SnowBox PRIVACY POLICY (“Privacy Policy”)
LAST UPDATED: September 2023
1. ABOUT THE SNOWBOX GROUP AND THIS PRIVACY POLICY
We are the SnowBox (“we”, “us”, “our”), and are committed to protecting your privacy.
This Privacy Policy provides information on how we collect and use personal data. SnowBox operates Snowbox.store. This Privacy Policy sets out the information that we collect, the reasons for which we collect the information, and how we can use and share the information.
If you have any requests to exercise your legal rights, check section 10 (“What are my privacy rights?”) below.
2. THIRD PARTY WEBSITES
Our website can contain links to and from the websites of our partner boutiques, retailers and brands (collectively our “Partners”), advertisers, and affiliates, amongst others. If you follow a link to any of these websites, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.
3. WHAT INFORMATION DO WE COLLECT, AND HOW?
When you interact with us, whether by using our website or communicating with us, we may collect the following information about you:
• Information you give us: you may give us information about yourself if you sign up for an account on our website, place an order for products, complete any online forms (such as registration forms, competitions, surveys or by reviewing the products you’ve ordered), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions, or correspond with us (by email, telephone, instant messaging apps, social media or otherwise).
Depending on what you provide, this information can include your name, address or location, phone number, email address, date of birth, gender, purchase information, shopping preferences, reviews, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).
If you register an account on the website, then you may choose to give us your photograph and nickname. From your SnowBox account, you can also invite your friends to shop at our website (including by email, Facebook, or Twitter). Even though we let them know that we’ve received their details from you, please ensure that you have your friend’s permission before sharing their contact details with us and only forward emails to people you know would be happy to receive them.
• Information our IT systems collect about you: each time you visit the website, certain information will be created and automatically recorded by our IT systems. That information includes:
Cookies: you can see more details about cookies in section 7, but these small text files can help improve your experience with the Website and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to, or ensuring that items you wish to order don’t disappear as you navigate between pages on our website. We also use cookies to provide you with tailored advertising.
Device information: the information provided by your device will differ depending on your operating system and device settings (eg. PC, Mac, iPhone, Android, or otherwise), but includes the type of device you have (eg. iPhone 6S or Samsung Galaxy S7), the device’s IP address and location, the browser you’re using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.
• Information we collect in store: the SnowBox is always looking for new opportunities to improve your shopping experience and this extends to your experiences in-store. You may also give us information about yourself in-store if you make a purchase using a credit or debit card, complete a survey or questionnaire, enter a competition or promotion, provide us with feedback or otherwise interact or correspond with us in-store or after your visit. Where you use a WiFi-enabled device in-store, certain information may be provided by your device, which will differ depending on your device and settings. The information that may be provided is the type of device you have, the device identifier/media access control (MAC) address, the proximity of the device from the access point, location of the device, and where relevant, when and for how long the device is connected to the Wi-Fi network. You can prevent information being provided by turning off the Wi-Fi feature on your device. We might also register your interactions with the products, in order to enhance your in-store experience by providing you a more personalised service during your visit and after.
4. WHAT DO YOU USE MY INFORMATION FOR?
To provide you with our services, including to allow you to order and receive products using our website, administer your SnowBox account and to optimise your experience, we need to use your information in a number of different ways.
We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our services, we will use your personal information (including your name, email address and address) to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you. You may unsubscribe from our email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt-out instructions in the promotional emails that are sent to you.You may unsubscribe from our email marketing communications by modifying your preferences in your SnowBox account’s profile management section, by following the opt-out instructions in the promotional emails that are sent to you.
Should your country be covered by such services, we may use your information to provide you with shopping recommendations and personal styling-related services, therefore, you’ll have access to an improved and more interactive shopping experience. Such services will be provided along with third-party providers, which will be acting as processors.
We use third-party service providers to serve advertisements most relevant to you across your different devices and on our own and others’ websites and mobile applications. In addition to the information about your visits to our website or usage of our mobile application, our service providers may also use the information about your interactions with other websites or applications to target advertisements for products available from SnowBox or from our partners. For information about opting out of targeted advertising and controlling the use of cookies, please see the cookies section of this Privacy Policy.
We also carry out research, analysis, and surveys on your use of our website, and views. We keep tracking of your spend on our website to see if you can benefit from our exclusive loyalty programs, VIP customer program and Access. Finally we use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security. Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we purpose that data.
To register and manage your SnowBox account on our Website, we collect your name, email, password and other additional details you may wish to add to your account, like phone number, addresses and gender. The legal basis is the performance of a Contract with you.
To fulfil the orders you make through our website, we collect your Name, addresses, phone number, Order details, like the products you are buying, the size and price. The legal basis is the performance of a Contract with you.
To collect payment from you we collect your payment information, which comprises the credit/debit card’s number, holder’s name and CVV. We don’t store them and only transfer them to our authorised payment providers. The legal basis is the performance of a Contract with you.
To provide you with our customer services (including helping you to solve any issue you have with our services, updating you about any change to our terms of service, or contacting you to know how was your experience with us): we collect your name, email, password, phone number and addresses and your contact history with us. The legal basis is the performance of a Contract with you and our legitimate interests in retaining you as a customer.
To monitor the quality of our customer services, we collect your name, email, password, phone number and addresses, your response to our SMS inquiries about the quality of the service and your contact history with us (including phone records of our conversations and conversations through email or other instant messaging apps). The legal basis is the legitimate interests in running our business.
To review and post your reviews on your orders: we collect your name, age range, skin characteristics (such as type, tone, and concerns) and your written review. The legal basis is your consent.
To administer, maintain and optimise our Website and our services, we collect your device information (such as your device IP address and device type), cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
To perform fraud and credit checks and if we can do business with you, we collect your name, email, addresses, credit/debit card details, browsing history, purchase history, date of birth, gender, specific behavioural cookies, device information (such as IP address and device type), any national identifiers (like driver’s license or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect SnowBox and its customers from fraudulent activities and compliance with a legal obligation.
To send you marketing communications and personalised offers, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behaviour, device information, shopping preferences, cookie identifiers, internal identifiers and country. The legal basis is the legitimate interests in electronic direct marketing of similar products and services which you have acquired using our website. When such is not applicable, your consent to send you special offers and campaigns powered by SnowBox in cooperation with exclusive partners.
To manage our loyalty programmes, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behaviour, device information, shopping preferences, nickname, cookie identifiers, internal identifiers, country, spent tier level and wealth. The legal basis is our legitimate interests in running our business and improving your shopping experience.
To provide you with personalised recommendations and enhance your experience, we collect your name, email, phone number, addresses, date of birth, purchase history, browsing history and behaviour, in-stores interactions with products, device Information, shopping preferences, nickname, cookie identifiers, internal identifiers, country, spent tier level and wealth. The legal basis is our legitimate interests in running our business and improving your shopping experience.
To carry on research, analysis, enquiries and surveys on your use of our website, we collect your Name; Addresses; Email; Device information, legal basis is our legitimate interests in running our business and improve our Website and your experience.
To advertise and retarget advertising of our and our Partners’ products and services, we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
To produce aggregated statistical reports, we use your order history, provided that the result of such reports do not identify you. The legal basis is our legitimate interests in running our business and improving our website.
5. WHO DO YOU SHARE MY INFORMATION WITH?
To provide our services and the website, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:
• Our partner boutiques and brands from whom you purchase products: we rely on carefully selected partners that supply the products that you see on our website. With your consent, we may also share with our Partners your name, contact information and purchase details about the products you have acquired from them for their own marketing purposes. The usage of your personal information for the mentioned purposes will be done in accordance with the Partner’s privacy policy.
• Third party service providers for business purposes: to function properly, we rely on a number of carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:
o Courier companies that we use in order to deliver the products to you and, as such, they need to have access to your order information, including your name and address. These providers have a global outreach, with many local companies that can be engaged depending on your shipping address.
o Payment providers that we use to process your payment information (including your credit/debit card details) so that we can collect payment from you. These are based in the European Union, United States and China and are engaged depending on your location.
o Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders to check for any fraudulent behaviour. Our current providers are based in the United States, Europe and Israel.
o Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimisation of the website. These providers are based in the United States and Europe.
o Customer Service management providers, that allow us to provide our customer services and improve and manage your customer experience. Our current provider is based in the United States.
o Marketing Tools providers that help us enable our marketing. These providers are based in the United States.
o Performance Marketing and Recommendations Providers that help us deliver advertising and recommendations of SnowBox products tailored to your interests and needs. These providers are based in Europe (mostly in the UK) and in the United States.
o Research companies that we can engage to help us carry out surveys regarding your use of our Website and Services. These providers are mostly based in Europe (mostly in the UK) or in the United States.
o Third parties that administer the platforms integrated with the Website, such as the selected partners which manage your product reviews.
o IT/technology providers that we use to support, maintain and provide our technology and IT infrastructure that supports our website and the storage of your information. This includes Microsoft Azure that we use to host your information. These providers are based in the Netherlands and Ireland.
• Advertisers for marketing purposes: we can provide your information to our advertising and social media partners that you select (including Facebook and Twitter), where they require the data to select and serve relevant adverts about ours and our partners’ products and services to you and others.
• Third party service providers to enrich data: we may also enrich, match or combine information we hold about you with data from other sources, for instance by sharing some of your personal data with selected business partners. These partners are based in the United States. We do this to better understand your customer profile and interests so that we can deliver customised offers and other personalised services.
• Third parties where we are considering a corporate transaction: the SnowBox is always looking for new opportunities and directions in which to grow. This means sometimes we may consider corporate transactions such as merger, acquisitions, reorganisations, asset sale, or similar. In these instances, we may transfer your information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, your personal information may be one of the assets that are transferred.
• To comply with legal requests: on occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands.
• Aggregated information with third parties: we may aggregate your information with the information of other customers, creating a dataset of information about the usage of our website, purchase of products, and other general, grouped information about our customers. The legal basis is our legitimate interest to understand the usage of our service and demand for our product. Although this dataset is aggregated and anonymised, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our website and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies (to help measure traffic), our partners and other providers (to allow them to better stock products), and our investors.
- COOKIES
We use technology such as “cookies” to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.
We use the following categories of cookies on our website:
Strictly necessary cookies: these cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided. These cookies will also inform us about your behaviour on our website, if we can do business with you and protect SnowBox and its customers from fraudulent activities.
Performance cookies: These cookies collect anonymous information on how you use our website (eg. we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site) and highlight areas we can improve such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. They are also used to help measure the effectiveness of an advertising campaign. You may opt-in to these cookies using your browser settings.
Functionality cookies: These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. You may opt in to these cookies using your browser settings.
Targeting cookies or advertising cookies: These cookies collect information about your browsing habits and limited aggregated demographic information in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites. You may opt-in to these cookies using your browser settings.
You can withdraw your consent to these cookies at any time through the following options:
• Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on;
• Other third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu.
• Any other type of cookies, you can clean the cookies through your browser settings.
Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.
7. SECURITY
Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:
• Using a Transport Layer Secure (TLS) to encrypt the personal data that you send us during the order process (including any financial information such as credit or debit card details).
• Requiring you to establish a unique username and password to access your FARFETCH account on our website.
• Not keeping details of your credit or debit card that would enable any third party to transact using that credit or debit card (such as your CVV number).
• Regularly monitoring our servers and IT systems for possible vulnerabilities and attacks. Unfortunately, despite this, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your personal data transmitted to or through our website, and any such transmission is at your own risk. In particular, please keep in mind that if you voluntarily disclose personal information through other means of communication than the website in a non-protected environment (such as through email, sms, online messages) then that information can be collected and used by others outside of our or your control.
8. HOW LONG WILL YOU USE MY INFORMATION FOR?
We retain the data you provide to us for as long as you have your SnowBox account with us and thereafter for such period as you may have questions or a claim in relation to our services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.
In some circumstances, you can ask us to delete your data as set out below.
After you have terminated your use of our services, we may store your information in an aggregated and anonymised format.
9. COMPLAINTS
If you have any questions or concerns about this Privacy Policy, please contact us:
• by emailing us at contact.snowbox@gmail.com
10. UPDATES TO THIS POLICY
Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.