Privacy Policy for Haypp Group

Responsible Haypp-company

Haypp Group is a group of companies that consists of different companies conducting e-commerce sales of tobacco-and nicotine products. This privacy policy applies to all operative companies within the Haypp Group (see list below).

 

The company that you are a customer of is controller for the personal data processing of your personal data. In the table below you see our companies, their respective websites and contact details.

 

Companies and contact details

Website(s)

Contact details to customer service

Haypp AB (org.nr. 559174–2738)

Birger Jarlsgatan 43, 111 45 Stockholm

SWEDEN

haypp.com

+46 (0)10 8848788

Cs.se@haypp.com

Northerner Scandinavia AB (org.nr.    556559–1699)                                                                                                   Kungsportsavenyn 21 1TR, 411 36 Göteborg

SWEDEN

northerner.com

helpdesk@northerner.com

Northerner Scandinavia AS (org.nr. 921 463 847)

Vangsveien 10, 1814 Askim, NORWAY    

snus.com

+47 41246788

kundeservice@snus.com

Northerner Scandinavia Inc

6 State Rd

Mechanicsburg, PA 17050

UNITED STATES OF AMERICA

nicokick.com

info@nicokick.com

Snusbolaget Norden AB (org.nr. 556801-3683)

Birger Jarlsgatan 43, 111 45 Stockholm

SWEDEN 

snusbolaget.se

snusmarkt.ch

+46 (0)8 588 849 80 (Sweden)

info@snusbolaget.se (Sweden)

 

+41 44 505 174 (Switzerland)

kundenbetreuung@snusmarkt.ch (Switzerland)

Snushjem.no AS (org.nr. 919649585)

C/O PKF ReVisjon AS

Sandstuveien 70 G, 0680 Oslo

NORWAY

snushjem.no

+472103723

info@snushjem.no

Snuslageret.no AS (org.nr. 816392802)

C/O PKF ReVisjon AS

Sandstuveien 70 G, 0680 Oslo

NORWAY

snuslagret.no

+472103723

kundeservice@snuslageret.no

 

Haypp has appointed a data protection officer, you may contact Haypp's data protection officer by email at privacy@hayppgroup.com or by mail at the addresses listed above for each respective Haypp-company (please mark the letter with "Att. Data Protection Officer”).

 

In this privacy policy, when "Haypp" or "we" is used, it means the Haypp-company responsible for the processing of your personal data, according to the compilation above.

The applicability of the privacy policy

Haypp is the responsible company for the processing of your personal data when using the Haypp's Website or mobile website (collectively (“Website”)) or contacting us through our Customer Service. We are strongly committed to protecting personal data.  This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.  It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

Which personal data do we collect?

Haypp collects, uses and otherwise processes the following personal data about you:

- Name and date of birth

- Address

- Gender- Phone number and email

- Marital status

- Education

- Household composition

- Income

- Payment details

- Account information including your marketing preferences

- Your communications with us

- IP address and information about your use of Haypp's Website

- Clickstream data, for example how you arrived at our Website and where you went after leaving our Website

- Technical data including your login data, browser type and version, time zone setting and location, browser plug-in types and versions and operating system and platform

- Hashed identifiers

- Information about visitor statistics, which of our goods or offers you have been interested in, how you have interacted with our newsletters

- Information about your purchases

- Your feedback and survey responses, which may include data relating to your lifestyle and usage of our products

- Third party demographic data

 

We also collect and process aggregated data, such as statistical or demographic data. This data may be derived from your personal data but has been fully anonymized.

 

We collect your Personal Data through direct interactions with you, for example when you submit an order to us, create an account, complete one of our surveys or contact our customer services centre. We also collect your Personal Data through the use of automated technologies when you interact with our Website. We may also collect your personal data from third parties such as analytics providers, advertising networks and data brokers or aggregators.

How we use the information collected

Haypp processes personal information mainly for the purposes stated below and for any additional purposes stated at the point of collection:

- In order to manage your order / purchase and manage your user account;

- To enable good customer service / manage customer service issues, such as managing your requests, correcting incorrect information, or sending information you have requested e.g. newsletters;

- To communicate with you, including providing order updates;

- To provide you with information relating to products and services that may be of interest to you, including offers and promotions of both a general and targeted nature;

- For the purpose of sharing hashed identifiers with social media platforms, in order to identify users of both our Website and those platforms;

- In order to fulfill legal obligations; and

- For other business-related purposes, including negotiating, concluding and performing contracts, managing accounts and records, supporting corporate social responsibility activities, legal, regulatory and internal investigations and debt administration.

- In order to conduct analytics and carry out market research;

- In order to learn more about what products and services may be of interest to you. This may include analyzing information about: your usage of our Website, which of our products, services and offers you (and other customers like you) have been interested in, which of our newsletters you have interacted with, product feedback and survey responses you (and other customers like you) have provided and information about your purchases and your communications with us. We may also combine your personal data with personal data, including demographic data, provided by third parties, in order to provide us with more information about what products and services you, and other customers like you, may be interested in. If you would like us to stop supplementing your data in this manner, you can send an email to privacy@hayppgroup.com, detailing your request;

- In order to carry out propensity scoring in relation to our customer base, using machine learning, based on both segment and individual attributes;

- For the development and improvement of our marketing, promotion and advertising strategies, including informing our marketing lists and advertising campaigns;

- To report on the success of our marketing campaigns;

- To identify whether or not you may be interested in completing our surveys;

- To produce anonymous, aggregated datasets, and to conduct analytics on these datasets, which inform our business and marketing strategies and which we may provide to our partners for their business use;

- For system administration and for obtaining statistical data about the behavior and patterns of our users at an aggregated level;

- To create audiences within social media platforms and direct advertising campaigns to those audiences;

- In order to develop, deliver and improve our products and services through analysis of the use of our Website;

- In order to help us develop our Website to be more useful and to enhance and tailor your user experience of the platforms offered by Haypp, by customizing the display of services to the device being used;

- In order to provide you with important messages such as information about changes in our terms and policies;

Marketing

We may use your Personal Data to form a view on which of our products may be of interest to you. You may receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing. We may send these communications to you by email, phone, SMS or push notification. We may also provide you with promotional content via the social media platforms that you interact with.

 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. You can also opt-out of receiving marketing messages and / or receiving promotional content via social media platforms by sending us an email or contacting us by phone.

Regarding your birth date

We ask you to provide your birth date when first entering the Website and when placing an order. We require this information in order to verify your age. The legal basis of processing of this data is our obligation to comply with age limit limitations for the sale of tobacco-and nicotine products.

 

The Website is not intended for children and we do not knowingly collect data relating to children.

Information that may be disclosed

We may share your personal data with people within Haypp who have a “need to know” that data for business or legal reasons, for example, in order to carry out an administrative function such as processing an invoice.

 

The Haypp-companies operating within the EU/EEA cooperate to maintain a shared customer database with good data quality. Within the shared customer database, personal data is processed for marketing purposes. The collaboration is administered by Snusbolaget Norden AB to which your personal data is shared. Snusbolaget Norden AB will process your personal data for these purposes as personal data processor for the other Haypp-company which is responsible for the processing your personal data.

 

Because we operate internationally, we may share your personal data with any entity within the Haypp group worldwide. These entities are required to maintain the confidentiality of your data and are restricted from using it for any purpose other than the purposes set out in this privacy policy.

 

We may share information with third party companies that process data on our behalf, in order for us be able to perform our services and deliver products requested by you. For example, we share personal data with our providers of analytics, distribution, IT and other services as is necessary for the running of our business. We may also disclose information to third party companies for usage in the evaluation and disclosure of reviews of our services and our Website, as well as market research.

 

We may share your personal data with our third party business partners, in order to obtain demographic data from those partners, which helps us to learn more about you and the products and services that you, and other customers like you, may be interested in. If you would like us to stop supplementing your data in this manner, you can send an email to privacy@hayppgroup.com, detailing your request.

 

We may disclose your personal data to third parties including the authorities and our professional advisors, for the purposes of seeking legal or other professional advice; to respond to a legal request or comply with a legal obligation; in order to protect any intellectual property rights in materials displayed on or otherwise available from our Website; and to enforce our Website terms and conditions.

 

We may disclose your Personal Data to third parties in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets.

 

Finally, we may share non-personal data with other third parties that are not described above. When we do so we aggregate the information so that a third party should not able to link data to you, your computer, or your device. Aggregation means that we combine the non-personal data of numerous people together so that the data does not relate to any one person. We may sell this anonymous, aggregate data to third parties for their business use.

We always apply a high level of security and confidentiality when processing all personal data.

Transfers of personal data 

Some of the companies that we work with are based outside the UK / EEA, meaning that their processing of your Personal Data will involve a transfer of data outside the UK / EEA. Whenever we transfer your Personal Data out of the UK / EEA, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards in accordance with applicable data privacy laws, for example, where service providers are based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield.

 

If you are located in the EEA or the UK, you can request a copy of the safeguards which we have put in place to protect your personal data and privacy rights by contacting us at privacy@hayppgroup.com

About cookies

We use cookies when you visit the Website. Read more about how we use cookies in our cookie policy which can be found on our websites.

Lawful basis for processing personal data

The lawful bases for processing your personal data are:

 

(a) Your consent.

 

(b) Contract: the processing is necessary in order for Haypp to fulfil the purchase contract between you and Haypp.

 

(c) Legal obligation: the processing is necessary for Haypp’s legal compliance.

 

(d) Legitimate interests: the processing is necessary for Haypp’s legitimate interests, which may include one or more of the following:

- running our business;

- analyzing how customers purchase and use our products and services;

- developing our products and services;

- informing our marketing strategy;

- defining categories of customers for our products and services;

- keeping our website up to date and relevant;

- producing sophisticated, aggregate datasets which we can sell to third parties;

- provision of administration and IT services;

- keeping our records up to date;

- securing our network and systems; and

- growing our business. 

Your rights and choices

You have certain specific legal rights in relation to the personal data that we process about you. A summary of these rights follows below.

 

Right to access. You have the right to be informed of, and request access to, the personal data that we process about you.

 

Right to data portability. You have the right, in certain circumstances, to request a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format. Provided that it is technologically possible, as determined at Haypp’s sole discretion (acting reasonably), you also have the right to request that we transfer this personal data to another controller.

 

Correction of erroneous information. You have the right to request that we correct or update erroneous or incomplete personal data that we hold about you. If you have an account you may also correct certain information by logging in.

It is important that the personal data we hold about you is accurate and current. Please therefore keep us informed if your personal data changes during your relationship with us.

 

Deletion of certain data. You have the right to request that we delete your personal data under certain conditions.

 

In certain cases, we must retain your personal data despite your request, owing to legal requirements such as accounting and tax legislation, or for example if we need to retain certain data in order to establish, enforce or defend a legal claim.

 

Right to restrict processing of your personal data. You have the right to request that we restrict our processing of your personal data in certain cases. If, for example, you claim that your personal data is incorrect, you can request a restriction on processing for a period of time that will give us the opportunity to check if your personal data is correct.

 

Right to object to our processing of personal data. You have the right, under certain conditions, to object to our processing of your personal data. In particular, you have the right to object to us processing your personal data for direct marketing purposes.

 

Right to withdraw consent. Where we are processing personal data based on your consent (for example when you complete a survey), you may withdraw this consent at any time by contacting us at privacy@hayppgroup.com. Where you choose to withdraw your consent, this will not affect the lawfulness of any processing of your personal data that we have carried out prior to this withdrawal.

Data Security

We have put in place appropriate security measures to prevent your personal data from being used or accessed in an unauthorized way, altered or disclosed, or accidentally lost. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Questions, complaints and exercise of your rights

If you have any questions regarding our processing of your personal data, or if you would like to exercise any of your rights as outlined in this privacy policy – please contact us at the contact details listed above, see list of companies and contacting details under "Responsible Haypp-company".

 

If you have a complaint regarding Haypp’s processing of your personal data, you have the right to submit such complaints to the competent data protection authority. However, where possible, we would appreciate the chance to deal with your concerns before you approach the data protection authority, so we ask that you please contact us in the first instance, using the details listed above.

Changes to the privacy policy

Haypp reserves the right to make changes to this privacy notice at any time. Any such changes are published on the Website www.haypp.com. We therefore encourage you to periodically review this privacy notice for any changes. It is your responsibility to review the privacy policy every time you submit information to us or place an order.

Links to other sites

In the event that our site contains links to third party websites, or material published by third parties, these links are for information purposes only. Due to the fact that Haypp has no control over the content of these websites, we cannot be held responsible for it. Further, Haypp is not responsible for any loss that might arise from the use of these links. For example, at the checkout at www.haypp.com, there are links to our external payment provider, Klarna. This website applies its own privacy policy and Haypp is not responsible for any personal data that you may provide on these pages. It is your responsibility to review the privacy policy for any third party websites that you access via the Website.

 

This privacy policy is applicable from 16 March 2020