Adyen is a payment service provided by Adyen B.V.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Netherlands – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
SOFORT (SOFORT GmbH)
SOFORT is a payment service provided by SOFORT GmbH.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Klarna (Klarna AB)
Klarna is a payment service provided by Klarna AB.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Sweden – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
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Managing support and contact requests
This type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk (Zendesk, Inc.)
Zendesk is a support and contact request management service provided by Zendesk Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Registration and authentication
By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Website will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (this Website)
The User registers by filling out the registration form and providing the Personal Data directly to this Website.
Personal Data processed: address; country; email address; first name; last name; phone number; User ID.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
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Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Google Ad Manager Audience Extension (Google Ireland Limited)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of this Website and allows selected advertising partners to display targeted ads across the web to them.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
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SPAM protection
This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google Ireland Limited)
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.
This processing constitutes:
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by
YourOnlineChoices (EU),
the Network Advertising Initiative (US) and
the Digital Advertising Alliance (US),
DAAC (Canada),
DDAI (Japan)
or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Further information about the processing of Personal Data
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
MageHost (MageHost B.V.)
MageHost is a hosting service provided by MageHost B.V.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
MageHost processes personal data on our behalf and does not use your data for its own purposes. However, this party can collect metadata about the use of the services. These are not personal data. MageHost has taken appropriate technical and organizational measures to prevent loss and unauthorized use of your personal data. MageHost is obliged to observe secrecy on the grounds of the agreement.
Place of processing: Netherlands
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
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Newsletter management
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Copernica (Copernica B.V.)
Copernica is an email address management and message sending service provided by Copernica B.V.
Personal Data collected: email adress, first name, last name, address, country and order history
Place of processing: Netherlands - Privacy Policy.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
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Backup saving and management
This type of service allows the Owner to save and manage backups of this Website on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Website.
Backup on Nomadesk (Nomadesk NV)
Nomadesk is a service to save and manage backups provided by Nomadesk NV
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Belgium – Privacy Policy.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
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Shipping and logistics
Shipping services enable this Website to deliver the ordered products to the User. To ensure greater security, this Website shares only the information necessary to process the shipment. Some of these services may also enable the sending of timed messages to the User, such as emails containing shipping confirmations and status updates.
PostNL (PostNL Holding B.V.)
PostNL is a shipping service provided by PostNL Holding B.V.
Personal Data collected: name, address, country and email address. When PostNL uses subcontractors they will share your data with this third party for the purpose of correct delivery.
Place of processing: Netherlands – Privacy Policy.
UPS (United Parcel Service, Inc.)
UPS is a shipping service provided by United Parcel Service, Inc.
Personal Data collected: name, address, country and email address. When UPS uses subcontractors they will share your data with this third party for the purpose of correct delivery.
Place of processing: United States – Privacy Policy.
DPD (DPD Nederland B.V.)
DPD is a shipping service provided by DPD Nederland B.V.
Personal Data collected: name, address, country and email address. When DPD uses subcontractors they will share your data with this third party for the purpose of correct delivery.
Place of processing: Netherlands – Privacy Policy.
Paazl (Paazl B.V.)
Paazl is a logistic service provided by Paazl B.V. which makes it possible to offer different shipping services on the Website.
Personal Data collected: name, address, country and email address. When DPD uses subcontractors they will share your data with this third party for the purpose of correct delivery.
Place of processing: Netherlands – Privacy Policy.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
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The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use this Website only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Website.
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Website depends on the payment system used.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
- right of access to Personal Data;
- right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
- right to receive their Personal Data and have it transferred to another controller (data portability);
- right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information.
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
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Internet or other electronic network activity information
Personal Information collected or disclosed:
Cookies, Usage data, Various types of data as specified in the privacy policy of the service, Various types of data, Email address, First name, Last name, Country, Address, Trackers, Tracker, Universally unique identifier (uuid), Unique device identifiers for advertising (google advertiser id or idfa, for example), Number of users, City, Device information, Session statistics, Browser information, Answers to questions, Clicks, Keypress events, Motion sensor events, Mouse movements, Scroll position, Touch events
Purposes:
- Analytics
- Handling payments
- Further information about Personal Data
- Data transfer outside the EU
- Displaying content from external platforms
- Contacting the User
- Interaction with external social networks and platforms
- Managing support and contact requests
- Advertising
- Tag Management
- Remarketing and behavioral targeting
- Backup saving and management
- SPAM protection
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC, Adyen B.V., PayPal Inc., SOFORT GmbH, Vimeo, LLC, Facebook, Inc., Zendesk, Inc., Klarna AB, Microsoft Corporation, Google Ireland Limited, Fonticons, Inc. , Meta Platforms Ireland Limited
Service providers or contractors: this Website, Google Ireland Limited
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Identifiers
Personal Information collected or disclosed:
First name, Email address, Last name, Usage data, Country, Address, Phone number, User id, Trackers, Universally unique identifier (uuid), Unique device identifiers for advertising (google advertiser id or idfa, for example), Tracker, Number of users, City, Device information, Session statistics, Browser information
Purposes:
- Contacting the User
- Registration and authentication
- Advertising
- Analytics
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Microsoft Corporation, Google Ireland Limited
Service providers or contractors: this Website
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Inferences drawn from other personal information
Personal Information collected or disclosed:
Usage data, Trackers, Answers to questions, Clicks, Keypress events, Motion sensor events, Mouse movements, Scroll position, Touch events
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google Ireland Limited
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Website.
For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You also provide Personal Information indirectly when you navigate this Website, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Website and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Website, if not stated otherwise within this document.