Privacy Policy
Updated: 31 January 2025
In this privacy notice (the 'Notice') we describe how we collect, use, and share your personal data when using our websites, digital channels, making a
purchase, when you communicate with us, for example when contacting customers service, and when you participate in contests and other activities that
we arrange.
Personal data means any information that, directly or indirectly, identify you, for example your name or your IP address.
It is important to us that you feel comfortable with how we process your personal data. We take measures to ensure that your personal data is protected
and that our use of personal data complies with applicable regulations and laws and our internal procedures and routines.
We never sell your personal data to any third party without your consent.
To make it easy for you to find the information you are looking for we have divided the information in this Notice into the following sections. You can click
on the relevant section in the list below to jump directly to the section in question.
1. Who is responsible for the use of your personal data?
2. Which personal data do we collect?
3. From where do we collect personal data?
4. Why do we use your personal data?
5. Based on which legal bases do we use your personal data?
6. Which recipients do we share personal data with?
7. Which rights do you have?
8. Cookies and other technologies
9. Where we process personal data
10. Updates to this NoticeMASTER LAST UPDATED 31 January 2025
11. Any questions?
12. Detailed information on our use of personal data
1. WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL DATA?
The company that you interact with is, as a starting point, responsible for its own use of your personal data. In this Notice 'we', ' our' and 'us' refer to the
relevant company that is responsible for the use of your personal data.
Snusbolaget Norden AB is, however, responsible together (joint controllers) with the relevant company for the use of your personal data to communicate
and send offers to you in various channels and to carry out analysis for customer insights. To ensure that your personal data is covered is safeguarded the
relevant group companies have entered into an agreement which includes an arrangement which governs the use of personal data. For information
regarding the essence of the arrangement, please contact us. Contact details can be found in section 11 below.
In the table below, we have outlined the companies that are covered by this Notice and their respective websites. For the sake of clarity, we have also
included information regarding to which counties each company delivers its products. Please see section 11 for contact information to each company.
Company Website Delivery countries
Haypp Limited
(reg. no. 13876184)
haypp.com/uk
northerner.com/uk
vapeglobe.co.uk
The United Kingdom of Great Britain and
Northern Ireland
Snusbolaget Europa AB
(reg. no. 559466-7122)
snusbolaget.se
snusbrev.se
snusmarkt.ch
nettotobak.com
haypp.com/de
Sweden, Germany and
SwitzerlandMASTER LAST UPDATED 31 January 2025
haypp.com/se
northerner.com/de
Snusbolaget Norden AB
(reg. no. 556801-3683)
Snusnetto.com
Sweden
Haypp GmbH
(HRB 729097)
Vapeglobe.de
Germany
Snushjem.no AS
(reg. no. 919 649 585)
snus.com
snushjem.no
snuslageret.no
Norway
Contact details to the companies can be found in section 11 below.
2. WHICH PERSONAL DATA DO WE COLLECT?
We only collect the personal data that we need.
We collect and process the following categories of personal data, but which personal data that we collect about you in particular depends on how you
interact with us:
· Identity information. Information that makes it possible to identify you, for example your name.
· Contact information. Information that makes it possible to contact you, for example your address, e-mail address and telephone number.MASTER LAST UPDATED 31 January 2025
· Order and delivery information. Information about your order and chosen shipping method, for example the product, purchase price, order date and
shipping method.
· User generated information. Information regarding your activity and use of our websites, digital channels, and services, for example clicks and visits and
your behaviour when using the websites and our digital channels.
· Profile information. Information regarding your profile, for example your gender and age.
· Communication. Contents of communication with us, for example contents in e-mail communication with customer service or the responses you provide
when participating in a market survey.
· Technical information. Technical information about the device that you use when visiting our websites and digital channels, for example type of device,
version of browser and operating system.
3. FROM WHERE DO WE COLLECT PERSONAL DATA?
We collect personal data from the following sources:
· Yourself. When you make a purchase on the website, use our websites and other digital channels, contact customer service or participate in a market
survey we collect personal data about you.
· Payment service providers. When you make a purchase on the website, we collect for example identity information, contact information and order and
delivery information that the payment service provider shares with us.
· Couriers and shipping companies. To ensure that your delivery has arrived or to track your shipment we collect order and delivery information that the
couriers and shipping companies that we collaborate with share with us.
· Group companies. The companies within the group collaborate with each other and therefore shares information for example in order to communicate
and send offers in various channels.
· Partners. We collaborate with different companies, for example marketing platforms, and collect the personal data that they share with us to manage the
relationship with the partner.
· Social network platforms. If you visit our channels on social network platforms, we collect the personal data that you provide to us when using these
channels.MASTER LAST UPDATED 31 January 2025
· External information services. We supplement the personal data that we collect about you with information from external information services. This in
order to communicate and send offers in various channels, to carry out analysis for customer insights and to carry out age verification.
4. WHY DO WE USE YOUR PERSONAL DATA?
We use your personal data for various purposes, including to manage your orders, provide our services, communicate with you, to make evaluations and
follow-ups, to manage and defend legal claims and to comply with the law.
Below we further explain the purposes with our use of personal data and provide examples of processing activities carried out for respective purpose.
Please note that not all processing activities may apply to you. Which processing activities that you are covered by depend on how you interact with us.
To read more about which categories of personal data, which legal basis that we rely on for the use of your personal data for each purpose and for how long
your personal data is stored, please see in section 12 below.
Manage your order or subscription
We use your personal data to manage your order on our website, for example to process your order, communicate with you regarding the order and to
handle any complaints. We also use your personal data to manage a subscription that you have ordered, for example to process the subscription and
communicate with you regarding the subscription. You need to provide the information that we have requested when you place your order, since the
information that we request is necessary in order to process your order. If you do not provide the information that we have requested, we unfortunately
cannot process your order.
Provide services on our websites
We also use your personal data to provide services on our websites, for example to register your user account and give you access to my account on the
website.
Respond to questions and provide customer service
If you contact us for example by e-mail or phone, we use the personal data that share with us to respond to your questions or to provide customer service.
Communicate and send offers in various channels
We use your personal data to send offers and personalized communications to you from us and our partners in various digital channels, for example by e-
mail or on social media platforms. You can at any time unsubscribe from communications by clicking on the unsubscribe link in the mailing or by contactingMASTER LAST UPDATED 31 January 2025
customer service. To communicate relevant information and offers, we may profile your personal data by analysing previous purchases and your use of our
websites, digital channels and services.
We also share your personal data for this purpose with social network platforms and marketing platforms. Please see section 6 below for further
information on which recipients that we share personal data with.
Provide customized customer benefits
We use your personal data to provide you with customized customer benefits. In order to provide customized customer benefits, we perform profiling by
analyzing purchasing behavior and history and sorting customers into different groups based on, among other things, how often and how much the
customer shops. This means that different customers can receive different benefits and advantages depending on their purchasing behavior and history.
Carry out analysis for customer insights
We use your personal data to carry out analysis for customer insights on an aggregated level. This in order to obtain a better understanding and insight into
our customers' buying behaviour and buying patterns. For this purpose, we can also supplement your personal data with information collected from
external information services. We do not profile your personal data for this purpose since analysis is made using aggregated information. We share
anonymised customer insights which do not include any personal data about you with manufacturers and partners for their use in their businesses.
Provide newsletter
We use your personal data to provide our newsletter, for example to send out the newsletter and manage your subscription. You can at any time
unsubscribe from the newsletter by clicking on the unsubscribe link in the newsletter or by contacting customer service.
Follow-up and analyse the business
We use your personal data to compile reports on an aggregated level and statistics to follow-up and analyse the business. By way of example, we compile
order and delivery information to ensure that we your products in stock and to understand which products that are more popular than other products. We
do not profile your personal data for this purpose.
Carry out contests, events and other activities
If you participate in a contest, event or another activity that we arrange, we use your personal data to carry out the contest, event or activity, for example to
register your participation, to communicate with you regarding the activity and, where applicable, publish information on winners on our websites and in
our digital channels.MASTER LAST UPDATED 31 January 2025
Carry out market surveys
If you choose to participate in a market survey that we carry out we collect the personal data that you provide in connection with the survey. Market
surveys help us better understand your shopping experience and your experience of our service. Your opinions about our business, products and services
are important to us. You can unsubscribe from mailing at any time by clicking on the unsubscribe link in the mailing or by contacting customer service.
Develop and improve the business
We use your personal data when we carry out analysis on an aggregated level to develop and improve the business, our business methods and business
strategies. This in order to enable us to continuously provide an even better shopping experience and customer service. We do not profile your personal
data for this purpose
Follow-up and analyse the use of our websites and digital channels
It is important for us to understand how our websites and digital channels are used. We therefore use your personal data for this purpose, for example
when we collect and analyse visitor and user statistics on how our website, digital channels and our services are used.
Enable functionality on our websites
To enable functionality on our website, for example to remember your settings, we use where necessary your personal data. This in order to provide you
with a better user experience on the website.
Manage the relationship with partners
We use your personal data to manage our relationship with partners, for example marketing platforms. This, for example, to pay commission to the partners
on purchases generated through marketing using the partner's platform. For the same purpose, we share personal data with our partners. Please see
section 6 below for further information on which recipients that we share personal data with.
Ensure technical functionality and security
We use your personal data to ensure necessary technical functionality and security of our websites and services, for example for security logging, error
handling, and backups.
Manage and defend legal claims
If needed, we use your personal data to manage and defend legal claims for example in connection with a dispute or court proceeding. For this purpose, we
share personal data, when needed, with other recipients, please see section 6 below.MASTER LAST UPDATED 31 January 2025
Fulfill legal obligations
To fulfil our legal obligations, if necessary, we will use your personal data, for example, in order to fulfil accounting or data protection obligations, carry out
age checks and for product liability and product safety. For this purpose, we may share certain information with other recipients. Please see section 6 below
for more information.
5. BASED ON WHICH LEGAL BASES DO WE USE YOUR PERSONAL DATA?
In order for the use of your personal to be lawful there must be a legal basis for the processing. Below we describe the legal bases that we rely on when
processing your personal data. To read more about the legal basis that we rely on for the use of your personal data for each purpose, please see
our detailed information on our use of personal data in section 12 below.
· Legal obligation. When we need your personal data to comply with a legal obligation which we are subject to, for example to fulfill age checks or
accounting requirements, the processing of your personal data is carried out based on this legal basis.
· Performance of a contract. When we need your personal data to perform a contract with you, e.g. our terms of purchase to process your order, the
processing of your personal data is carried out based on this legal basis.
· Legitimate interest. In certain cases, we have made the assessment that we have a legitimate interest of processing your personal data and that this
legitimate interest – under a balancing of interest test – outweighs your interest of not having your personal data processed, for example to communicate
with you or to follow-up and analyse the business. In such a case our processing of your personal data is carried out to satisfy our legitimate interest. You
have the right to object to processing of personal data carried out based on our legitimate interest, please see section 7 below.
· Consent. When you have given your consent to our processing of your personal data, for example if you accept our use of cookies and similar technologies,
the processing is carried out based on your consent. You have the right to withdraw your consent at any time, please see section 7 below.
6. WHICH RECIPIENTS DO WE SHARE PERSONAL DATA WITH?
Below we describe which recipients that we share your personal data with. Which recipients we share your personal data with depends on how you interact
with us. Unless we have stated otherwise below the recipient is responsible for its own use of your personal data.
To read more about why and based on which legal basis we share your personal data with different recipients, please see our detailed information on our
use of personal data in section 12 below.
We share personal data with:MASTER LAST UPDATED 31 January 2025
Service providers
To process personal data for the proposes described in this Notice, we share personal data with service providers that we have engaged. These service
providers provide, for example, IT services (e.g. storage), communication services (which enable us to send you messages and newsletters) and warehousing
services. When the service providers process personal data on our behalf, they act as data processors for us, and we are responsible for the processing of
your personal data. They must not use your personal data for their own purposes and are contractually and legally obliged to protect your personal data.
Payment service providers
Vi use payment service providers to process your payment when you make an order on our websites and therefore share personal data with them for the
same purpose.
Couriers and shipping companies
To process your order and deliver your ordered goods to you we share personal data with the couriers and shipping companies that we have engaged to
carry out the transport of the goods.
Group companies
The companies with the group collaborate and therefore share personal data with each other, for example to communicate and send offers in various
channels. Snusbolaget Norden AB is responsible together (joint controller) with the relevant group company for the use of your personal to communicate
and send offers in various channels.
Social network and marketing platforms
To communicate and provide personalised offers in our digital channels and on other websites we share personal data with social network and marketing
platforms.
When we automatically share personal data with these platforms we are, where applicable, jointly responsible together with the relevant social network or
marketing platform for the collection and transfer of your personal data using cookies and similar technologies. We and the relevant platform is are,
however, independently responsible for the subsequent use of your personal data. We have entered into specific arrangements with the platforms which
outline the roles and responsibility of us and the relevant platform in relation to the use of your personal data. You have the right to receive information on
the essence of these arrangements. Contact our data protection officer to obtain this information, please see section 11 below for contact details. Please
also see our detailed information on our use of personal data in section 12 below for more information about the recipients with whom we are jointly
responsible for the use of your personal data.MASTER LAST UPDATED 31 January 2025
Partners
To manage the relationship with the partner we share personal data with them for the same purpose. As an example, we share personal data with
marketing platforms that we cooperate with to pay correct commission on purchases generated through marketing made with the partner's platform.
Other recipients
If needed, we share your personal data with other recipients for the following purposes:
• to manage a merger or sale of the business,
• to manage and defend legal claims and rights,
• to fulfil legal obligations,
• to respond to a request, and
• to protect and ensure the safety of our staff.
Examples of recipients are external advisors, public authorities, courts, law enforcement, and potential buyers and sellers should we sell the business.
7. WHICH RIGHTS DO YOU HAVE?
You have certain right rights under applicable data protection laws in relation to the personal data that we have collected about you.
You have the right to:
• Request access to and a copy of your personal data. You can view certain personal data that we have store about you by accessing my account.
• Request rectification of your personal data that is incorrect or incomplete.
• Withdraw your consent to our use of your personal data that is based on your consent.
• Request erasure of your personal data in some circumstances, but not in cases where we, for example, are legally obligated to keep your personal
data.
• Unsubscribe from marketing communications which you for example can do by clicking on an unsubscribe link in the communication. Where
applicable you can unsubscribe from communication in Your account.MASTER LAST UPDATED 31 January 2025
• Request restriction of your personal data in certain circumstances and you can then, at least for a certain period of time, prevent us from using your
personal data for other purposes that for example to manage and defend a legal claim or to comply with legal obligations that we are subject to.
• Object to the processing of your personal data that is based on our or another party's legitimate interest for reasons related to your specific
situation and if we cannot show that we have a compelling reason for our use of personal data we will stop using your personal data for the relevant
purpose.
• Transfer your personal data (data portability) under certain circumstances by requesting a copy of your personal data that you have provided to us
in a structured format that you can transfer to another recipient.
In order to exercise your rights, please contact customer service for the relevant company. Please see section 11 below for contact details.
8. COOKIES AND OTHER TECHNOLOGIES
We use cookies and other technologies on our website. For more information on our use of cookies and other technologies and how you can adjust your
cookie settings on the website, please see [ our information on use of cookies].
9. WHERE WE PROCESS PERSONAL DATA
We endeavour to store your personal data within the EU. However, in certain cases we transfer personal data with recipients outside the EU/EEA, for
example service providers engaged by us. The countries outside the EU/EEA that we transfer your personal data to include the U.S.
To ensure that the personal data is protected, we ensure that there are adequate safeguards in place with the service providers that process your personal
data outside the EU/EEA area in light of the laws of the receiving country, for example data transfer agreements which include standard data protection
clauses for transfers of personal data in addition to, if needed, supplementary measures.
10. UPDATES TO THIS NOTICE
We regularly update this Notice. This in order to ensure that the Notice reflects our use of personal data. As an example, we will update this Notice if we
decide to collect additional categories of personal data or if we intend to use collected personal data for additional purposes.
We will in such case notify you in advance by appropriate means, for example by showing a message on the website or by e-mail. The latest version of the
Notice is always available on this page and the date the Notice was last updated is stated above.
11. ANY QUESTIONS?MASTER LAST UPDATED 31 January 2025
If you have questions about this Notice, our use of your personal data or if you wish to exercise your rights, please contact our customer service, please see
contact details below.
Company Address Contact details
Haypp Limited Sweden House
Phone no: +44 8000 489 014
5 Upper Montagu Street
Email: privacy@hayppgroup.com
London W1H 2AG, UK
Snusbolaget Europa AB Dammliden 1
137 69 Österhaninge
Sweden
Phone no.: +46 (0)8-525 157 60
Email: privacy@hayppgroup.com
Snusbolaget Norden AB Östgötagatan 12
116 25 Stockholm
Sweden
Phone no.: +46 (0)8-525 157 60
Email: privacy@hayppgroup.com
Haypp GmbH
c/o Schmeding & Hoffman
Max-Brauer-Allee 52
22765 Hamburg
Germany
Phone no: +49 800 1800 890
Email: privacy@hayppgroup.com
Snushjem.no AS
Phone no.: +47 80025175MASTER LAST UPDATED 31 January 2025
Email: privacy@hayppgroup.com
Kabelgata 39C
0581 Oslo, Norway
If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection authority in your country. Below we
have outlined the data protection authority that is responsible for supervising our use of personal data in the countries to which we deliver our products.
Contact details for each data protection authority can be found on the data protection authorities' websites.
Country Data protection authority Website
Norway Datatilsynet datatilsynet.no/
Switzerland Eidgenössische Datenschutz- und Öffentlichkeitsbeauftragte (EDÖB) edoeb.admin.ch/
Sweden Swedish Authority for Privacy Protection (IMY) imy.se
Germany Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BFDI) bfdi.bund.de/
United Kingdom Information Commissioner's Office (ICO) ico.org.uk/
12. DETAILED INFORMATION ON OUR USE OF PERSONAL DATA
Why and how we use personal data
Please find below detailed information regarding our use of personal data, including the categories of personal data used, the legal basis for the use and for
how long the personal data is stored.
Purpose Personal data Legal basis Storage period
Manage your order or subscription • Communication
Performance of a contract . The
processing is necessary in order to
• Contact information
Personal data is stored until the order
has been processed, including delivery
and payment, and for a period of 36MASTER LAST UPDATED 31 January 2025
Purpose Personal data Legal basis Storage period
• Identity information
• Order and delivery
information
Provide services on our websites • Contact information
• Identity information
• Order and delivery
information
• User generated information
Respond to questions and provide
• Communication
customer service
• Contact information
• Identity information
• Order and delivery
information
fulfill the contract with you pursuant
to our terms and conditions.
Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of providing
services on our websites.
Consent. If you have given your
consent to our use of cookies and
similar technologies for this purpose,
the use of your personal data that has
been collected using cookies and
similar technologies is based on your
consent.
Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of responding to
questions and providing customer
service.
months thereafter to manage
complaints and warranty matters or
the longer period thereafter that is
necessary to handle the complaint or
the warranty matter.
Personal data is stored as long as you
have an active customer relationship
and for a period of six (6) months
thereafter for this purpose. Your
customer relationship is active if you
have interacted with us, e.g. made a
purchase or contacted customer
service, during the last twelve-month
period. This means that your personal
data is stored for this purpose for a
maximum period of 18 months
without any activity.
Personal data is stored for this
purpose as long as you have an active
customer relationship, however, up to
a maximum of 18 months from the
date of the completion of the matter.
Personal data published in digital
channels, for example in our social
media feeds is, as a starting point,
retained until further notice.MASTER LAST UPDATED 31 January 2025
Purpose Personal data Legal basis Storage period
Communicate and send offers in
various channels
• Contact information
Provide custom benefits • Identity information
Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of communicating
and sending offers in various channels.
• Order and delivery
information
• Profile information
• Technical information
• User generated information
Consent . If you have given your
consent to our use of cookies and
similar technologies for this purpose,
the processing of your personal data
which is collected using cookies and
similar technologies is based on your
consent.
Personal data is stored for this
purpose as long you have an active
customer relationship and for a period
of 12 months thereafter for this
purpose. Your customer relationship is
active if you have interacted with us,
e.g. made a purchase or contacted
customer service, during the last
twelve-month period. This means that
your personal data for this purpose is
stored for a maximum period of 24
months without any activity. Order
and delivery information is, however,
stored for a period of up to 27 months
calculated from the date of collection
for this purpose.
• Identity details
• Contact details
• Order and delivery
information
Legitimate interest. The processing is
necessary in order to satisfy our
legitimate interest of providing
customized customer benefits and
provide customers with an even better
customer experience.
Personal data is stored for this
purpose as long as you have an active
customer relationship and for a period
of 12 months thereafter for the same
purpose. Your customer relationship is
active if you have had contact with us
in the last 12 months, e.g. made a
purchase or contacted customer
service. This means that your personal
data is stored for this purpose for a
maximum of 24 months without
activity. However, order and delivery
information are kept for up to 27MASTER LAST UPDATED 31 January 2025
Purpose Personal data Legal basis Storage period
Carry out analysis for customer
insights
• Contact information
• Identity information
• Order and delivery
information
• Profile information
• Technical information
months from the date of collection for
this purpose.
Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of carrying out
analysis for customer insights.
Personal data is stored for this
purpose for a period of 27 months
calculated from the date of collection.
Statistics and reports on an aggregated
level which do not include any
personal data are stored until further
notice or until deleted.
• User generated information
Provide newsletter • Contact information
• Identity information
Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of providing our
newsletter to you when you have
registered for the newsletter.
Follow-up and analyse the business • Identity information
• Order and delivery
information
Legitimate interest . The processing is
necessary in order to satisfy our
Personal data is stored as long as you
have an active customer relationship
and for a period of six (6) months
thereafter for this purpose. Your
customer relationship is active if you
have interacted with us, e.g. made a
purchase or contacted customer
service, during the last twelve-month
period. This means that your personal
data is stored for this purpose for a
maximum period of 18 months
without any activity.
Personal data is stored for this
purpose for a period of 27 months
calculated from the date of collection.
Statistics and reports on an aggregatedMASTER LAST UPDATED 31 January 2025
Purpose Personal data Legal basis Storage period
• Profile information
legitimate interest of follow-up on and
analysing the business.
• User generated information
level which do not include any
personal data are stored until further
notice or until deleted.
Carry out contests, events and other
activities
• Communication
Carry out market surveys • Contact information
• Identity information
• Communication
• Contact information
• Identity information
Develop and improve the business • Identity information Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of carrying out the
contest, event, or the activity in
question.
Personal data is stored for this
purpose during the time the activity is
carried out and for a period of 26
months calculated from the date of
the activity to satisfy our legitimate
interest of follow-up on the
participation, evaluate the activity and
for planning potential future activities.
Thereafter the personal data will be
anonymised. Statistics and reports on
an aggregated level which do not
include any personal data are stored
until further notice or until deleted.
Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of carrying out
market surveys for the purpose of
collecting your opinions about our
business, products, and services.
Personal data is stored for this
purpose during the period the survey
is carried out and for a period of three
(3) months thereafter to compile the
responses in a report. Thereafter the
personal data will be anonymised.
Statistics and reports on an aggregated
level which do not include any
personal data are stored until further
notice or until deleted.
Legitimate interest . The processing is
necessary in order to satisfy our
Personal data is stored for this
purpose for a period of 27 monthsMASTER LAST UPDATED 31 January 2025
Purpose Personal data Legal basis Storage period
Follow-up and analyse the use of our
websites and digital channels
Enable functionality on our websites • Order and delivery
information
• Profile information
• User generated information
• Identity information
• Profile information
• Technical information
• User generated information
• Technical information Manage the relationship with partners • Identity information
• Order and delivery
information
• Technical information
legitimate interest of developing and
improving the business.
Consent . The processing is carried out
based on the consent that you provide
when accepting our use of cookies and
similar technologies for the same
purpose.
Consent . The processing is carried out
based on the consent that you provide
when accepting our use of cookies and
similar technologies for the same
purpose.
Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of managing the
relationship with our partners, e.g.
marketing platforms that we
collaborate with.
from the date of collection. Statistics
and reports on an aggregated level
which do not include any personal
data are stored until further notice or
until deleted.
For information on how long your
personal data is stored for this
purpose, please see our information
on our use of cookies. Statistics and
reports on an aggregated level which
do not include any personal data are
stored until further notice or until
deleted.
For information on how long your
personal data is stored for this
purpose, please see our information
on our use of cookies. Statistics and
reports on an aggregated level which
do not include any personal data are
stored until further notice or until
deleted.
Personal data is stored for this
purpose as long as there is an active
relationship and for a period of ten
(10) years thereafter to satisfy our
legitimate interest of managing and
defending legal claims.MASTER LAST UPDATED 31 January 2025
Purpose Personal data Legal basis Storage period
Ensure technical functionality and
security
• Relevant categories of
personal data
Manage and defend legal claims Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of ensuring
technical functionality and security of
our websites and services.
Personal data is stored for the same
period as stated in relation to each
relevant purpose of the processing.
Personal data in logs is retained in
order to satisfy our legitimate interest
of troubleshooting and incident
management for a period of 13
months from the date and time of the
log entry. Personal data in backups are
stored for a period of 13 months from
the date of the backup.
Legitimate interest . The processing is
necessary in order to satisfy our
legitimate interest of managing and
defending legal claims.
Personal data is stored for the period
required in order for us to manage and
defend the legal claim in the individual
case.
Fulfill legal obligations • Only the categories of
personal data needed for
managing and defending a
legal claim in the individual
case
• Only the categories of
personal data are necessary
for fulfilling the relevant legal
obligation.
Fulfill legal obligation . The processing
is necessary in order to fulfill legal
obligations that we are subject to.
Legitimate interest . The processing is
necessary in order to comply with the
legal obligation not to sell products to
minors.
Personal data is stored for such period
that is necessary in order for us to
fulfill each legal obligation that we are
subject to and for a period of ten (10)
years thereafter to satisfy our
legitimate interest of managing and
defending legal claims and for the
period necessary to manage such a
claim. As an example, personal data in
accounting material is stored for 7
years calculated from the end of the
calendar year in which the relevantMASTER LAST UPDATED 31 January 2025
Purpose Personal data Legal basis Storage period
financial year ended in order for us to
fulfil our legal obligations
(bookkeeping and accounting
requirements in the Swedish
Accounting Act (1999:1078)).
Why and with whom we share personal data
Please find below detailed information regarding which categories of personal data we share with other recipients and the legal basis for the transfer.
Recipient Purpose Personal data Legal basis
Payment service providers Manage your order or subscription • Contact information
• Identity information
Performance of a contract . The
processing is necessary in order to
fulfill the contract with you pursuant
to our terms and conditions.
• Order and delivery
information
Couriers and shipping companies Manage your order or subscription • Contact information
• Identity information
Performance of a contract . The
processing is necessary in order to
fulfill the contract with you pursuant
to our terms and conditions.
• Order and delivery
information
Social network and marketing
platforms
Communicate and send offers in
various channels
• Identity information
• Technical information
• User generated information
Consent . The processing is carried out
based on the consent that you provide
when accepting our use of cookies and
similar technologies for the same
purpose.
Partners Manage the relationship with the
partner
• Identity information Legitimate interest . The processing is
necessary in order to satisfy ourMASTER LAST UPDATED 31 January 2025
Recipient Purpose Personal data Legal basis
• Technical information legitimate interest of managing our
relationship with our partners.
Other recipients
Purpose Personal data Legal basis
Manage a merger or sale of the business Only the personal data that is necessary for this
purpose is shared with the recipient.
Manage and defend legal claims Only the personal data that is necessary for this
purpose is shared with the recipient.
Fulfil legal obligations Only the personal data that is necessary for this
purpose is shared with the recipient.
Respond to a request Only the personal data that is necessary for this
purpose is shared with the recipient.
Protect and ensure the safety of our staff Only the personal data that is necessary for this
purpose, for example to notify an incident to law
enforcement.
Legitimate interest . The processing is necessary in order
for us to satisfy our and the buyer's legitimate interest
of completing the sale or merger.
Legitimate interest . The processing is necessary in order
for us to satisfy our legitimate interest of managing and
defending legal claims.
Legitimate interest or to fulfil a legal obligation . The
processing is necessary in order for us to comply with
our legal obligations. Otherwise, the processing is based
on a balance of interests where it is necessary to satisfy
our obligation to comply with legal requirements
Legitimate interest or to fulfil a legal obligation . To the
extent that we are obligated to respond to a request,
personal data is used to fulfil this legal obligation.
Otherwise, the processing is based on a balance of
interests where it is necessary to satisfy our and the
requester's legitimate interest in responding to the
request.
Legitimate interest . The processing is necessary in order
to satisfy our legitimate interest of protecting and
ensuring the security of our staff.MASTER LAST UPDATED 31 January 2025
Recipients that We Are Jointly Responsible With
As noted in section 6 are we jointly responsible for the use of your personal data with certain recipients that we share your personal data with.
Recipient Information
Facebook Ireland Limited
Information regarding Facebook Ireland's use of your personal data, including their legal basis and the
ways that you can exercise your rights against Facebook Ireland can be found in their Data Policy
available at https://www.facebook.com/about/privacy .
Grand Canal Square, Grand Canal Harbour, Dublin
2, D02C525, Ireland
We and Facebook Ireland have entered into a joint controller addendum to determine the respective
responsibilities in relation to the use of your personal data for which we and Facebook Ireland is jointly
responsible, please see https://www.facebook.com/legal/controller_addendum .
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