Privacy Policy

Last updated: January 30, 2024

This privacy policy describes the personal information that we, Sneex, LLC, and our subsidiaries (collectively, “Sneex”, “we”, “us”, or “our”) collect about you, why we collect it, how we use it, and when we disclose it with third parties or service providers.

This privacy policy covers our website, the Sneex mobile or desktop application (the “Site”), our associated services, and any other future platforms or offerings that we may develop (collectively, the “Platform”).

What personal information do we collect about you?

We collect the below categories of personal information from you when you access the Platform:

  • Contact and Account Information: Name, email address, postal address, and phone number. If you create an account with us, we also collect demographic information such as your age, date of birth, and gender, in addition to your account username and password.
  • Payment Information: When you place an order with us, you will need to pay for the products or services you have ordered. We collect partial credit card number (or other payment method) and associated payment details associated with your order. We share your personal information with third parties that process payment card transactions on our behalf. Our third-party payment processors collect, use, and process your information, including full payment card numbers, in accordance with their privacy policies. You can access their privacy policies via their own websites.
  • Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product detail, purchase price, and date of the transaction.
  • Website Activity: We collect information related to your access to and use of our Platform, including the type of browser you use, access times, pages viewed, your IP address, and the page you viewed before and after visiting our Platform. We may also collect this type of information in visual form when you visit our Platform, including video snippets of your Platform activity.
  • Device Information: We collect information about the computer or mobile device you use to access our Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • Geolocation Information: We may derive the approximate location of your device from your IP address. We may also collect information from your device in accordance with your device settings.
  • Commercial Information: We collect information about your product and service preferences and interests.
  • Social Media Information: Account names, handles, biographies, and other details that you make available on social media networks.
  • Other information that you may provide to us or that we may infer based on the above.

How do we collect personal information?

We collect personal information directly from you in the below contexts. We also collect personal information from you using sources like advertising or marketing networks, data analytics providers, social networks, data brokers, and other service providers or third parties.

  • If you register an account with us
  • In connection with purchases and returns
  • If you upload or share a photo or other digital content through one of our Platforms, or share content linking to any of our social media platforms
  • If you enroll in our loyalty program
  • If you participate in a contest, promotion, or survey
  • If you contact us via e-mail or through our customer service, including through the use of online chat tools that we may make available
  • We and our third-party vendors may use tracking tools like browser cookies, flash cookies, pixels, and web beacons to collect information from you. Please see “How do we use cookies and other tracking technologies?” for more information.

How do we use your personal information?

We may use your personal information in the following ways:

  • To provide, operate, maintain, protect, and improve our Platform;
  • To fulfill your order (including to send you emails to confirm your purchase and provide you with updates with respect to your order status and shipment) and to provide you with related customer service in order to manage our contractual relationship with you, and to comply with our legal obligations;
  • To communicate with you, respond to your inquiries, and to send you information by email, postal mail, telephone, text message, notifications, or other means about our products, services, and rewards and promotions;
  • To administer our promotions and any loyalty program(s);
  • To enhance and help us better understand your shopping experience, needs, and preferences and provide consistent, personalized services and experiences across our Platforms;
  • To protect the security or integrity of the Platform, including to perform security analyses to verify that the Platform is working properly and have not been compromised based on our legitimate interests;
  • To protect us, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), fulfill our reporting obligations, monitor and enforce compliance with our contracts, including our Terms of Platform and Terms of Sale, and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable; and
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred.

How do we disclose your personal information?

We disclose your personal information to the following categories of third parties:

  • Platform providers: We engage vendors to perform certain functions on our behalf such as: payment processors, billing and collection providers, auditing and accounting firms, professional services consultants, providers of data hosting, storage, and analytics services, and IT and security vendors.
  • Social media platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you through cookies and other digital tracking mechanisms that they place on your device. In some cases, the social media company may recognize you through these technologies even when you do not interact with their platform. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and the controls they make available to you.
  • Companies involved in advertising: We work with companies that assist us in advertising our Platform to you and others who may be interested in the Platform. These companies may use tracking technologies on our Platform to collect or receive information over time and across different websites or platforms, including this Site and the Platform and elsewhere on the internet, and use that information to provide measurement services and provide you with targeted ads. 
  • Corporate affiliates: We share personal information with our subsidiary companies.
  • Business partners: We may work with other companies to provide you with certain product or service offerings.
  • Law enforcement, government agencies, or parties in a legal proceeding: We may share personal information with these entities to comply with the law or assist law enforcement. We may also provide your personal information to third parties in the context of a subpoena or similar legal process.
  • Third parties in the context of a merger or similar business transaction.

How do we use cookies and other tracking technologies?

We and our third-party vendors use cookies, pixel tags, and other tracking technologies on the Platform in a variety of ways to enhance or personalize your online browsing and shopping experience. These tracking technologies help us better understand your shopping needs and preferences and tell us which parts of our website you have visited, facilitate, and measure the effectiveness of our advertisements, and provide consistent and personalized services and experiences. These tracking technologies gather information over time and across different websites about you, some of which may be personal information as identified above in “What personal information do we collect about you”.

You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. If you do not accept cookies, however, you may not be able to access your account information or make purchases on our Platform. Please note that our Platform does not currently recognize “Do Not Track” signals. However, our Platform may recognize certain opt-out preference signals, such as the Global Privacy Control. You may set such a signal through your browser or browser extension.

Third Party Links

Third-party links on the Platform may direct you to third-party websites that are not affiliated with us, including social media platforms. We are not responsible for the content or accuracy of third-party websites, or for any other materials, products, or services of third parties.

We are not liable for any harm or damages related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with any third-party websites. Please review carefully the third party’s policies and practices and make sure you understand them before you access their website. Complaints, claims, concerns, or questions regarding third-party products should be directed to the third party.

How do you protect my personal information?

We take reasonable precautions, including working with reputable third-party payment processors and implementing physical and electronic safeguards, to help protect the security and privacy of your personal information. However, please be aware that no means of transmitting data over the internet is 100% secure. Please take steps to protect your own personal information, such as by selecting a unique and complex password for your account.

Do we collect children’s information?

We will never knowingly request personal information from anyone under the age of 18. Our Platform is not targeted to or intended for use by children. Accordingly, we do not have actual knowledge that we sell or share the personal information of consumers under the age of 16 years old. However, if we learn that we have received personal information from a child under the age of 18 without appropriate parental consent, we will delete that information from our database.

How long do we keep your personal information?

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:  

  • The length of time we have an ongoing relationship with you and provide the Platform to you (for example, for as long as you have an account with us or make purchases);
  • Whether there is a legal obligation to which we are subject (for example, we are required to keep records of your transactions for a certain period of time); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).   

What choices do I have about my personal information?

You can review and change certain personal information related to your use of the Platform (such as your name and contact information) by signing into your account or by contacting us as described in the section entitled, “How do I contact you?” below.

If you prefer not to receive promotional communications from us, such as information about special offers, you can let us know by contacting our customer service as described in the section entitled, “How do I contact you?” below. You may also follow the instructions included with the message, such as by following unsubscribe or opt out links.

Please note that when you make an online purchase from us, we will continue to confirm your order status and shipment by email. We may also need to contact you via telephone, email, or postal mail with questions or information regarding your order or other non-promotional matters.

Do I have any rights to my personal information?

You may have rights (“Data Subject Rights”) with respect to the personal information that we collect or process about you, however, these rights differ depending on your country or state of residency, including the European Union, the United Kingdom, California, Virginia, Colorado, Connecticut, Utah. Please note that we reserve the right to honor your Data Subject Rights to the extent required by applicable law.

  • Right to Confirm Processing, Access, and/or Obtain a Copy (referred to in some countries as a Data Subject Access Request): If you ask us, we will confirm whether we are processing your personal information. Additionally, upon request, we will provide you with a copy of all personal information you are lawfully entitled to receive, potentially including specific pieces of information, along with certain other details.
  • Right to Amend: If you believe your personal information is inaccurate or incomplete, you may request that we correct it.
  • Right to Delete: You may request that we delete your personal information but should note that this right is limited and subject to certain exceptions as prescribed by applicable law.
  • Right of Portability: You may request that we move, copy, or transfer the electronic personal information that we hold about you to another organization.
  • Right to Opt Out of Certain Processing Activities: You may ask us to restrict or stop the processing of your personal information. This includes general requests and requests in specific contexts, such as if we process personal information that is considered “sensitive” under applicable U.S. state laws or engage in certain automated decision-making activities.
  • Right to Opt Out of Targeted Advertising: Targeted advertising is the practice of serving you tailored advertisements based your personal information gathered over time and across other businesses, websites, applications, or services. You have the right to opt out of this practice.
  • Right to Opt Out of Sales: Some states may consider targeted advertising a “sale” of personal information. You may request that we not “sell” your personal information.
  • Right to Non-discrimination: We will not discriminate against you for exercising Data Subject Rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of your personal information.
  • Right to Appeal: If we deny your request to exercise a Data Subject Right, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please be sure to include information about your prior request so that we may locate our earlier determination. 
  • Right to Lodge a Complaint: You may submit a complaint to the competent supervisory authority in the country in which you live if you have any concerns about our processing of your personal information.

If you or your authorized agents would like to exercise a Data Subject Right, you may do so by following the instructions in “How do I contact you?” below. Please note that you may also login to your account to access and correct your account information at any time.

In order to process your request to exercise a Data Subject Right, we will ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as most recent purchase, if applicable.

Additional Disclosures for California Residents

If you reside in California, please read this section for additional disclosures about how we collect, use, and disclose information about you under the California Consumer Privacy Act (or “CCPA”) (California Civil Code Section 1798.100 et seq.).

  • Categories of Personal Information Collected: In the previous 12 months, we have collected the personal information listed in the section “What personal information do we collect about you?” above. This information falls into the following categories under the CCPA: identifiers; categories of personal information described in Cal. Civ. Code 1798.80(e); commercial information; geolocation information; audio, electronic, or visual information; internet or electronic network activity information; inferences drawn from the above categories. Additionally, we collect the following “sensitive” personal information: account credentials and contents of messages that you send to our customer service providers. 
  • Sensitive Personal Information Uses or Disclosures: We do not use or disclose “sensitive” personal information for purposes other than those specified by the CCPA.
  • Business or Commercial Purpose for Collecting and Selling Information: We collect personal information for the business and commercial purposes described in “What personal information do we collect about you?” and “How do we use your personal information?” above.
  • Categories of Sources of Personal Information: We collect personal information from and about you as described in “How do we collect personal information about you?” above.
  • Categories of Third Parties with Whom We Disclose Information: We may disclose your personal information with third parties as described in “How do we disclose your personal information?” above.
  • Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the categories of personal information listed in “What personal information do we collect about you?” for the reasons described in “How do we disclose your personal information?” above.
  • Sale or Share of Personal Information: Because we engage in the practice of cross context behavioral advertising, also known as online targeted advertising, we may “sell” and/or “share” your personal information as those terms are defined by the CCPA. In the preceding 12 months, we may have “sold” or “shared” identifiers, commercial information, and internet or electronic network activity information with data analytics, advertising networks, and/or social media networks.

Your Nevada Rights

2019 Nev. L. 211 permits customers of Sneex who are Nevada residents to request that we not sell their personal information. We do not sell personal information as defined by Nevada law. If you are a resident of Nevada and would like to request that we not sell your information in the future, please contact us following the instructions below.

Additional Information for Residents of the European Economic Area and the United Kingdom

For personal information subject to the General Data Protection Regulation (“GDPR”), we will not collect or process that information unless we have a lawful basis to do so under the GDPR. The principal lawful bases that we rely on include:

  • Legitimate interests: We process your personal information in connection with meeting our legitimate business objectives (such as those listed above) or those of a third party. We balance those interests against any risks to your rights from our data processing activities and do not pursue any data processing where the potential harm to your rights outweighs our legitimate interests.
  • Performance of a contract: We process personal information to the extent necessary to perform our obligations under a contract with you or your organization, or if requested by you or your organization to enter into a contract with us.
  • Legal obligation: We may need to process personal information to comply with a law or legal process to which we are subject.
  • Consent: If we rely on consent as a lawful basis for processing your personal information, we will obtain your consent before processing your personal information for one or more specific purposes. You are free to withdraw your consent at any time.

Cross Border Transfers

Sneex is headquartered in the United States and uses service providers around the world. As part of our data processing activities, we may transfer your personal information across borders, including into countries whose laws protecting personal information may not be as robust as your home country’s laws. We endeavor to take reasonable steps to have adequate safeguards in place to protect your personal information when it is transferred across borders.

If we transfer any personal information from the European Economic Area to countries not deemed by the European Commission to have an adequate level of personal data protection, we will use adequate safeguards or other lawful means to make the transfer in accordance with applicable privacy laws.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time and notify you in accordance with law, which may include email or other notice posted to the Platform. Any changes to this Privacy Policy will become effective when we notify you of the changes. Your use of the Site or Platform following any such updates will constitute your acceptance of such updates.

How do I contact Sneex?

For questions about our privacy policy, to make choices about receiving promotional communications, to request to exercise a Data Subject Right, or to update your personal information, you can contact us by email, at legal@sneex.com, or by writing us at P.O Box 550829, Atlanta, GA, 30355. [If you would like to request to exercise a Data Subject Right, you may also email legal@sneex.com.

Additional Information for Job Applicants

This section supplements the information provided above and describes the additional personal information we collect when you apply for a job with Sneex. We may collect the personal information in the below table in the following ways: directly from you; from publicly available sources, such as government entities, public records systems, and social media networks; data analytics providers and data brokers; or as you may otherwise authorize, such as a former employers or references.

Please note if you use our Platform in the job application process, additional information is collected, as described above. We may collect the personal information categories listed in Cal. Civ. Code § 1798.80(e) (the California Customer Records Statute) in addition to the categories of personal information listed below. Items with an asterisk (*) may be considered “sensitive” personal information according to the CCPA.

  • Identifiers: Government-issued identification numbers, including your Social Security, driver’s license, passport, state identification card, or military identification card numbers.
  • Demographics and Protected Classifications*: citizenship, gender, data of birth, age, and other traditionally protected classifications that you chose to disclose, such as race and ethnicity, marital status, sexual orientation, veteran or military status, disability, and medical status
  • Professional or Employment Related Information: professional associations and employment history, including name of employer, position, employer contact information, and associated employment records
  • Educational Information: educational institutions attended, degrees and certifications attained, and other educational or student records, which may include details about attendance, grades, and academic and disciplinary history

We generally collect this personal information in order to evaluate your application for employment. For more details about how we use and disclose the personal information listed here, please refer to “How do we use your personal information?” and “How do we disclosure your personal information?” above.