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Our privacy policy

Last update: September 30, 2018


This privacy policy (hereinafter referred to as the “Policy”) lay down the terms and conditions according to which Snowleader SAS, 45 Saturne street (74650 Chavanod, France), registered within the trade and companies registry of Annecy under no.507 679 025 (hereinafter referred to as “Snowleader”, “we”, “our”), protects the personal data it may collect and process, in particular pursuant to our general terms and conditions ( https://www.snowleader.com/en/cgv) and to our cookie policy ( https://www.snowleader.com/en/cookies-policy), in each and every single country where we offer our services.

 

 

Snowleader collects and processes the Personal Data of the Buyers and of the Buyers’ beneficiaries, as well as, more generally, of any prospect, applicant or web user of the Site (hereinafter referred to as the “Data Subjects”, “you”, “your”).

 

Capitalized terms must be construed according to the definitions of the general terms and conditions, the definitions of article 4 of the EC Regulation no.2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “GDPR”), or the definitions listed in this Policy and the other contractual documents of Snowleader.

What are the principles relating to the processing of Personal Data?

 

 

Snowleader collects or processes your Personal Data as “data controller”, for the purposes of providing you the Site and its services, and as such, Snowleader determines the means and purposes of the processing of your Personal Data.

 

Snowleader is liable for the Personal Data you share with us, and we undertake to process them in compliance with the applicable laws and regulations, including the GDPR. It notably implies:

  • - To collect and process your Personal Data in a lawfully and fairly manner;
  • - To collect your Personal Data for specified, explicit and legitimate purposes and not further process them in a manner that is incompatible with those purposes;
  • - To process only adequate, relevant Personal Data limited to what is necessary in relation to the purposes for which they have been collected and are processed;
  • - To make sure your Personal Data are exhaustive, accurate and, where necessary, kept up to data; and
  • - To host your Personal Data only for the time necessary in relation to the purposes for which they have been collected and are processed, in compliance with the laws and regulations on statutes of limitation.

 

What Personal Data do we collect, how and to what purposes?

 

 

Snowleader lists its processing of your Personal Data in the chart here below, and details (i) the services or circumstances under which Snowleader collects and/or processes your Personal Data (column 1), (ii) the categories of Personal Data (column 2), (iii) the purposes and the uses (column 3) and (iv) the legal ground upon which we ensure the lawfulness of our processing (column 4).

 

In order to include new services or practices, this Policy may be updated at any time at https://www.snowleader.com/en/privacy. We invite you to read the new version of the Policy, which replaces and supersedes the previous version at the date of its “last update”.

 

Situations Categories of Personal Data Means and purposes Legal ground
Sales and delivery of products on the Site Identity
Contact details, including billing adress and shipping adress
Purchase order information
In order to validate your order
In order to manage the contracts, purchase orders, shipping, invoices and accounting
Performance of Snowleader's GTCs
Provision of additional services
Online tracking,warranties,customer services
Identity
Contact details, including billing adress and shipping adress
Information on your service, warranty,right of withdrawal (dates, exchanges, etc)
In order to provide you with the service/ estimates you asked during an order
In order to manage the commercial relationship with you, including any request (information or purchase), withdrawal or litigation
Performance of Snowleader's GTCs
Including actions and exchanges before and after the contract's term
Snowleader loyalty program Identity
Contact details, including billing address and shipping address
Membership information (status, loyalty points, validity,advantages)
Payment information
In order to apply the loyalty options to your orders on the Site
In order to process and follow your membership (including any payment)
In order to process any feedback from you (including any potential litigation)
In order to create statistics
Performance of Snowleader's GTCs
Payment plans Identity
Contact details, including billing address and shipping address
Purchase order, additional service and membership information
Payment information (payment plan, costs, duration, etc...)
In order to provide you with estimates
In order to process your instalments
In order to process any feedback from you (including any potential litigation)
In order to create statistics
Performance of Snowleader's GTCs
Newsletter and commercial communications subscriptions Buyers:
Identity;
Contact details
Purchasing history

 

Other Data Subjects:
Identity
Contact details
Buyers:
In order to send marketing messages on product and services similar to those already purchased
Other Data Subjects:
In order to send the newsletter
In order to send commercials (with your prior consent)
In order to maintain a list of Data Subjects who indicated us they did not want to be contacted
In order to create statistics or studies
Prior consent of Data Subjects
Snowleader's legitimate interest (improving and tailoring our messages),
Compliance with a legal obligation (maintain a list of no-contacts)
Site browsing
(See Snowleader's cookies policy)
Data on Site browsing:
Page views, Pages which redirected on the Site, Exit links used
Browsing information

 

Technical information:
IP address, MAC address, etc
Browser information
Device information
Comments on the Site's blog
In order to customize our services, our Site (customization, suggestions or advertising based on your interests)
In order to ensure the Site's features (display,interface,language,currency,screen resolution) and to improve your Site's experience (new features)
In order to protect and secure the Site against fraudulent or malicious use
In order to create statistics
Snowleader's legitimate interest
(Sites changes, stats and security)
Performance of Snowleader's GTCs (services on the Site)
Prior consent of Data Subjects (optional cookies for Site's services)
Careers Identity and contact details
Resume and application letter, job offers (degrees, experience, etc)
Interview feedbacks
In order to review job applications
In order to process recruitments
In order to recruit candidates
Prior consent of candidates to process their application
Snowleader's legitimate interest to find the best suited candidate for our job offer

Information and consent prior or simultaneous to the collection

 

 

Snowleader collects the Personal Data of each Data Subject in different ways. Depending on the activities, you may receive prior information on the processing of your Personal Data, or a message leading to this information.

 

- Direct collection: we may receive our Personal Data through the different features of the Site, including through your requests, your orders, the services you requested and the cookies uploaded by Snowleader on your device.

 

- Indirect collection: sometimes, we can receive your Personal Data from third parties, including from any partner or service provider which takes part to the provision of products and services available on Snowleader’s Site, or through cookies installed by third parties on your device.

 

When we collect Personal Data through forms (online and offline), we will point out the mandatory fields with a star. No answer to these fields may prevent you from accessing the service.

 

Most Personal Data laws and regulations in many jurisdictions do not require to obtain your consent prior to the collect, process or transfer of your Personal Data for the processing purposes listed in the chart here above. However, when required by law, we will obtain your consent prior to processing. In this case, you may withdraw your consent to the processing at any time, either by changing your choices on your “My Account” page on the Site, or by requesting so on the Site’s contact form, or pursuant to articles 8 and 9 of this Policy.

When do we disclose your Personal Data?

 

 

Some of your Personal Data may be disclosed to third parties.

 

Within Snowleader, staff members may have access to your Personal Data insofar as necessary in order to provide you the products and services you have requested, to ensure the technical maintenance, the protection and the security of the Site, or with your prior authorization (in particular for direct marketing messages).

 

1 - Disclosure to partners and service providers

 

Partners and third party service providers may access your Personal Data, acting (i) either as data processors (as defined by the GDPR) in order to provide Snowleader services as required in order to achieve the processing purposes listed here above (hosting, maintenance, marketing), (ii) or as data controller in order to provide other services in addition to Snowleader services, such services to be clearly identified and placed under their sole liability (payment services, payment by instalments, third party cookies and in particular social network cookies) pursuant to articles 10 et seq. here below.

 

2 - Disclosure to public authorities and public bodies

 

As required under applicable laws and regulations, or with your specific authorization, Snowleader may disclose your Personal Data with third parties, including any public body, legal officer, ministerial officer or debt collection agency, in order to:

        (i)Protect the rights, the property or the security of the Data Subjects, Snowleader, Snowleader staff members or third parties;
          (ii)Proceed to Snowleader’s change of assets in the event of mergers & acquisitions or sale of assets (in this situation, your Personal Data will be disclose to the potential buyer, and the potential buyer will be liable to renew information and consent collection operations when needed under applicable laws and regulations) ; and
            (iii)Comply with a legal obligation, with a court or administrative order, a judicial award of any nature whatsoever or in order to implement the enforcement measures ordered by competent authorities.

 

Where do we host your Personal Data?

 

 

Snowleader uses the services of Smile Hosting and Smile Hosting’s sub-processors service providers in order to host the Site, including the Personal Data collected and processed on the Site. Smile Hosting and its sub-processors host the Personal Data in France.

 

Snowleader provides its services in the European Union and in Switzerland, but some of its third-party service providers are located in other countries. As a result, we may transfer your Personal Data from a country within the European Economic Area (“EEE”) towards a country outside of the EE. When Snowleader transfers Personal Data outside of the EEE, this transfer will always be done in a secured and lawful manner, either:

 

- By transferring the Personal Data towards countries which have a level of protection of personal data deemed adequate by an adequacy decision of the European Commission;

 

- By transferring the Personal Data to a third party recipient in the United States which is Privacy Shield certified, such certification been construed by an adequacy decision of the European Commission as providing an adequate level of protection of your Personal Data;

 

- By enforcing the European Standard Contractual Clauses (as executed between Snowleader and its subsidiaries or between Snowleader and its service providers) which have been approved by the European Commission as providing an adequate level of protection of your Personal Data; or

 

- By transferring your Personal Data to third-party service providers which have implemented Binding Corporate Rules compliant with article 47 of the GDPR.

 

How much time do we keep your Personal Data ?

 

 

We keep your Personal Data as long as necessary for the purposes of the processing for which they were collected (typically for the contractual term when you buy a product or use a service, and which can be extended until the service has been fully provided or until the product has actually been received and the corresponding right of withdrawal has expired).

  • - When you contact us with an information request, we keep your Personal Data as long as necessary to proceed your request (unless your request leads to an order from you, in which case the retention period is extended for the order time period previously referred to here above);
  • - When you have accepted to receive directy marketing messages, we keep your Personal Data until you unsubscribe or after a period of inactivity (absence of any positive contact from your part) which is set to three years in France;
  • - Where cookies are loaded on your device, we keep them as long as necessary for their purposes, up to a time period set by applicable local regulations and best practices, which is thirteen months in France; and
  • - When you contact us to apply to Snowleader’s job offers, or in order to present an unsolicited application, we keep your Personal Data until the position has been filled or for a time period which can not exceed the maximum retention period in France (two years from application date).

 

Each time, we may archive your Personal Data for an additional time period, notably pursuant to specific laws and regulations or until expiration of applicable statutes of limitation. In the event we were to keep your data for a longer time period for other reasons, we will provide you with these reasons and with the applicable retention period upon collection of your Personal Data.

How do we protect your Personal Data?

 

 

 

We undertake to keep your Personal Data safe and to take all reasonsable precautions to this end. We implement technical and organisational measures as necessary for this Policy and pursuant to the applicable laws and regulations in order to protect your Personal Data against any unauthorized access, change, disclosure, loss or destruction, notably by SSL-type data encryption (Secure Socket Layer). We contractually impose the same commitments to those of our service providers that process your Personal Data.

 

You must ensure the security and confidentiality of your Site’s access credentials (identified, password) in order to prevent unlawful use or misappropriation of your user account (identity theft).

Your rights

 

 

You enjoy a certain number of rights related to your Personal Data, i.e.:

 

  • - A right of access and information: you have the right to be informed of the way in which your Personal Data is processed, and in particular, you have the right to obtain (i) confirmation as to whether or not Personal Data concerning you are being processed, and, when it is the case (ii) to access such Personal Data and obtain a copy thereof.

 

  • - A right to rectification: you have the right to obtain the rectification of inaccurate Personal Data or to complete incompleted Personal Data, including by providing a supplementary statement.

 

  • - A right to erasure (‘right to be forgotten’):in some cases, you have the right to obtain the erasure of your Personal Data. However, this is not an absolute right and Snowleader may have legal or legitimate grounds for keeping such Personal Data.

 

  • - A right to restriction of processing: in some cases, you have the right to obtain the restriction of the processing of your Personal Data.

 

  • - A right to data portability: you have the right to receive the Personal Data you have provided to Snowleader, in a structured, commonly used and machine-readable format, and you have the right to transfer these Personal Data to another data controller without opposition from Snowleader. This right only applies (i) when the processing of your Personal Data is based on your consent or on a contract and (ii) when such processing is carried out by automated means.

 

  • - A right to object to processing: you have the right to object at any time to the processing of your Personal Data. When you exercise your right to object to a data processing based on the legitimate interest of Snowleader, Snowleader may still claim compelling legitimate grounds to continue the processing to which you are objecting.

 

  • - The right to revoke your consent, at any time, to a processing based on your consent: you may withdraw your consent to the processing of your Personal Data when such processing is based on your consent. The withdrawal of your consent does not affect the lawfulness of the processing carried out on the basis of such consent prior to its withdrawal.

 

  • - The right to file a complaint with the supervisory authority: you have the right to file a complaint with your Data Protection Authority for the protection of Personal Data.

 

  • - The right to give instructions concerning the use of your data after your death: you have the right to give Snowleader instructions concerning the use of your Personal Data after your death.

 

  • - The right to obtain a copy of the standard contractual clauses executed by Snowleader when your Personal Data are transferred outside of the EEA.

 

For further information on your rights and on how to exercise them, please see article 9 “contact” of this Policy. Please note that we may require you to demonstrate your identity and to fully justify the information included in your request, before processing our request.

Contact

 

 

If you have any questions or concerns about how we process and use your Personal Data, or would like to exercise one your rights as abovementioned, please contact us by using the contact details here below:

 

- 0820 420 374 (0,12€/min), Monday to Saturday, 9 am - 7 pm

- contact@snowleader.com (Answer within 48h)

- On our live Chat on the Site, Monday to Saturday, 9 am - 7 pm

- Live on Skype Monday to Saturday, 9 am - 7 pm

 

You may also exercise your rights by sending your request through the contact form on the Site.

Third party data processing throught the Site

 

 

Snowleader only provides third parties with Personal Data as necessary for Snowleader’s services, provided they do not process your Personal Data for other purposes than those listed hereunder. Such third parties only act on Snowleader’s instructions when they are data processors within the meaning of the GDPR: they are legally bound to comply with the applicable data protection laws and regulations and contractually bound to ensure the same level of security and confidentiality for your Personal Data as Snowleader ensures for you.

 

More specifically, Snowleader informs you that your mailing address, email and phone number are transferred to your shipping service providers for the performance of the services, including in order to execute your delivery choices, to notify you or provide you with a shipping follow-up or to send you customer survey. Some of these service providers, which are data processors within the meaning of the GDPR, may transfer these Personal Data outside of the EEE (see article 5):

 

  • - La Poste may transfer them to its subsidiaries and third-party service providers in Morocco which partake in the outsourcing of some of its client services, as well as in the third-party remote maintenance of software used by its client services; the transfer framework is generally pending the execution of the standard contractual clauses of the European Commission;
  • - TNT may transfer them to its subsidiaries and third-party service providers outside of the EEE for the purposes of managing customer relationship and performing shipping, notably for international shipping; TNT has implemented a lawful transfer framework, which may be provided to you by TNT upon request; and
  • - TDI may transfer them, through its online shipping platform, to carriers for the purpose of performing shipping as well as to service providers for technical support and maintenance of such online platform, under its sole responsibility.

 

Snowleader hereby details information on those of its third-party service providers (i) which collect and process your opinion on the Site and on Snowleader, including for warranty or prelitigation, (ii) which collect and process your payment data and (iii) which share your Personal Data on social networks, in particular because these third parties may require your consent or when they act as data controller to provide their services.

 

This information is not exhaustive and Snowleader invites each Data Subject to read the privacy policies of its partners and third-party service providers which collect and/or process your Personal Data from and outside of the Site, through Snowleader or under their own responsibility.

 

Review and trust service providers

 

1 - Snowleader has included a Trustpilot on the British, Belgian and Spanish versions of the Site. Trustpilot is a platform which collect client reviews on companies, and where Snowleader can get feedback and statistics on its customers’ satisfaction. These reviews are verified and analyzed by Trustpilot to ensure they are genuine, and the Site is able, through the Trustpilot component, to disclose the opinions on the Site by Snowleader’s Buyers.

 

Trustpilot provides its services in France through its legal entity Trustpilot A/S, registered under CVR n°30 27 65 82 and located Pilestræde 58, 5th floor, 1112 Copenhagen K, Denmark.

 

When you are visiting the Site, you may access Trustpilot’s platform by clicking on hyperlinks included for this purpose on the Site. After your purchase, you may also receive an email from Trustpilot inviting you to leave a review on the Site or on Snowleader, through Trustpilot’s platform, at the email address you have given to order your purchase.

 

When you write a review on Trustpilot’s platform, you provide Trust pilot with Personal Data (i) necessary to post a review, such as your identity (user name, access credentials), your email, your review and evaluations, or (ii) optional (public profile, order info, feedback documents, “likes”). Trustpilot also collects and processes your connection data on the review platform (IP address, browser settings, location).

 

You may rectify or erase your Personal Data hosted and processed by Trustpilot at any time, and in particular by deleting your account and its reviews on Trustpilot’s platform, and you may also claim for your right to object Trustpilot’s processing.

 

These Personal Data may be collected and hosted in several member states of the European Union as well as in the United States and in Australia. Trustpilot may also transfer these Personal Data to subsidiaries, service providers and data processors (including social networks) in order to comply with its contractual obligations or in order to enter into other Personal Data processing under its control and sole liability.

 

You may access Trustpilot’s privacy policy at:

https://legal.trustpilot.com/end-user-privacy-terms

 

 

2- Snowleader has included a Trusted Shops component on the French, German, Swiss, Austrian and international versions of the Site. Trusted Shops is a service allowing customers to buy on websites listed as “trusted” by Trusted Shops, to leave reviews on the reliability of these online websites, and to enjoy additional warranties linked to their purchases on these sites (in the event of no delivery, or when the non-compliant product or service is returned, the customer is fully reimbursed up to €2,500).

 

Trusted Shops provides its service in France through its subsidiary Trusted Shops France SARL à associé unique, registered with Amiens trade and company registry under no.825345655, and located at 660 route d’Amiens, 80480 Dury, France. Its website and its pages on social networks are managed by Trusted Shops GmbH, registered with Koln’s lower civil court in Germany under no.32735, and located at Subbelrather Straβe 15c, 50823 Koln, Germany.

 

When the Site uses the services of Trusted Shops, the Personal Data of the order or each Buyer are transferred to Trusted Shops, with the Buyer’s authorization, or in order to provide the Buyer with the additional contractual warranty. Trusted Shops also collects directly Personal Data relating to each visitor’s browsing (browser, date, time, IP address and connection information) on the Site.

 

When you buy on the Site, you may be invited by Snowleader or by Trusted Shops to leave a review on the Site or on Snowleader through Trusted Shops online platform. If you write a review to Trusted Shops, you provide Trusted Shops with Personal Data related to your identity, your contact details, your reviews and evaluations and your order information (which will be correlated with the products you purchased on Snowleader’s Site). Trusted Shops also collects and processes your connection data on its review platform.

 

Trusted Shops does not collect any Personal Data on the Site if you do not buy products benefitting from Trusted Shops warranty and if you do not reply to Trusted Shops’ invitation to leave a review on Trusted Shops platform. You may also rectify or erase your Personal Data as hosted and processed by Trusted Shops, if they are not required for further processing, and you may claim the application of your rights to limit or object to Trusted Shops’ processing (including direct marketing processing).

 

Trusted Shops uses a third-party payment service provider located in a country outside of the European Union as well as credit agencies located in Germany. In particular, the hosting service providers of its websites are located in Germany and in the United States. Any transfer to a service provider located in the United States is conditioned to its certification to the EU-US Privacy Shield. Moreover, Trusted Shops entered into standard contractual clauses as set by the European Commission as international transfer framework.

 

You may read Trusted Shops’ privacy policy at:

https://business.trustedshops.co.uk/imprint

 

 

3- Snowleader subscribes to the FEVAD code of ethics, and uses the FEVAD’s services in order to get analytics as well as an ombudsman service between Snowleader and consumers. Using an ombudsman is a mandatory required for Snowleader’s Site pursuant to several French and European laws and regulations. When a complaint meets the conditions set by law for mediation, the FEVAD’s ombudsman may be contacted by the web user of by Snowleader.

 

The Fédération du e-commerce et de la vente à distance is a nonprofit association under the French law of 1901, which purpose is to ensure ethical and sustainable development of online commerce and remote sales in France. It is located at 60 Boétie Street, 75008 Paris, and registered under SIREN no.784 854 994 (phone number +331 4731 8541, contact@fevad.com).

 

In this mediation system, Snowleader may provide the FEVAD with the Personal Data related to the identity, the contact details, the contracts, orders and exchanges between the Buyer and Snowleader, along with any relevant information considering the specifics of the litigation (product, price, discount, payment, shipping, reimbursement, compliance with warranties, etc.). Personal Data transferred for the purposes of analytics are anonymized in order to present aggregated results, and are not retained by the FEVAD.

 

The FEVAD ombudsman may transfer the case to sectorial mediation centers for some products / services. You may put an end to the mediation at any time or by refusing the settlement offer. The FEVAD will keep information on your mediation until the applicable statutes of limitations expire.

 

The FEVAD undertook to apply the highest level of confidentiality to all Personal Data received for the purposes of analytics or ombudsman services.

 

Payment service providers

 

In order to make credit card transactions as secure as possible, the various payment services offered by the Site use the 3DS system, a software created by Visa and Mastercard. After entering his/her banking information, a window pops up and the Buyer must enter his 3D secure code, which authenticates him and confirms that it is the cardholder who makes the payment. Thus, even though the Buyer’s bank details were stolen or obtained in any way by a third party, they could not be used without knowing the personal authentication code.

 

4- Snowleader has integrated a Paypal component on the Site. PayPal is a payment service provider. Payments are made via dedicated online payment accounts or, for people who do not have a PayPal account, directly by credit card. A PayPal account is managed from an email address. PayPal provides payment services and contractual protection for buyers.

 

PayPal operates in Europe through its subsidiary PayPal (Europe) SARL & Cie, SCA, 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

 

If a Buyer selects PayPal as a payment method on our Site, the Buyer is informed and agrees that his/her Personal Data may be automatically transferred to PayPal for the processing of the payment of his/her order. The categories of data transferred to PayPal are related to its identity, contact details and data required to execute transactions (i.e. the orders).

 

Snowleader transfers these Personal Data to PayPal for the purpose of payment processing (execution of the contract with the Buyer) and to fight against fraud (legitimate interest of Snowleader and PayPal). Such Personal Data may also be transferred to credit verification agencies in order to check the identity and creditworthiness of the Buyer.

 

PayPal may in turn transfer these Personal Data to its subsidiaries, service providers and subcontractors when necessary, in order to comply with its contractual obligations or in order to process the Personal Data under its control and responsibility.

 

You may withdraw your consent to the processing of your Personal Data by PayPal at any time, including by choosing another payment method. The withdrawal of your consent is only valid for the future, and does not affect the Personal Data that must be transmitted or processed to process payment for your order.

 

You can view PayPal's privacy policy at:

https://www.paypal.com/uk/webapps/mpp/ua/privacy-full

 

5- Our partner Oney Bank offers you a financing solution called Facily Pay, which allows you to pay for your purchases from €100 to €4,500 in 3 or 4 times with your credit card. We invite you to consult our general terms and conditions of sale at https://www.snowleader.com/en/cgv.html for more information on the Facily Pay financing solution

 

Oney Bank is a public limited company registered with the Lille trade and companies register under no.546380197, and located at 40 avenue de Flandres, 59170 Croix, France. Oney Bank is a credit institution approved by the French Prudential Supervisory Authority and is subject to its supervision.

 

If this financing solution is used, the Buyer issues an instalments request by providing his/her Personal Data to Oney Bank. The Buyer can also create a personal client account on the Facily Pay service. In both cases, Oney Bank is data controller and processes these Personal Data (identification data, financial data, browsing data) under its sole responsibility and control.

 

Oney Bank processes these Personal Data in order to comply with its legal obligations (credit check, anti-money laundering and anti-terrorist financing), in order to reply to your financing request and for profiling and direct marketing purposes. You may object to any profiling or direct marketing by contacting Oney Bank by clicking on the unsubscribe link in its advertising messages or as indicated by Oney Bank

 

Oney Bank may transfer Personal Data to public authorities and to service providers and agents, some of whom are located in Morocco and in the United States. These transfers are governed by the execution of standard contractual clauses of the European Commission, a copy of which can be obtained from Oney Bank.

 

Oney Bank's privacy policy regarding Facily Pay service can be found at: https://www.oney.fr/site/b/informations-legales/protection-des-donnees.html

 

Oney Bank’s privacy policy regarding the Facility Pay customer account can be found at: https://www.comptefacilypay.oney.fr/politique-donnees-oney.pdf

 

6- Snowleader uses the services of the payment service provider European Merchant Services ("EMS"), in particular for transactions made using the Bancontact payment method on the Belgian version of the Site. Buyers may use the payment methods offered by EMS to pay for their orders on the Site. Snowleader and EMS process the Buyer's Personal Data on this occasion.

 

EMS is a company registered with the Dutch Commercial Register under no.34226533 and located at 25 Herikerbergweg, 1101 CN Amsterdam, Netherlands. It is owned by First Data Corporation, registered in the State of Delaware under no.2192851, with registered office at 5565 Glenridge Connector NE, Suite 2000 Atlanta, GA 30342, USA, and which operates in Europe through its First Data subsidiary at 1 Canada Square, Canary Wharf, London E14 5AB, UK.

 

Snowleader and EMS act as joint data processors for the Personal Data relating to the Buyer and the transaction. Under the applicable laws and regulations in some countries, EMS may collect and process sensitive data solely for the purpose of authenticating payments through the use of fingerprints.

 

The Buyer’s Personal Data may be used by EMS or one of its affiliates (such use being governed by Binding Corporate Rules), as well as transferred to credit reference and fraud prevention agencies or to suppliers, in order to comply with its contractual obligations or in order to process Personal Data under EMS' exclusive control and responsibility.

 

You may withdraw your consent to the processing of your Personal Data by EMS at any time, including by choosing another payment method, by contacting EMS or by clicking on the unsubscribe link attached to any EMS marketing communication.

 

You can read EMS' privacy policy at:

 

https://emspay.be/fr/privacy-information-notice

 

7- Snowleader uses the online transaction platform of the payment service provider CIC Lyonnaise de Banque in order to manage online payments. This platform alone collects and uses the Buyer’s data provided at the time of payment (card number, validity date, etc.). Snowleader executes your order once it receives the confirmation of your payment.

 

CIC Lyonnaise de Banque is a public limited company registered with the Lyon trade and companies registry under no.954 507 976 and whose registered office is located at 8 rue de la République, 69001 Lyon. CIC Lyonnaise de Banque is data controller for processing on its online transaction platform.

 

You may withdraw your consent to the processing of your Personal Data by CIC Lyonnaise de Banque at any time, in particular by choosing another payment method or by contacting the Data Protection Officer of CIC Lyonnaise de Banque, 63 chemin Antoine Pardon, 69814 Tassin Cedex.

 

You can read CIC Lyonnaise de Banque's privacy policy at:

https://www.cic.fr/fr/informations-legales/protection-des-donnees.html

 

8- Postfinance SA provides Snowleader with specific payment methods, available directly on the Site or through a payment service provider, in order to enable Buyers to pay for their orders using PostFinance payment methods, which are intended for people domiciled in Switzerland. These payment methods are not available for Buyers domiciled outside of Switzerland, particularly those within the European Union.

 

Postfinance AG is a subsidiary of Swiss Post AG, registered under company identification number CHE-114.583.749 and domiciled at Mingerstrasse 20, 3030 Bern, Switzerland.

 

Upon payment, when entering and processing Personal Data relating to the Buyer, his order and the transaction, PostFinance applies the provisions of the Swiss data protection laws. PostFinance outsources certain activities to its partners, in particular within the postal group to the sister companies Poste CH and Swiss Post Solutions SA.

 

You may read PostFinance's privacy policy at:

https://www.postfinance.ch/en/detail/privacy.html

 

9. Snowleader’s Site uses the Payline online payment service provided by Monext in order to enable Buyers to carry out their transactions. By using the payment methods offered by Payline to pay for their orders on the Site, Buyers acknowledge and accept the processing of their Personal Data by Snowleader and Monext. Monext cross-references the Personal Data collected on the Site with other data from publicly available information (in particular from the public part of social networks), in compliance with applicable laws and regulations.

 

Monext is a simplified joint stock company registered with the Nanterre trade and companies registry under no.503185001, and domiciled at Tour Ariane, 5 place de la Pyramide, 92088 Paris La Défense Cedex. It hosts its services on its own infrastructures and servers located in France.

 

In addition to processing your order and transactions where it acts as Snowleader’s data processor, Monext uses the Buyers’ Personal Data as data controller, at its sole discretion and under its exclusive control and responsibility, for customer relationship management purposes, based on its legitimate interest, and for direct marketing actions, based on its legitimate interest or with your consent.

 

You may object to the processing of your Personal Data by contacting Monext on their website or via the unsubscribe link on any commercial communication from them.

 

You can consult Payline's privacy policy at:

https://www.payline.com/en/legal-notice

 

Social networks

 

The Site includes several features allowing the Data Subjects to share content from the Site and from their browsing on social networks; you are invited to check under which conditions these third-party data controllers proceed to the processing of your Personal Data

 

1- Facebook is a social network that allows its users to communicate with each other and interact online, including in order to exchange opinions or experiences, as well as to access commercial (about products, services or companies) or non-commercial information. You can create personalized profiles, exchange content and create a network via friend requests on Facebook, among other things.

 

The Facebook group acquired Instagram in 2012, which provides the eponymous social network that also allows users to communicate with each other, and based in particular on the sharing of pictures and videos of each member, amateur or professional, through subscriptions to publications from several accounts. The Snowleader Site contains a link to Snowleader's professional account on Instagram.

 

Facebook and Instagram are managed by Facebook Inc. 1 Hacker Way, Menlo Park, CA 94025, USA. The data controller for persons residing outside the United States and Canada is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

 

Each time a page of the Snowleader Site includes a Facebook component (such as a sharing button), the Internet browser of the Data Subject is prompted by this component to download it from Facebook onto the Data Subject’s terminal. During this operation, Facebook is informed of which page of the Site is visited by the Data Subject.

 

If the Data Subject is connected to Facebook or Instagram at the same time, Facebook associates the pages visited on the Site with the Data Subject’s profile as well as with other browsing or device information, during his/her entire browsing on the Site, always through the Facebook components. Likewise, if the Data Subject clicks on one of these components, such as a "Like" button, or if they post a comment, Facebook associates these actions with the Data Subject's profile and keeps this information. Facebook shares and cross-references these information with other Facebook products (including Whatsapp) and with third parties.

 

Facebook receives these information from the Facebook components whether or not the Data Subject has clicked on the Facebook components, as long as he or she is connected to Facebook and/or Instagram. If you wish to object to this transfer of information to Facebook, you can do so by logging out of Facebook prior to any visit to the Site. You can also use the Facebook or Instagram settings to block certain processing, and unsubscribe from marketing communications. Other services include the removal of automatic data transmissions to Facebook, including through modules integrated into Internet browsers.

 

Facebook's privacy policy is available at https://www.facebook.com/about/privacy.

 

Instagram's privacy policy can be accessed from https://help.instagram.com/, under "Privacy and Security", option "Instagram Data Use Policy".

 

2- Twitter is a social network that allows users to exchange messages (or "tweets") limited to 140 or 280 characters, either privately between users or publicly accessible to all on the Internet, and financed by advertising. The Snowleader Site includes a link to Snowleader's professional account on Twitter, where Snowleader presents the activities of its teams, the products it offers for sale as well as the different sports and activities that can be practiced using them.

 

Twitter is managed by Twitter Inc. registered in Delaware under number C 3006676 and located at 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. For persons residing outside the United States, the data controller is Twitter International Company, 1 Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

 

If the Data Subject consults Snowleader's Twitter account, even without being logged in or having an account on Twitter, Twitter collects Personal Data relating to your browsing on Twitter, your location and your device, in particular in order to improve and personalize advertisements. These Personal Data are collected by Twitter even when only consulting the Site, without the Data Subject using Twitter.

 

If the Data Subject has a Twitter account, Twitter also collects tweets and interactions ("Likes") with the tweets in Snowleader's Twitter account, and these Personal Data are cross-referenced and associated with the Personal Data collected and processed on your profile.

 

You may object to the processing of your Personal Data by Twitter by logging out of your Twitter account before visiting the Site, by adjusting your account settings on Twitter in order to limit processing or by using the browsing settings of Internet browsers or of other dedicated applications.

 

Twitter's privacy policy is available at: https://twitter.com/en/privacy

 

Google data processing

 

Snowleader uses several separate Google services on the Site, including (i) the marketing and customer relationship analysis tools provided by Google Ads and (ii) the YouTube video hosting and sharing platform. These services are managed and provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, which is the data controller. Google LLC operates in France through its subsidiary Google France, registered no.443061841 in the Paris trade and companies registry, and located at 8 rue de Londres, 75009 Paris.

 

1- Google Ads is a range of professional services provided by Google for the purpose of analyzing Site visits, advertising management and customer relationship management. Snowleader uses Google Customer Reviews and Google Analytics, among other services. The purpose of these services is, respectively, to evaluate Snowleader and the Site through the collection and aggregation of opinions of Internet users and Buyers, and to provide Snowleader with analyses and statistics on Internet users who have visited the Site; Google may also process Personal Data collected for the purpose of maintaining and supporting these services, or in connection with other Google services.

 

a) Google Analytics: whenever the Internet user or the Buyer takes action on the Site, Google collects and processes, as a data processor on behalf of Snowleader data controller, the Internet user's login credentials (cookies, IP addresses, identifiers of the terminals used, Buyer credentials) as well as information associated with requests sent to Google Analytics' servers (IP addresses, date and time of requests, URL requested, subject of the request, browser and operating system type and language, device cookie). The IP address can be used to obtain the Internet user's geographical position.

 

Google Ads deletes part of the IP address (after 9 months) and cookie information (after 18 months) associated with requests. At Snowleader's request or at the end of the contractual relationship, Google deletes all personal data from its systems, subject to any applicable legal archiving obligations, within a period of up to 180 days from the request. You may also use, where Google has made such a mechanism available, the Google Ads service's data subject request tool, including in order to exercise your rights to object to the processing or in order to delete your Personal Data.

 

b) Google Customer Reviews : Snowleader provides Google with transaction information for each order placed on the Site, which may contain Buyers' Personal Data relating to their identity, personal life and economic and financial data. When a Buyer makes a purchase on the Site, he or she has the opportunity to participate in a survey and to receive an email from Google inviting him or her to give their opinion about the Site. If the Buyer agrees to participate, an email is sent to him once his order has arrived, inviting him to note his experience and give his opinion. The scores collected are then displayed on the Snowleader profile and are used for reviews on Snowleader (display on advertisements and in Google's search results on Snowleader and the Site). The reviews are in the form of a short questionnaire allowing the Buyer to evaluate his buying experience on the Site. Google Customer Reviews also provides Snowleader with a dashboard with analysis and statistics related to surveys and opinions on Snowleader.

 

When you have a Google Account, you can decide whether your name and photo should appear next to your opinions and recommendations when they are posted to the public.

 

More information can be found at:

https://privacy.google.com/businesses/adsservices/

https://policies.google.com/technologies/ads?hl=fr

 

2- Youtube is a video hosting and sharing platform that allows you to view and comment on the content posted by its users, and which is financed by the insertion of ads, more or less personalized according to your browsing and your user account (account dedicated to YouTube or associated Google account).

 

Each time a page on the Snowleader Site contains a YouTube component (such as a sharing button), the Internet browser of the Data Subject is prompted by this component to download it from Google onto the Data Subject's terminal. During this process, Google is informed of which page of the Site is visited by the Data Subject, as well as of unique identifiers related to the browser, application or device used by the Data Subject.

 

YouTube's privacy policy is available at: https://policies.google.com/privacy

 

 

If the Data Subject is connected to his or her Google account on the various services offered by Google, Google collects and correlates information about the Site to the Personal Data in the Google Account. If the Data Subject uses an Android device on which Google applications are installed, the terminal regularly exchanges information with Google servers. Google collects information about the Data Subject’s activity on each of the services provided by Google.

 

Google may host and process your Personal Data in the United States or in other countries outside the EEA and Switzerland (à Taïwan et à Singapour). Google is Privacy Shield certified for the processing of Personal Data in the United States and complies with Article 28 of the DGPS for other international transfers of Personal Data.

 

You can set up the use of your Personal Data by Google on the various Google services. If you wish to opt out of Google's information collection, you can do so by logging out of the services you have logged in to with your Google Account before using the Site. Other services allow you to prevent automatic data transmissions to Google's various services, including through modules integrated into web browsers.