General information

The following privacy policy applies to the website www.snusland.ch, operated by WENO Commerce GmbH. Unless otherwise stated, WENO Commerce GmbH is responsible for data processing in accordance with the applicable data protection laws of Switzerland, in particular the Federal Act on Data Protection (FADP / GDPR).

To give you an overview of what personal data we collect and how we use it, this page communicates. Data protection is applied in accordance with legal requirements, and we reserve the right to update this information at any time and without notice.

Please note that in some cases other companies, either alone or jointly with WENO Commerce GmbH, are responsible for data processing under data protection law. In these cases, the data protection guidelines of this provider come into force.

Contact person for data protection

If you have any questions about data protection or would like to exercise your rights, please write to our contact person for data protection:

info@snusland.ch

Your rights

As a data subject of data processing, you can exercise the following rights, provided that the legal requirements are met:

Right to information: You can request access to the personal data stored by us at any time, insofar as we process this data. In this way, you can check what personal data we have stored about you and ensure that we use it in accordance with the applicable data protection regulations.

Right to rectification: If your personal data is incorrect or incomplete, you can request a correction and be informed of the changes made. We will inform the recipients of the data concerned about the adjustments made, unless this is impossible or involves disproportionate effort.

Right to erasure: Under certain circumstances, you may request that your personal data be erased. However, it should be noted that in individual cases, particularly in the case of statutory retention obligations, the right to erasure may be excluded. In such cases, the data may be blocked instead of erased under the given conditions.

Right to restriction of processing: You have the right to have the processing of your personal data restricted.

Right to data portability: You may receive the personal data you have provided to us in a readable format free of charge.

Right to object: You have the right to object to data processing at any time, in particular in connection with direct advertising (e.g. newsletters).

Right of withdrawal: In principle, you have the right to withdraw your consent at any time. However, the processing of your data, which was carried out on the basis of your previous consent, will not become unlawful retroactively as a result of your revocation.

To exercise these rights, please send us an e-mail to the address below:

info@snusland.ch

Right to lodge a complaint: You have the right to lodge a complaint with a competent supervisory authority, for example if you do not agree with the way in which your personal data is processed.

Data security

We use suitable technical and organizational security measures to protect your personal data stored by us against loss and unauthorized processing, including unauthorized access by third parties. Our employees and the service companies commissioned by us are obliged to maintain confidentiality and to protect your data. Access to personal data is only granted to these persons to the extent necessary to fulfill their tasks.

Our security measures are continuously adapted in line with advances in technology. Nevertheless, there are always certain security risks associated with the transmission of information via the Internet and electronic means of communication. We therefore cannot guarantee the security of information transmitted in this way.

Contact us

If you contact us via our contact addresses and channels (e.g. by e-mail, telephone or contact form), your personal data will be processed. This is the data that you have made available to us, such as your name, your function, your e-mail address or telephone number and your request. In addition, the time of receipt of your request is documented. Mandatory information is marked with an asterisk (*) in contact forms.

We process this data exclusively in order to implement your request, for example to provide information about a product, to assist with contract processing, such as product returns, or to integrate your feedback into the improvement of our service.

6. Use of your data for marketing purposes

6.1 Central data storage and analysis in the CRM system

If a clear assignment to your person is possible, we will store the data described in this privacy policy, including your personal data, your contacts, your contract data and your surfing behavior on our websites, in a central database and link them together. This enables efficient management of customer data, enables us to respond to your inquiries appropriately and supports the efficient provision of the services you have requested and the processing of the associated contracts.

We analyze this data in order to further develop our offers in line with your needs and to display and suggest the most relevant information and offers to you. We also use methods that can predict possible interests and future orders based on your use of the website.

6.2 E-mail marketing and newsletters

If you register for our e-mail newsletter, for example during the order process or on our website, your e-mail address will be saved. Mandatory fields are marked with an asterisk (*) in the registration form.

By registering, you consent to the processing of this data in order to receive news from us about our company and offers in the area of snus, nicotine pouches and caffeine pouches as well as related products and services. This may also include invitations to participate in competitions or to evaluate the products and services mentioned. Recording the salutation and name enables us to assign the registration to any existing customer number and to personalize the content of the emails. The link to a customer account helps us to make the offers and content contained in the newsletter more relevant to you and better tailored to your potential needs.

We will continue to use your data to send you emails until you withdraw your consent. Revocation is possible at any time, in particular via the unsubscribe link contained in all our marketing e-mails.

Our marketing emails may contain a so-called web beacon or 1×1 pixel (tracking pixel) or similar technical aids. A web beacon is an invisible graphic that is linked to the user ID of the respective newsletter subscriber. This technology provides us with information about which addresses have not yet received the email, which addresses it was sent to and which addresses failed to receive it. We can also see which addresses have opened the email, how long it remained open and which links were clicked on. Finally, we also receive information about which addresses have unsubscribed. We use this data for statistical purposes and to optimize the advertising emails in terms of frequency, timing, structure and content. This enables us to better tailor the information and offers in our emails to the individual interests of the recipients.

The web beacon is deleted when you delete the email. To prevent the use of the web beacon in our marketing emails, you can configure the settings of your email program so that HTML is not displayed in messages, if this is not already the case by default. You can find information on how to adjust this setting in the help sections of your email software.

By subscribing to the newsletter, you also consent to the statistical analysis of user behavior for the purpose of optimizing and adapting the newsletter.

By registering for our newsletter, you also consent to the statistical analysis of user behavior in order to optimize and adapt the newsletter. This consent forms the legal basis for data processing in accordance with Article 6(1) of the EU General Data Protection Regulation (GDPR).

For our marketing emails, we use the email marketing software Mailchimp, provided by Intuit Mailchimpt, 405 N Angier Ave. NE in Atlanta, GA 30308 USA. Your data is therefore stored in an Intuit Mailchimp database to provide and support the use of the software, which gives Intuit Mailchimp access to your data as necessary.

7. Disclosure to third parties and third-party access options

Without the support of other companies, we would not be able to provide our services in the desired form and quality. In order to be able to use the services of these companies, it is necessary to pass on your personal data to a certain extent. This forwarding takes place in particular in order to fulfill the contract you have requested, for example to logistics or transport companies that deliver the products or to manufacturers who are to fulfill your warranty claims.

Data is also passed on to selected service providers and is limited to the extent necessary for the provision of the service. Various third-party service providers are already explicitly mentioned in this privacy policy, in particular in the sections on marketing. These service providers include IT service providers such as providers of software solutions, advertising agencies and consulting firms.

In addition, your data may be passed on, in particular to authorities, legal advisors or debt collection agencies, if this is required by law or is necessary to protect our rights, in particular to enforce claims arising from the relationship with you. Data may also be disclosed if another company intends to acquire our company or parts thereof and such disclosure is necessary to carry out due diligence or to complete the transaction.

8. Transfer of personal data abroad

We reserve the right to transfer your personal data to third parties abroad if this is necessary to carry out the data processing described in this privacy policy. It goes without saying that the statutory provisions on the disclosure of personal data to third parties will be complied with. If the country in question does not offer an adequate level of data protection, we will ensure through contractual agreements that your data is adequately protected by these companies.

9. Retention periods

We only store personal data for as long as is necessary for the processing described in this privacy policy within the scope of our legitimate interest. The storage of contract data is prescribed by statutory retention obligations. These obligations arise from accounting and tax regulations. According to these regulations, business communications, concluded contracts and accounting documents, for example, must be stored for up to 10 years. As soon as we no longer need this data to provide services to you, it will be blocked. This means that the data may only be used if this is necessary to fulfill retention obligations or to defend and enforce our legal interests. The data will be deleted as soon as there is no longer an obligation to retain it and there is no longer a legitimate interest in retaining it.

10. Log files and data

When you visit our website, our hosting provider stores every access on the server in a log file. The following data is recorded without any action on your part and stored until it is automatically deleted:

• IP address
• Time and date of access
• URL
• Status codes of the website
• Website that redirected you to our website
• Operating system of your device (computer/tablet, smartphone) and the browser used, including language setting
• Transmission protocol http
• Device type
• City / region from which the access was made

This data is collected and processed with the aim of enabling the use of our website (e.g. establishing a connection), ensuring permanent system security and stability and analyzing errors and performance problems in order to optimize our website.

In the event of an attack on the website's network infrastructure or suspected unauthorized or improper use of the website, the IP address and other data are evaluated for investigation and defense. If necessary, this information is also used in the context of criminal proceedings to identify and initiate civil and criminal proceedings against the users concerned.

Finally, when you visit our website, we use cookies as well as applications and tools that are based on the use of cookies. The data described here may also be processed in this context. Further information on this can be found in the following sections of this privacy policy, in particular section 11.

11. Cookies

Cookies are small text files that are stored by your web browser on your hard disk or in your computer's memory when you visit our website. They are given a unique identifier that recognizes your browser and may contain information that can be retrieved when the cookie is read.

Cookies help to make your visit to our website easier, more pleasant and more meaningful. We use cookies for various purposes that are necessary for your desired use of the website, i.e. they are "technically necessary". For example, we use cookies to identify you as a registered user after you have logged in so that you do not have to log in again when navigating different pages. The shopping cart and order functions are also based on cookies. In addition, cookies also perform other technical functions that are necessary for the operation of the website, such as load balancing to distribute the performance load across different web servers and relieve them. Cookies are also used for security reasons, for example to prevent the unauthorized posting of content. Finally, we also use cookies for the design and programming of our website, for example to enable the uploading of scripts or codes.

Most Internet browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or you are notified each time a new cookie is received.

If you deactivate cookies, you may not be able to use all the functions of the website.

12. Google SiteSiteSearch / Google Custom Search Engine

On our website we use the Google SiteSearch/Google Custom Search Engine from Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to offer you an efficient search function.

If you use our search fields and JavaScript is activated in your browser, your browser may transmit the log file data listed in section 10 (including your IP address) and the search term you entered to Google. If you wish to prevent the transmission of data, you can deactivate JavaScript in your browser settings (usually in the data protection menu). Please note, however, that this may impair the search function and other functions of the website.

For further information on the processing of your data by Google, please refer to Google's privacy policy.

13. Tracking and web analytics tools

13.1 General information on tracking

We use the web analysis services listed below to design and continuously optimize our website in line with requirements. Pseudonymized user profiles are created and cookies are used (see also section 11). The information generated by the cookie about your use of this website is usually transferred to a server of the service provider together with the log file data listed in section 10, where it is stored and analyzed. This transfer may also take place to servers abroad, e.g. in the USA (see in particular the guarantees provided in section 8).

By processing the data, we obtain the following information:

• Navigation path that a visitor takes on the page
• Length of stay on the website / subpage
• Page / subpage on which the website is left
• Country, region, city from where the website is accessed
• End device (type, version, color depth, resolution, width and height of the browser window)
• Returning and new visitors

As part of our contract, the service provider will use this information to analyze the use of the website, to compile reports on website activity for us and to provide other services related to the use of the website and the Internet for market research and needs-based design of these Internet pages. To a certain extent, we and the service provider can be regarded as joint controllers within the meaning of data protection law for this processing.

For further processing of the data by the respective provider as the (sole) controller under data protection law, in particular also for any disclosure of this information to third parties such as authorities due to national legal regulations, please observe the corresponding data protection information of the provider.

13.2 Google Analytics

We use the web analysis service Google Analytics from Google Ireland Limited (Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland) or Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) ("Google").

The data described about the use of the website may be transmitted to the servers of Google LLC in the USA for the processing purposes explained (see section 13.1). In order to protect privacy, the IP address is shortened by activating IP anonymization ("anonymizeIP") on this website before transmission within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

Users have the option of preventing the collection of data generated by the cookie and related to website use (including the IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in at the following link:

http://tools.google.com/dlpage/gaoptout?hl=de

Further information on Google's data protection can be found here.

14. Social Media

14.1 Social media profiles

We have included links to our profiles in the social networks of the following providers on our website:

• Telegram FZ-LLC, Al Kazim Towers, Dubai United Arab Emirates
• Meta Platforms Inc, 1601 S California Ave, Palo Alto, CA 94304, USA
• Twitter San Francisco, California, United States
• Instagram Inc. 1601 Willow Road, Menlo Park, CA 94025, USA
• TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland
• X, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA
• Linkedin Unlimited Company, Wilton Palace, Dublin 2, Ireland

If you click on the social network icons, you will automatically be taken to our profile on the respective platform. This establishes a direct connection between your browser and the server of the corresponding social network. As a result, the network receives information that you have visited our website with your IP address and clicked on the link.

If you click on a link to a social network while you are logged into your user account with this network, the content of our website can be linked to your profile. This allows the network to associate your visit to our website directly with your account. If you wish to prevent this, you should log out of your user account before clicking on the relevant links. However, there is always a connection between your access to our website and your user account if you log in to the respective network after clicking on the link. The respective provider is responsible for the associated data processing under data protection law. Please therefore note the information on the network's website.

14.2 Social media plugins

You can use the following social plugins from the listed providers on our website:

• Telegram FZ-LLC, Al Kazim Towers, Dubai United Arab Emirates
• Meta Platforms Inc, 1601 S California Ave, Palo Alto, CA 94304, USA
• Twitter San Francisco, California, United States
• Instagram Inc. 1601 Willow Road, Menlo Park, CA 94025, USA
• TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland
• X, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA
• Linkedin Unlimited Company, Wilton Palace, Dublin 2, Ireland

You can find the data protection declarations of the above-mentioned providers on their respective websites.

We use social plugins to facilitate the sharing of content from our website. These plugins help us to increase the visibility of our content on social networks and thus contribute to better marketing.

By default, the plugins are deactivated on our websites so that no data is transmitted to the social networks simply by accessing our website. To ensure data protection, we have integrated the plugins in such a way that a connection to the networks' servers is not automatically established. Your browser only establishes a direct connection to the servers of the respective network when you activate the plugins and thus give your consent to data transmission and processing by the social network providers.

The content of the plugin is transmitted directly from the social network to your browser, which integrates it into the website. As a result, the provider receives the information that your browser has accessed the corresponding page of our website, even if you do not have an account with this social network or are not currently logged in. This information, including your IP address, is transmitted directly from your browser to a server of the provider (usually in the USA) and stored there. We have no influence on the scope of the data that the provider collects with the plugin, but from a data protection point of view, we can be considered jointly responsible with the providers up to a certain extent.

If you are logged in to the social network, it can assign your visit to our website directly to your user account. If you interact with the plugins, this information is also transmitted directly to a server of the provider and stored there. The information (e.g. that you like one of our products) can also be published on the social network and possibly displayed to other users. The provider of the social network may use this information for advertising purposes and to customize its offer. For this purpose, usage, interest and relationship profiles may be created, for example to analyze your use of our website with regard to the advertisements displayed to you on the social network, to inform other users about your activities on our website and to provide other services associated with the use of the social network. For information on the purpose and scope of the data collection and the further processing and use of the data by the social network providers, as well as your rights in this regard and setting options for protecting your privacy, please refer directly to the data protection information of the respective provider.

If you do not want the provider of the social network to assign the data collected via our website to your user account, you must log out of the social network before activating the plugins. You can revoke your consent at any time by informing the provider of the plugin of your revocation in accordance with the information in its privacy policy.

15. Online advertising and targeting

15.1 in general

We cooperate with various companies to present you with interesting offers online. In doing so, we analyze your user behavior on our website and other websites in order to be able to show you online advertising that is individually tailored to you.

Most technologies for tracking your user behavior ("tracking") and for the targeted display of advertising ("targeting") work with cookies (see section 11), which enable your browser to be identified across different websites. Under certain circumstances, you may also be recognized online across different devices (e.g. laptop and smartphone), especially if you have registered with a service that you use on different devices.

In addition to the data already mentioned, which is generated when websites are visited ("log file data", see section 10) and when cookies are used (see section 11) and which may be transmitted to the companies involved in the advertising networks, the following data in particular is used to select the potentially most relevant advertising:

• Personal details that you have provided when registering or using a service from advertising partners (e.g. gender, age, etc.)
• User behavior (e.g. search queries, interactions with advertising, websites visited, products viewed and purchased, newsletters subscribed to).

We and our service providers use this data to determine whether you belong to the target group we are addressing and take this into account when selecting advertisements. For example, after visiting our site, you may be shown ads for the products you have viewed when you visit other sites ("re-targeting"). Depending on the scope of the data, a user profile can also be created, which is automatically evaluated, and the ads are selected according to the information stored in the profile, such as membership of certain demographic segments or potential interests or behaviors. Such ads may be presented to you on various channels, including our website or app (as part of onsite and in-app marketing) as well as ads placed via online advertising networks we use, such as Google.

The data can then be analyzed for billing purposes with the service provider and to evaluate the effectiveness of advertising measures in order to better understand the needs of our users and customers and to improve future campaigns. This may also include information that the performance of an action (e.g. visiting certain pages of our websites or sending information) is attributable to a specific advertisement. In addition, we receive aggregated reports from the service providers about advertising activities and information about how users interact with our website and our advertisements.

The legal basis for this data processing is your consent in accordance with Art. 6 para. 1 lit. a EU GDPR. You can withdraw your consent at any time by rejecting or deactivating the relevant cookies in the settings of your web browser (see section 11). Further options for blocking advertising can also be found in the information provided by the respective service provider, e.g. Google.

16. Use of our chat function

If you contact us via the chat, your personal data will be processed. This data includes information that you have provided to us, such as the name of your company, your own name, your position, your e-mail address and your request. In addition, the time of the request is documented. Mandatory fields are marked with an asterisk (*).

We only use this data to process your request, for example to provide information about a product, to assist with contractual matters such as returning products or to incorporate your feedback to improve our service. For the chat function, we use a tool from C. Social Intents, LLC, whereby your data is stored in a database of C. Social Intents, LLC. This allows C. Social Intents, LLC to access your data as necessary to provide the software and support its use.

17. Registration for a customer account

If you create a customer account on our website, we collect the following data, whereby mandatory information is marked with an asterisk (*) in the corresponding form:

• Salutation
• Name
• First name
• Billing and delivery address
• Birthday
• Company, company address (optional)
• Phone number
• E-mail address
• password
• Gender

Our use of your personal data serves various purposes. Identity information is used to verify your identity and to check your registration. The e-mail address and password are used as login data to ensure that the correct person is using the website, and they are also used to verify and confirm the opening of the account and for future communication in the context of contract processing. This data is also stored in the customer account to facilitate future contract conclusions. You also have the option of entering further details such as your preferred means of payment in the account.

We also use your data to provide you with an overview of the products and services you have ordered and to offer you an easy way to manage your personal data. They are also used for the administration of our website and contractual relationships, including the establishment, design, processing and amendment of contracts concluded with you via your customer account.

The information you provide on language and gender is used to show you customized offers on the website that meet your personal needs. It is also used for the statistical evaluation and optimization of our offers.

To avoid misuse, we recommend that you treat your login data confidentially and close the browser window when you have finished communicating with us, especially if you share the computer with others.

18. Ordering products

If you would like to order products on our website or book services, various data are required for contract processing. If you do not log in with your customer account (see section 17), the following data will be collected depending on the product or service. Mandatory fields in the corresponding form are marked with an asterisk (*):

• Salutation
• Name
• First name
• Billing and delivery address
• E-mail address
• Confirmation minimum age
• Phone number

We use your data to verify your identity before concluding the contract and to confirm your order by email. This information is stored with order data (such as time, order number), product information (name, price, features), payment information (selected payment method, confirmation, time) and contract processing information (e.g. returns, service requests) in our CRM database to ensure smooth order processing. If necessary, relevant data is also passed on to third-party providers (e.g. shipping service providers). This data processing is based on the fulfillment of the contract in accordance with Art. 6 para. 1 lit. b EU GDPR.

The provision of optional data is voluntary. We use this data to better tailor our offers to your needs, to facilitate contract processing and, if necessary, to contact you via alternative communication channels. It is also used for statistical analysis to optimize our offer. This data processing is based on your consent in accordance with Art. 6 para. 1 lit. a EU GDPR, which you can revoke at any time.

19. Online payment processing

If you purchase chargeable services or products on our website, further data may be required in addition to the information specified in section 18, depending on the type of product or service and your desired payment method. This may, for example, be your credit card information or the registration with your payment service provider. This data and the time and amount of the purchase will be forwarded to the relevant payment service providers, such as payment solution providers, credit card issuers and credit card acquirers. Please refer to the privacy policy and general terms and conditions of the respective company. The legal basis for this transfer is the performance of a contract pursuant to Article 6(1)(b) of the EU General Data Protection Regulation (GDPR).

In order to avoid payment defaults, we may pass on the necessary data, in particular your personal data, to a credit agency that automatically assesses your creditworthiness. You will be assigned a so-called score value, which indicates the risk of non-payment as a percentage. This value is calculated using mathematical-statistical methods and taking into account data from other sources. Based on the information received, we reserve the right not to offer you the "invoice" payment option. The legal basis for this data processing is our legitimate interest pursuant to Article 6(1)(f) of the EU General Data Protection Regulation (GDPR) to avoid payment defaults.

20. Submission of ratings and comments

In order to help other users with their purchasing decisions and to support our quality management, in particular with the processing of negative feedback, we offer you the opportunity to rate products on our website. The published data includes your rating, the time of the rating and, if applicable, a comment or a nickname of your choice. The nickname can be freely chosen to protect your privacy and can be changed in the customer account if necessary.

By posting comments and contributions on our website, you agree that your comment with the chosen nickname as well as any uploaded photos and videos are publicly visible and that we may use them freely and free of charge for advertising purposes. We reserve the right to remove unlawful reviews and to contact you for comment if necessary.