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1. Introduction

Puff Corp’s Privacy Policy describes how Snako, and it’s subsidiaries and affiliates, collects, uses, and shares your information through your use of our websites, our mobile applications and any other services controlled by Snako. Accordingly, Snako is the “Controller” of the information that we collect, and any personal data we collect, in any form, is governed by this Privacy Policy. By visiting the Snako website, using a Puffco mobile app, or using any Snako service.

 

Throughout this Privacy Policy, Snako may be referred to as “the Company”, “We”, “Us”, or “Our”.

 

2. Information We Collect

When you visit Snako’s websites, use any Snako mobile application, or use any Snako service, we may collect the following categories of personal information (“Personal Information”):

 

Personal Identifiers:

 

Birthdate

Name

Demographic Information

Email address

Telephone number

Mailing address

Username and password

Age verification information, which includes any information you have provided to help us verify your age

Purchase Information:

 

Credit or payment information

Proof of Purchase

Information reported for a warranty claim

Device serial numbers

Technical Information

 

Diagnostic data from your device, such as firmware version, app usage, and device features

IP address

Browser type

Mobile operating system

Usage Data

Location Information

 

We will only collect location data if you share it with us from your mobile device when you use the Snako app and connect a Snako device to the app. We do not track location data automatically. You can opt out of sharing Location Information at any time in the Snako app settings.


3. How We Collect Information

We may collect PI in the following several ways:

 

When you purchase our products on our website

When you verify your age

When you sign up to receive marketing information via email or text

When you follow us or interact with us on social media

When you give us feedback based on a survey

When you contact our Customer Service team for support

When you make a warranty claim

When you create an account on a Snako mobile app

When you use the Snako app with a Snako device

When you apply for a job with us


4. How We Use Information

We may use the information we collect from you to in the following ways:

 

To complete a transaction on puffco.com

To provide you with information, services, and products offered on or through puffco.com;

To market our products to you (see “Marketing” below)

To verify that you are of legal age to purchase our products

To provide customer service on our products

To fulfill a valid warranty claim

To create and manage a profile you create on our site or mobile application

To create insights and analysis of our products and they way you use them

To respond to or follow-up on your comments, inquiries, or other requests;

To improve the quality of our websites and products, and tailor them to your preferences;

To communicate with you and interact with you on social media


5. Sharing Information

Under no circumstances do we rent or sell your PI. We may share your PI with (1) our wholly-owned affiliates and subsidiaries; and (2) our service providers who perform services on our behalf, such as order fulfillment, marketing, customer service, and analytics. We do not authorize our service providers to use or disclose your personal information except as necessary to perform services on our behalf or comply with legal requirements. We share Personal Information in the following ways

 

On rare occasions, we may need to share PI to comply with legal subpoenas related to investigative demands from courts and law enforcement agencies. We want to be perfectly clear on this point: we will only share information with law enforcement only if law enforcement has (1) obtained a valid subpoena from a court or other governmental agency that has authority to issue a subpoena, and (2) if there is no ability for Snako to challenge the validity or scope of the subpoena. You have our word that we will always challenge a subpoena if we believe the subpoena is unlawfully issued.

 

In addition, we share aggregated anonymized information, including usage data about Snako products, with third parties and service providers for a variety of purposes, including quality assurance. We take steps to ensure that you cannot be identified from this information and we require third parties to keep all shared information in its anonymized form.

 

Any of our service providers with whom we share your PI are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. We will take all reasonable steps to make sure these service providers comply with the same privacy principles that govern our collection of your Personal Information.

 

6. Marketing

When we collect your PI for marketing purposes, we will ask for your consent, such as by email response, opt-in box or click through agreement acceptance, before we use or share your PI for any other purpose.

 

You have the right to ask us not to process your Personal Information for marketing purposes. We will inform you (before collecting your Personal Information) if we intend to use your Personal Information for marketing purposes, or if we intend to disclose your Personal Information to any third party for marketing purposes.

 

We will give you choices about your Personal Information. Some choices are presented up front in the form of opt-in notices or acceptance boxes for marketing to you or sharing your Personal Information with third parties. You always have the choice to opt-out if you later change your mind. One form of opt-out is clicking the Unsubscribe link in a marketing email. This will remove you from our marketing email list. Please note that these opt-in/opt-out choices do not apply to the receipt of mandatory website, service or software communications, such as receipt of order or shipping confirmations on Snako website stores, which you may receive periodically as part of Snako performing its contract with you.

 

If you do not wish to receive direct marketing material from us or a third party on our behalf, in addition to following the “Unsubscribe" instructions in a marketing email, you can send us a request at customerservice@puffco.com.

 

7. Security of Information

We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

 

8. Cookies

When you use visit our websites, app or use our services, we may use “cookies” and similar technologies (e.g., beacons, log files, pixels and Flash LSOs). This technology involves placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences and generally improving your experience on or with our Services.

 

Specifically, we may use such technology for purposes such as to:

 

Provide us with general analytics about our Services, including demographic information in a non-identifiable form, in order to improve our Services’ performance and customize users’ experience;

Support security measures

Allow you to engage in our social media offerings on our Services (e.g., Facebook “Like” button); and

More effectively market our Services and advertise other Services that may be of interest to you.

Where required by law, we collect your consent for the use of such technologies.

A cookie is a small text file saved on your device or browser. Some of these cookies are necessary for the functioning of our Services (known as “Strictly Necessary” cookies), while others are not (known as “Non-Essential” cookies). Some cookies (known as persistent cookies”) will remain on your device until you delete them, while others (known as “session cookies”) are automatically erased when you exit your Internet browser.

 

You can set your device or browser to accept or reject most cookies, or to notify you in most situations that a cookie is offered so that you can decide whether to accept it. However, if you block cookies, certain features on our Services may not function. Additionally, even if you block or delete Cookies, not all tracking will necessarily stop.

 

We may place or recognize technology on your browser or device when you visit or use our Services for purposes of serving you targeted advertising (also referred to as “online behavioral advertising”). We also work with third party advertising companies who place their own cookies or similar technology on your browser or device when you visit or use our Services and other websites to serve customized advertisements to you as you browse the Internet. As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered. Please note that even if you reject such technology, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests.

 

9. Your Choices and Rights

When you provide us with personal data, you have rights about how we use it, and why.

 

If you no longer wish to receive email marketing communications from us, you may opt-out of receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Likewise, , to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in.

 

Similarly, if you no longer want to receive text messages from us, reply STOP (or as otherwise instructed) in the text message. We will always ask for your consent to send

 

10. California Privacy RIghts

If you are a California resident and customer of Snako, you have the right to receive, once per year, free of charge, 1) the identity of any third party company to which we have disclosed your personal information as defined by California’s “Shine the Light” law for that company’s own direct marketing purpose; and 2) a description of the categories of personal information disclosed. To request this information, please contact us at privacy@puffco.com, or at the address listed in the “Contact Us” section below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email or mail address.

 

For California residents, while we never sell your information you can still make a CCPA “Do Not Sell” request to us by emailing us at privacy@puffco.com.

 

California law also requires us to let you know that we do not respond to DNT signals.

 

11. European Privacy Rights

As an EU resident, you have the following rights:

 

To request access to your personal data (commonly known as a “data subject access request") (GDPR art.15).You may receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

To request correction of the personal data that we hold about you (GDPR art.16). You may have any incomplete or inaccurate data we hold about you corrected.

To request deletion of your personal data (GDPR art.17). You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

To object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms (GDPR art.21). You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

To request restriction of processing of your personal data (GDPR art.18). You may ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

To request the transfer of your personal data to you or to a third party (GDPR art.20). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To object to the processing of your personal data under certain circumstances in particular if we process your personal data on the basis of legitimate interest (GDPR Art. 6 (1)(b)) or if we use your personal data for marketing purposes.

To lodge a complaint with a EU Member State of your residence, place of work or place of the alleged infringement if you consider that our processing of your personal data infringes the applicable data protection laws.

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