Privacy Policy and Cookie Policy

3. Data collected by us

The data we collect falls into three general categories.

3.1 Data that you transmit to us

We collect information that you provide to us when you use the Snubes platform:

• Account information. When you create a Snubes account, we need certain information such as your name, email address, company name etc..
• Profile Data. We may also ask you to complete your profile in order to use certain features of the Snubes Platform. This may include your address and telephone number. Certain areas of your profile (e.g. your service description) are visible to others anonymously as parts of your public profile page.
• Other authentication data. In the interest of creating and maintaining a secure environment, we may collect the trade register number as well as the VAT ID.
• Payment information. When you use the payment services, we collect your payment information (such as your bank account or credit card details).
• Communication with Snubes and other members. When you communicate with Snubes or use the Snubes platform to communicate with other members, we process data collected to provide this communication service.
• Other Information. You may choose to provide us with information in other instances, such as when you fill out a form, perform a search, update or add information to your Snubes account, respond to surveys, post on community forums, participate in promotions, or use other features of the Snubes Platform.

3.2 Data we collect automatically when you use the Snubes Platform

When you use the Snubes Platform, we collect information about the services you use and how you use them.

• Usage Data. We collect information about your activities on the Snubes Platform, such as the pages or other content you view, your searches for services, bookings you make and other actions you take on the Snubes Platform.
• Location Data. When you use certain features of the Snubes Platform, we may collect information about your general location (e.g. IP address, postcode).
• Log Data. When you use the Snubes Platform, we automatically collect log data, even if you have not created a Snubes account or logged in. This data includes, but is not limited to: Information about how you used the Snubes Platform (including any links to third party applications), IP address, access times, information about hardware and software used, device information, device event data (e.g. crashes, browser type), and the website you accessed or interacted with before or after you used the Snubes Platform. Personally identifiable log data is deleted within a short period of time after your visit to our website or aggregated in such a way that no personal reference is possible.
• Transaction Data. We collect information about your transactions on the Snubes platform such as date and time, payments and other related transaction details. The data collected is deleted after settlement.
• Cookies and similar technologies. Snubes uses cookies for different purposes. See chapter 8 for more information.

3.3 Data we collect from third parties

We may collect information about you that others submit when they use the Snubes Platform or collect information (as outlined in the above two clauses and below) from other sources and combine it with the information we collect through the Snubes Platform.

• Your references. If you have asked someone to write a reference for you, it will be published on your Snubes profile page.
• Background information. For members, where legally permitted, Snubes may request reports from public registers. To request these reports, we may use your information, including your full name and company name.
• Other sources. If you consent in your profile, we may obtain further economic information about you from third-party providers and/or cooperation partners. For example, we may obtain credit check results from service providers as part of our risk assessment measures. We may process and store these results and make them available on the private Snubes profile page of clients and service providers in the form of a traffic light to provide both parties with neutral information about creditworthiness.

4. How We use Your personal data

We use, store and process information about you to provide, analyse, improve and develop the Snubes Platform and to create and maintain a trusted and secure environment.

4.1 Provision, improvement and further development of the Snubes platform

• To enable you to access the Snubes platform
• To enable you to communicate with other members.

For this purpose, we use the data that we automatically collect when you use the Snubes platform. The processing is necessary for our legitimate interests, which is why the legal basis here is Art. 6 para. 1 lit.f) GDPR. The processing serves to adapt our service to the interests of our users and to improve our service in general, to monitor and solve problems, for marketing purposes, to communicate with users, to contact users and for fraud detection and prevention.

4.2 Use of the Snubes offer

• To provide our customer service.
• To send you service or support messages such as updates, security alerts and account notifications.
• If you provide us with your contact details, we may use and store these details for the following purposes: (i) to enable you to invite colleagues or project collaborators, (ii) to enable you to send reference requests, (iii) for other purposes to which you separately agreed at the time of data collection. 
• To create your account and communicate directly via Snubes

On the Snubes platform, you can publish data so that it can be viewed by the general public. For example:

• Certain information from your service pages is anonymised in the search results list for all to see. They include data such as the service description as well as service data such as service language and lead times that the provider has released.
• After the conclusion of a contract, clients can write reviews. Such reviews are part of your public, anonymised service pages.
• The anonymised areas of your service pages or profile page, which may contain data such as your company name, logo, contact person, and description, are only visible to users after logging in to Snubes or may be blocked to protect information security.
• Information you share with everyone on the Snubes platform may be indexed by third-party search engines. In some cases, you can turn this feature off in your account settings. If you adjust these settings or your content shared with the public, these search engines may not update their databases. We have no control over the practices of search engines. They may use caches that contain outdated information about you.

To enable quotation requests, we may share your information with other members as follows:

• When you submit a service request as a client, certain information about you is shared with the provider. This includes your full name, company name, profile information and any other information that you agree to share. When you book an appointment online, other useful information is transmitted, such as your telephone number.
• If you as a provider have a confirmed enquiry, certain information will be passed on to the client. This includes your full company name, name, telephone number and address. 

For this purpose, we use in particular your account data and your profile data, as well as data regarding communication with Snubes and other members. The processing is necessary for the performance of a contract and for the implementation of pre-contractual measures or the performance of the contract. The legal basis is therefore Art. 6 para. 2 lit. b) GDPR. The data is deleted as soon as it is no longer necessary for achieving the purpose for which it was collected. This is the case when the registration with Snubes is cancelled.

4.3 Creating and maintaining a trustworthy and secure environment

• To conduct risk assessments to identify and prevent fraud, spam, abuse, security-related incidents and other harmful activities that are or may be directly or indirectly unlawful, harmful, threatening, defamatory, obscene, racially, sexually, ethnically or otherwise offensive; to infringe or violate the rights of others; to intentionally submit irrelevant, misleading or false information; to intentionally conduct activities that intentionally cause system disruption. To verify information or proof of identity you submit (such as verifying the address of accommodation or comparing your ID photo with another photo you submit).
• To resolve any disputes with our users and to enforce our agreements with third parties.
• To enforce our terms of use and payment terms.

In particular, we use your transaction data for this purpose. The processing is necessary for our legitimate interests, namely for the detection and prevention of fraud. The legal basis is therefore Art. 6 para. 1 lit. f) GDPR.

4.4 Provision, personalisation, measurement and improvement of our advertising and marketing measures

• To send you special promotions, marketing information, advertising and other information that may be of interest to you based on your communication preferences (including information about Snubes’ or business partners’ campaigns and performance). To personalise, measure and improve advertising.
• To conduct referral programmes, loyalty rewards, surveys, sweepstakes, contests or other sales promotion activities or events sponsored or conducted by Snubes or business partners

In particular, we process their account data and profile data for this purpose. The processing is necessary for our legitimate interests, in particular for marketing purposes and communication with users. The legal basis is therefore Art. 6 para. 1 lit. f) GDPR.

6. Transfers of Your personal data

We will only share your personal data with third parties in the following situations: 

6.1 External service providers

We use various service providers to provide services in connection with the Snubes Platform. For example, service providers may assist us with the following activities: (i) verifying or authenticating your identity, (ii) matching data against public databases, (iii) assisting with background checks, fraud prevention and risk assessments. We have concluded a data processing on behalf contract with each of these service providers in accordance with Article 28 of the GDPR.

6.2 Additional services by providers

Providers may use third-party services available through the Snubes Platform to assist them in managing their services. For this purpose, providers have access to functions on the Snubes platform through which information about the client (such as the name of the client, the telephone number of the client and the anonymised email address of the client) can be transmitted to the service provider in order to coordinate the tendering process, manage the offers or provide other services.

6.3 Data exchange between contracting authorities and service providers

To enable quotation requests, we may share your information with other members as follows:

• When you submit a service request as a client, certain information about you is shared with the provider. This includes your full name, company name, profile information and any other information that you agree to share. When you book an appointment online, other useful information is transmitted, such as your telephone number.
• If you as a provider have a confirmed enquiry, certain information will be passed on to the client. This includes your full company name, name, telephone number and address. 

Your billing and disbursement information will not be shared with other members.

6.4 Security and law enforcement

Snubes may disclose your information to courts, law enforcement and other government agencies or authorised third parties if and to the extent we are required to do so by law or if disclosure is objectively necessary for the following purposes: (i) to respond to claims brought against Snubes in accordance with the requirements of any legal process; (ii) in response to verified requests in connection with a criminal investigation or an alleged or suspected unlawful act or other action that may expose us, you or other users to legal liability; (v) for risk assessment, customer support, product development and troubleshooting purposes; or (iv) to protect the rights, property or personal safety of Snubes, our employees, other members or the public.

We will attempt to notify Members of data requests unless (i) notification is prohibited by the legal process itself, by a court order served on us, or by applicable law, or (ii) we believe that notification would be futile or ineffective, would create a risk of bodily harm or injury to a person or group of persons, or would create a risk of fraud to the detriment of Snubes, other Members, or the Platform (collectively, “Risk Scenarios”). In cases where we comply with legal requests for these reasons without notification, we will attempt to subsequently notify the member concerned of the request if we believe in good faith that we are no longer legally prevented from doing so or that a Risk Scenario can no longer occur.

6.5 Group companies

To assist us in providing the Snubes Platform, we may share your data with Snubes Schweiz GmbH, who will process it for the purposes set out in clause 4.4. If special additional conditions apply to the services they provide, we will notify you of this via the Snubes Platform.

In all other cases, we will inform you when personal information is to be shared with third parties. This gives you the opportunity to decide whether your information should be shared with the third party.

6.6 Aggregated data

We may also share aggregated data (information about our users that we combine so that it no longer identifies or refers to an individual user) and non-personal data for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

9. Newsletter

We also offer a newsletter to our users and other interested persons.

9.1 Receipt of the newsletter

You will only receive e-mail advertising if you have given your consent separately. Registration for our newsletter takes place in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter.

The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent to the storage of the data, the email address and their use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you provide us with for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted after you unsubscribe from the newsletter. Data stored by us for other purposes remains unaffected by this.

9.2 The use of MailChimp

Snubes uses the services of MailChimp for sending newsletters. The provider is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service with which, among other things, the sending of newsletters can be organised and analysed. If you enter data for the purpose of receiving newsletters (e.g. email address), this data is stored on MailChimp’s servers in the USA.

MailChimp is certified according to the “EU-US Privacy Shield”. The “Privacy Shield” is an agreement between the European Union (EU) and the USA, which is intended to ensure compliance with European data protection standards in the USA.

With the help of MailChimp, we can analyse our newsletter campaigns. When you open an email sent with MailChimp, a file contained in the email (known as a web beacon) connects to MailChimp’s servers in the USA. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked on. In addition, technical information is recorded (e.g. time of retrieval, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. It is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.

If you do not want any analysis by MailChimp, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message. You can also unsubscribe directly on the website.

The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you provide us with for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of MailChimp after you unsubscribe from the newsletter.

10. Data collection by third parties

Our carefully selected partners and service providers may process personal information about you on our behalf as described below.

10.1 Social networks

You can link your Snubes account to your account with a social network provider (Linked-In, Xing, Facebook, etc.). Your contacts on these third-party services are called “followers”. When you make this link,

• some of the data you submit to us by linking your accounts may be published in your Snubes account profile;
• a link to this third-party social network may be included in your private Snubes profile;
• The publication and display of information you submit to Snubes through this link will be governed by your settings and permissions on the Snubes Platform and the third party website.

10.2 Google Maps/Earth

Certain areas of the Snubes Platform use the Google Maps/Earth services, including the Google Maps API(s). The use of Google Maps/Earth is subject to the Google Maps/Earth Additional Terms of Service and the Google Privacy Policy.

10.3 Google Tag Manager

The Google Tag Manager is used for tracking analyses on websites.

10.4 Google Analytics

We use Google Analytics and Google Universal Analytics to recognise you and connect the devices you use when you visit our site or service on your browser or mobile device, log into your account on our service, or otherwise interact with us. We share a unique identifier, such as a user ID or hashed email address, with Google Universal Analytics to enable this service. Google Analytics allows us to better understand how our users interact with our service and tailor our advertising and content to you. For information on how Google Analytics collects and processes data, and how you can control the data that is sent to Google, please see Google’s “How we use data from websites or apps on or in which our services are used” page at http://www.google.com/policies/privacy/partners/. You can learn about the opt-outs currently available for Google Analytics, including for the Google Analytics browser add-on, here: https://tools.google.com/dlpage/gaoptout/.

We use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features allow us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform you, optimise and serve our ads based on your past visits to the Service. You can set your advertising preferences or opt-out of certain Google advertising products by accessing the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting the NAI’s online resources at https://optout.networkadvertising.org/?c=1. 

10.5 Google AdWords Conversion

Google AdWords Conversion provides us with information about what happens after a customer interacts with our ads – for example, whether they bought a product, subscribed to a newsletter or took other actions on our website.

10.6 Facebook Pixel

The Facebook Pixel provides us with data for the analysis, optimisation and economic use of the website.

10.7 Widgets

We may display certain areas of the Snubes Platform (e.g. your service page) anonymously, i.e. without your company name, name, logo or other personal information, on websites operated by Snubes’ business partners using technologies such as widgets or APIs. If your services are displayed on a partner site, anonymised information from your public profile page may also be displayed.

10.8 Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include: (i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. 

Their Data Protection Officer can be emailed at: dpo@sopro.io.

10.9 Hotjar

Snubes uses Hotjar as a third-party partner to improve the performance of the platforms.

When a user of Snubes visits one of our Hotjar enhanced platforms, Snubes privacy policy will apply to the Personal Data collected.

Hotjar may temporarily process your IP address so that we can ensure our service is running smoothly and improve the quality of our platforms. Any IP addresses we process are used exclusively for associated performance metrics and to monitor and track application errors. For this purpose, We may temporarily store your IP address with  Hotjar’s Sub-Processors which are subject to strict obligations of confidentiality, and will process it only according to Hotjar instructions.

Depending on the web browser you use, it might be possible for you to disallow Hotjar from collecting Data when visiting Snubes platforms. To discover if your web browser offers this functionality visit Hotjar’sDo Not Track page.

10.10 Lead Forensics

For marketing and optimization purposes, this website uses products and services from LeadForensics (Communication House, 26 York Street, London, W1U 6PZ United Kingdom). Lead Forensics determines the actual course of your visit to this website, including all pages visited and viewed by you, and how long you spent on this page. As far as IP addresses are collected, these will be anonymized immediately after collection. On behalf of the operator of this website, Lead Forensics will use the information collected to evaluate your visit to the website, to compile reports on website activity and to provide other services related to website usage and internet usage to the website operator https://www.leadforensics.com/cookie-policy/ . As far as we process personal data, we do so because of our legitimate interests to better design our website. The legal basis is the protection of legitimate interests in accordance with Art. 6 (1) (f) GDPR. You can object to data processing at any time with effect for the future by clicking on the following link: https://optout.leadforensics.com/?clientID=221406. We will not save any additional data.

12.1 Access and update

You can view, update or delete the data in your Snubes account by logging into your Snubes account and checking your account settings and profile.

12.2 Termination of the account

Information on how to cancel your Snubes account can be found in your account settings. Please note that by cancelling your Snubes account, all related information will be deleted and will no longer be available, including any reviews you have received. Submitted reviews from clients or providers will remain.

12.3 Checking and updating your data

You may request copies of your data held by us in writing. We will provide them with a copy of the personal data we hold about them as soon as possible and in any event no later than 30 days after we receive a written request or an email request. We may require proof of identity to verify their access request.

If the personal data we hold about you is incorrect, please let us know. We will then update the relevant information(s). You may also request the deletion or limitation of the use of your personal data in accordance with the relevant data protection laws.

12.4 Access to and complaint about data transmitted to us by third partie

You have the right to access and challenge information provided to us by third parties as part of our fraud detection/prevention and risk assessment activities if all of the following conditions apply: (i) we use third parties to carry out automated checks or risk assessments; (ii) we make a decision that has legal consequences for you or that significantly affects you; and (iii) the decision is based solely on the automated checks or risk assessments. 

12.5 Right to data portability

Where we process your personal data (i) on the basis of your consent or for the performance or initiation of a contract with you and (ii) the processing is carried out with the aid of an automated procedure, you have the right to receive the personal data relating to you in a structured, common and machine-readable format and to transfer this data to another controller without hindrance from us. Where technically feasible, you also have the right to request that we transfer this data directly to the other controller. The exercise of this right to data portability does not affect your right to request the deletion of their data.

12.6 Right to restriction of processing. 

You have the right, in certain circumstances, to request that we restrict the processing of your personal data if you dispute the accuracy of the personal data for a period of time that allows us to verify the accuracy of the personal data.

12.7 Right of objection

You have the right to object on grounds relating to your particular situation to the processing of your personal data and the right to object to the processing of your personal data for direct marketing purposes insofar as they are related to such direct marketing.

12.8 Right of appeal

Without prejudice to any other administrative or judicial remedy, you have the right to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information or have responded to your concerns. Please visit the ICO’s website for further information, including contact details.