© Snug Site 2020
Your privacy is important to us and we will treat it with high respect. We will require a level of personal information so that we may perform our core functions as a service to you. Here is an outline of the ways in which Snug Site collects and uses your personal information. We will collect and use all information you provide to us over this website, electronically or via the telephone only for the purposes of administering your account or purchased services, (b) send you statements, invoices and reports, (c) collect payment from you, (d) send newsletters and relevant information, (e) publish information that you have submitted for publication, (f) and disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend legal rights. In the event that some of your personal information may be passed on to any sub-contractors for the purposes of maintaining our services to you, the sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement.
What types of information do we collect?When browsing this website it is done so anonymously.Prior to engaging in paid services, we will request and collect your business information. This will be done through an online form on this website, over the phone or through email communication. This is always done by request.When ordering or registering on our site, as appropriate, you may be asked to enter your name or email address. You may, however, visit our site anonymously.
What is business and personal information used for?Any information collected assists us with providing our services, We collect your business or personal information for Billing and Contact purposes. We collect anonymous data for interaction with external social networks, platforms, and Analytics.The Personal Data used for each purpose is outlined in the specific sections of this document.
Collection of Email AddressAll email address to a Snug Site email address, may be automatically subscribed to our Newsletter or will receive future correspondence from us pertaining to offers and news. You will always be given the option in Newsletters to unsubscribe from this service.
Is my Business and Personal Information protected?Snug Site makes every effort available to us to ensure that your information is not acquired by any third-party. We use a secure online Invoicing and support ticket tool. Only authorised Snug Site staff are permitted access to Business and Personal information stored in our online systems. We do not transfer or share any information to outside parties.We may be obliged to release your information when appropriate to comply with the law, enforce our site policies, or to uphold our Terms of Service rights.
Mode and place of processing the Data
Methods of processingThe Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processingThe Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
PlaceThe Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention timePersonal Data shall be processed and stored for as long as required by the purpose they have been collected for.Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The purposes of processingThe Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Handling payments, Hosting and backend infrastructure, Interaction with external social networks and platforms, Managing contacts and sending messages, Traffic optimization and distribution and SPAM protection.Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal DataPersonal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google AdWords conversion tracking (Google Inc.)
Google Analytics with anonymized IP (Google Inc.)
Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.Personal Data collected: address, city, company name, country, email address, first name, last name, number of employees, phone number, state, Tax ID, website and ZIP/Postal code.
Handling paymentsPayment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Freshbooks (2NDSITE Inc.)
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Google Cloud Storage (Google Inc.)
This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google Inc.)
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
MailChimp (The Rocket Science Group, LLC.)
Traffic optimization and distribution
This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User’s browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Website. The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
Facebook Like button and social widgets (Facebook, Inc.)
Google+ +1 button and social widgets (Google Inc.)
Twitter Tweet button and social widgets (Twitter, Inc.)
The rights of UsersUsers may exercise certain rights regarding their Data processed by the Owner.Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processingWhere Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rightsAny requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Applicability of broader protection standardsWhile most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.Such broader protection standards apply when the processing:
- is performed by an Owner based within the EU;
- concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
- concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.
Additional information about Data collection and processing
Legal actionThe User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
System logs and maintenanceFor operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policyMore details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handledThis Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Definitions and legal references
Personal Data (or Data)Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage DataInformation collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
UserThe individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data SubjectThe natural person to whom the Personal Data refers.
Data Controller (or Owner)The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)The means by which the Personal Data of the User is collected and processed.
ServiceThe service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
CookiesSmall sets of data stored in the User’s device.
Last Updated 24th May 2018