1. General

Welcome to Snipperwall. Snipperwall is convinced that protecting the privacy of its users and customers is of great importance. This statement is meant to inform users of the Website http://www.snipperwall.com about their privacy. Information is given about how personal data is collected and processed and how users can influence the processing of their personal data. This Privacy statement only applies to the use of personal data on the website http://www.snipperwall.com (hereinafter: the website). The personal data of users is being processed with the utmost care and security. Snipperwall is compliant with all applicable European and Dutch law and regulations, including the Data Protection Act. The Controller for the processing of personal data is: Serramedia B.V., Kruithuisstraat 25, 1018WJ, Amsterdam.

2. Definitions

a. Privacy Statement: this privacy- and cookie statement;

b. User: Every user that has an account for Snipperwall

c. Controller: Serramedia B.V., Kruithuisstraat 25, 1018WJ, Amsterdam

d. Website: www.snipperwall .com

3. Providing personal data is not required

Providing personal information is not mandatory. Users always have the choice to not let their personal data be processed by the Controller. However in order to make use of all the functionalities of the Website it is necessary to process personal data of users. Some services can only be provided when the User has accepted the processing of his personal data. “Personal information” is any information used to identify an individual, including, but not limited to, first and last name, an email address, phone number, employer name, or other contact information.

4. Which information is collected?

4.1 Data Submissions by Users. In some areas on our Website, we ask Users to provide Personal Information that will help us to enhance the use of the Website or for other purposes: facilitating correspondence, providing Users with the products or services requested or registering entitlement to access certain special features of the Website. It is always the Users choice whether or not to submit that Personal Information. If Users choose not to provide requested Personal information, they may not be able to use certain features of the Website.

4.2 Data Collection by Controller. The Controller will also automatically collect information about surfing habits of its Users. This information consists of the IP address and cookies. This is related to the way Users use our Website and services, such as what pages Users visit, what information Users search for or what type of browser Users are using. We only use this anonymous data to operate and improve our Website and services.

4.3 Data Collection by Third Parties. The Website has the possibility to exchange personal data of their Users with its group companies and combine this data with personal data collected as part of a purchase or through the use of products or services. Snipperwall and its group companies can also share personal data as a result of the collection of cookies through surfing data.

These cookies are called third party cookies. Third parties can also store cookies on the computer of the User. For the use of cookies by a third party, the privacy and cookie policy of these third party shall apply. Advertisers and other companies do not have access to the cookies stored by Snipperwall.

If the cookies of Users are used by Google, Users can withdraw their consent. Users can withdraw their consent through the following linkhttp://www.google.nl/privacy_ads.html. And for its group companies, Users can withdraw their consent through the following link http://www.youronlinechoices.eu/nl.

5. Cookies

5.1 Snipperwall makes use of session cookies that are stored on the browser of Users. These cookies are small pieces of information that our server sends to the browser of the computer of the User. The purpose of these session cookies is to facilitate the use of the Website during a session. For example, if a User wants to go back to a previous page during his session, the information of that previous page is still available.

5.2 Snipperwall makes use of affiliate cookies, these cookies will automatically be deleted when the browser is closed. Snipperwall also makes use unique ID cookies. So Users can be identified as a unique User. This cookie has a lifespan of a year which means that it automatically will be deleted once a User has not visited the Website for more than a year. Finally, Snipperwall uses temporary cookies. These temporary cookies record Users’surfing habits on the Website for up to ten days. When on the eleventh day User enters the Web the data from the cookie from day one will disappear. The information obtained through these cookies, will be automatically deleted 60 days after Users last visit the Website.

5.3 Snipperwall stores cookies for the technical storage or for the access to data for the sole purpose of providing communication over an electronic communications network. The communication on the Website in some cases can only be made possible by placing a cookie. Snipperwall also makes use of cookies which are strictly necessary for the storage or access to the Website.

5.4 Under Art. 11.7a Telecommunicatiewet it is required that when Snipperwall uses cookies for other purposes than listed in 6.1, Snipperwall needs to have the explicit consent of the User. The User of the Website will need to be informed in advance why Snipperwall needs these cookies and what the benefit is for the User of the Website. The User needs to be aware of the consequences of the use of their cookies. Users can always withdraw their consent at any time.

5.5 If the User does not want to give his consent to use of cookies, the User should decline the request for permission. In that case it may happen that the User is not able to get access to all the features of the Website. Each time the User enters a certain part of the Website it could occur that Snipperwall will makes a new request for permission to use cookies.

5.6 If the User does not want to give his consent for the use of cookies, the browser settings can be adjusted while visiting the Website to block the use of cookies. In that case, however, it may happen that the Website is not accessible. The browser can be set by the User so that the User will be informed whenever a cookie is stored. The button “HELP” in the toolbar of most browsers will help the User adjust the settings of the computer.

6. For what purposes are personal data processed

6.1 Snipperwall processes the data of User for the following purposes:

– For the delivery of products and services of the Website;

– For targeted offers. Snipperwall can place ads of products or services that are based on Users interests. In the context of optimizing the deals Snipperwall can draw a profile of Users;

– To send Users newsletters, offers, user information, services, messages or other electronic messages;

– To analyze, maintain, protect and optimize its Websites and related technologies;

– To comply with all the regulatory obligations.

6.2 Snipperwall can send newsletters to Users who have given their explicit consent. Users permission can always been withdrawn or modified.

6.3 Snipperwall stores the personal data in principle as long as needed to comply with the above mentioned purposes. Snipperwall will also store personal data to meet all legal (storage) requirements.

7. Transfer of personal data to third parties

7.1 Snipperwall only gives personal information to third parties as Users have given their explicit consent.

7.2 By agreeing to this Privacy Statement, the User has given Snipperwall permission to carefully select and provide third parties with the personal data of Users. These third parties are directly involved in the Website and have access to personal data only to the extent necessary in connection with the under 9.1 mentioned purposes.

7.3 Only with the unambiguous consent of the User, Snipperwall can use personal data to send electronic information and offers from carefully selected third parties about their products and services. Snipperwall will always evaluate promotional information from third parties before it is send to Users. Snipperwall selects these third parties based on the information Snipperwall has collected about product purchases, internet behavior and subscriptions. These third parties will then use Users’ personal data to make offers that are aligned with the interests of the User. Users can withdraw their permission for the use of electronic data by third parties by sending an email to support@snipperwall.com.

7.4 In special cases, Snipperwall may let third parties process the personal data of Users without prior consent. Special cases could include lawful requests from authorities, subpoenas, court orders, actions for damages, the detecting or prevention of fraud, or acts to improve safety of the network and to guarantee the quality of the services. Snipperwall will also provide personal information to editors who on behalf of Snipperwall provide products or services.

7.5 Snipperwall can share certain anonymous data with third parties, such as the number of Users or how many Users have clicked on a particular advertisement. On the basis of these data no identification of Users can be made. So these data are not to be considered personal data.

8. Location of servers

8.1 Snipperwall makes use of servers for the storage of personal data. These servers are located in Ireland, Amazon Cloud Services.

8.2 However, Snipperwall reserves the right to store and process personal data outside the territory of the EEA. In that case Snipperwall assures that the country where the personal data is processed will fulfill all the regulatory demands of the European Data Protection Directive.

8.3 When Snipperwall makes use of servers outside the territory of the EER Users will be asked for their unambiguous consent.

9. Security of personal data

9.1 Snipperwall uses the appropriate technical and organizational security measures to protect the personal data of the Users. Given the fact that these measures are deemed to be the state of the art, protection should be considered sufficient to prevent unauthorized access, alteration, disclosure or loss of personal data.

9.2 The whole procedure of processing personal data is in compliance with the requirements of proportionality and subsidiarity.

10. Inspection, modification and deletion of your personal data

10.1 At any time a User may request to get access to all his (personal) data that Snipperwall has collected and processed. Users can also submit a request for their data to be changed or deleted. The User can send an e-mail to support@snipperwall.com.

10.2 If Users do not want to let their personal data be processed by third parties or that their personal data is being used for targeted offers, Users can withdraw their consent by sending an e-mail. If Snipperwall can not or not fully identify the User’s questions in relation with his request for inspection, modification or removal of his personal data, Snipperwall will ask to specify the request. Snipperwall will suspend the execution of the request of the Visitor until Snipperwall has been provided with further specification. After the execution of the request Snipperwall will send the User a confirmation message.

10.3 After Snipperwall received the request to stop processing personal data of the User, Snipperwall will terminate the processing of personal data of the User as soon as possible. In case of a legitimate request for removal, alteration, deleting or modifying the personal data this will also take place as soon a possible, except to the extent that Snipperwall could de obligated by law to keep personal information. Snipperwall could have (other) compelling reasons to resist against the elimination of the personal data.

10.4 The Website also gives the User the right to see or change his own personal data, and the Website allows the User to remove personal data from the appropriate data capabilities.

11. Minors

In some cases, the Controller will ask for the explicit permission to use personal data. If the User is younger than 16 years, the User in such cases has to have consent of his or her parent or guardian for the processing of personal data by the Controller. The parent or guardian may in that case have the right to modify or delete the personal data of the minor.

12. Changing the privacy and cookie policy

Snipperwall reserves the right to adapt her privacy and cookie policies. Snipperwall advises the visitor to regularly check the Website to see if changes are made. If Snipperwall has made substantial changes in her privacy and cookie policy it will ensure that there is a more prominent way to notify the Users, for example through email.

This Privacy and Cookie Statement was last amended on 12nd of March 2015.