Privacy Policy

Last updated June 30, 2023

This Privacy Policy describes the personal information Snorkel Europe Limited (Snorkel UK) and Snorkel International, LLC (collectively, “Snorkel”, “we”, “our”, or “us”) collect from you when you, how we use it, with whom we share it, and the choices you have in connection with this.

APPLICABILITY OF PRIVACY POLICY

This Privacy Policy applies to the Snorkel websites at snorkellifts.co.uk and snorkellifts.com (collectively, the “Website”), as well as Snorkel’s offline services and interactions with you (collectively, the “Services”).

INFORMATION WE COLLECT AND USE

Through your use of our Services, we collect personal information directly and automatically as outlined below. Except as otherwise indicated, the personal information you provide is such that we need to carry out the requested action. If you do not provide us with your personal information, we would not be able to do so.

A. Information Collected From You

We collect personal information from you when you:

• Attend an event:If you attend an event and interact with us, we will collect your identifiers (name, company name, telephone number, and email address). We use this personal information to communicate with you and send you information we feel may be of interest to you. The legal basis for this processing is your consent.
• Apply for employment: When you apply for employment with Snorkel, we will collect your identifiers (name, email address, physical address, telephone number) and your professional or employment information (resume, cover letter, employment history, and educational history). We use this personal information to create assess and manage your application with Snorkel, to communicate with you, and as necessary to comply with the law. The legal basis for this processing is that the processing is necessary to perform a contract with you or to take steps, at your request, before entering a contract. We also process this personal information as part of our legitimate interest in the facilitation and optimization of our recruitment process.
• Contact us: When you contact us or submit an inquiry, we will collect your identifiers (name, email address, telephone number, physical address, postal code, company name) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you have. The legal basis for this processing is performance of our contract with you.
• Create an account: To create an account, we collect your identifiers (name, company name, email address, physical address) and your selected username and password. We use this personal information to create and manage your account and to provide you with access to certain features of our Website. The legal basis for this processing is performance of our contract with you.
• Make a purchase: When you make a purchase, we collect your identifiers (name, email address, physical address) and your payment information (payment card number, expiration date, CVV). We use this personal information to process your payment and fulfill and manage your purchase. The legal basis for this processing is performance of our contract with you.
• Register your warranty: To register your warranty, we collect your identifiers (name, company name, email address, physical address) and your commercial information (product purchased, serial number). The legal basis for this processing is performance of our contract with you.
• Schedule an inspection: To schedule a LOLER, we collect your identifiers (name, company name, email address, telephone number). We use this personal information to manage your inspection and communicate with you. processing is performance of our contract with you.
• Submit a labor rate declaration: To submit a labor rate declaration, we collect your identifiers (name, email address) and your labor rate. We use this personal information to assess and issue labor reimbursements. The legal basis for this processing is performance of our contract with you.
• Submit a warranty claim: To submit a warranty claim, we collect your identifiers (name, company name, email address, physical address) and your commercial information (product purchased, serial number, parts information). We use this personal information to manage and assess your claim and to communicate with you. The legal basis for this processing is performance of our contract with you.
• Subscribe to our newsletter: When you subscribe to the Snorkel newsletter, we collect your identifiers (name, email address). We use this personal information to fulfill your request to receive Snorkel news, events, and product updates. The legal basis for this processing is your consent.
• Use Snorkel equipment: Snorkel equipment is equipped with a GPS device that allows Snorkel to obtain the geolocation of equipment. If you purchase equipment from Snorkel, the GPS device will collect geolocation, location/route, speed, distance, altitude, stop and start time, and operating status. Depending on the type of equipment, the GPS device will also collect information on the equipment, such as battery voltage, coolant level and temperature, oil pressure, and fuel level and rate. Snorkel uses this information to improve Snorkel equipment and user experience and to provide support and maintenance. This information is collected and maintained by our service provider that provides and manages the GPS device for us and is stored for a period of two (2) years and archived thereafter in a de-identified manner. The legal basis for this processing is your consent.
• Visit Snorkel: If you visit Snorkel, your visual information will be captured by our CCTV footage. We use this personal information to ensure the safety and security of Snorkel, our personnel, and guests. The legal basis for this processing is our legitimate interest in the protection of the rights of Snorkel and others.

In our processing of your personal information, we may also use your personal information to comply with the law and for other limited circumstances as described in HOW WE SHARE YOUR INFORMATION.

B. Information Collected From Third Party Sources

If you elect to finance your purchase, we will receive your identifiers (name) and commercial information (product purchased and amount) from the financing company. We use this personal information to issue invoices and obtain payment. The legal basis for this processing is performance of our contract.

C. Information Collected Automatically

In addition to the personal information you provide directly to us, we may also collect information from you automatically as you use our Website. This includes the following internet or other electronic network activity information:

• Usage information: Information about your interaction with the Website, such as pages visited, frequency of access, time spent on each page, and referring website details.
• Location information: Information about your location, which may be determined by your IP address.
• Device information: Information about the device you are using, such as hardware model, operating system, browser, and your preferences.

To collect this information, we use necessary, performance, and analytics cookies. We use the collected information to: (i) conduct analytics to improve the Website; (ii) enhance user experience; (iii) prevent fraudulent use of the Website; (iv) diagnose and repair errors, and in cases of abuse, track and mitigate the abuse; and (v) remember your preferences. Particular cookies to note on our Website include:

• Google Analytics: To conduct analytics, we use Google Analytics. Google Analytics may set cookies on your browser or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. The Google Analytics Terms of Use and Privacy Policy describe how Google may use and share the information collected by Google Analytics. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on.
• Hubspot: We use HubSpot to analyze the data traffic on our Website and your behavior while using our Website. We use this information to gain valuable insights into user behavior on our Website to improve our Website. For more information on Hubspot, please review its privacy policy.

To disable cookies and limit the collection and use of information through them generally, you can set your browser to refuse cookies or indicate when a cookie is being sent.

INFORMATION SHARING

Snorkel will share the personal information identified in this Privacy Policy in the following instances:

• Within Snorkel: We will share your personal information within Snorkel for legitimate business purposes, to efficiently carry out business, and to the extent permitted by law. The legal basis for this is our legitimate interest in carrying out our business operations efficiently.
• In the event of a corporate reorganization: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. The legal basis for this processing is our legitimate interest in carrying out our business operations.
• For legal purposes: We will share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of use or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law. The legal basis for this processing is compliance with a legal obligation applicable to us and our legitimate interest in compliance with other laws applicable to Snorkel.
• With service providers for a business purpose: In the preceding twelve (12) months, we have disclosed your personal identifiers, payment information, geolocation data, and internet and other electronic network activity information to our service providers that assist us in providing our Services. These service providers include our IT support, payment processor, shipping and delivery provider, GPS technology provider, and email vendor. The legal basis for this is our legitimate interest in providing the Services more efficiently.
• With IT for a business purpose: In the preceding twelve (12) months, we have disclosed your internet and other electronic network activity information to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, identify and repair Website errors, and to update, maintain, and improve the Website. The legal basis for this is our legitimate interest in improving and maintaining the Website.
• For a sale: We do not share your personal information for money, however, we do share personal information with certain third parties, which may be considered a “sale” under the California Consumer Privacy Act. In the preceding twelve (12) months, we have shared your internet or other electronic network activity collected via cookies to data analytics providers.

RIGHTS OF CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) grants certain rights to California residents. If our processing of your personal information is subject to the CCPA, you are entitled to the following rights:

• Right to access: You have the right to request what personal information we have collected, used, disclosed, and sold about you within the preceding 12 months. You may only make a request for access twice within a 12-month period.
• Right to deletion: You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions.
• Right to opt-out: You have the right to opt-out of the sale of your personal information to third parties. Snorkel does not have actual knowledge that it sells personal information of minors under the age of 16 years.
• Right to Correct Inaccurate Personal Information. You have the right to request we correct your inaccurate Personal Information, subject to certain exceptions.
• Right to non-discrimination: You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.

To exercise your right to access, delete, or correct your personal information, you may submit a request at +1 (702) 727-4929 or through our interactive webform. To opt-out of the sale of your personal information via cookies, please see Information Collected By Cookies above. For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. The interactive webform contains the information we require to process your request. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

RIGHTS OF INDIVIDUALS IN THE EUROPEAN UNION

Individuals in the European Union (EU) and the United Kingdom are entitled to certain rights under the General Data Protection Regulation (GDPR) or the UK Data Protection Act (DPA 2018). If our processing of your personal information is subject to these laws, you are entitled to the following rights:

• Right to access: You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the personal information we process.
• Right to rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
• Right to restrict processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Right to object to processing: You have the right to object at any time, for reasons arising from your particular situation, to processing of your personal information, which is carried out on the basis of our legitimate interests.
• Right to data portability: This only applies to personal information you have given us. You have the right to ask that we transfer the personal information you gave us from one organization to another or give it to you.
• Right to lodge a complaint: You have the right to lodge a complaint with the relevant supervisory authority.

To exercise these rights, please contact us at optout@snorkelifts.com.

RIGHTS OF NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at optout@snorkellifts.com. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

CORRECT OR VIEW YOUR PERSONAL INFORMATION

You can access your Snorkel account to correct or view certain personal information of yours in our possession and which is associated with your account.

MARKETING COMMUNICATIONS

You may opt-out of receiving marketing emails from us by clicking the “unsubscribe” link provided with each email. Please note that we will continue to send you emails necessary to the Services, your purchase, or any assistance you request.

RETENTION OF PERSONAL INFORMATION

We will retain your personal information until the earlier of: (i) the personal information is no longer necessary to accomplish the purpose for which it was provided; or (ii) we delete your information pursuant to your request. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. This includes for security, fraud, and abuse prevention, for financial record-keeping, or to comply with legal or regulatory requirements. Please see company Document Retention Policy for further specifics.

DO NOT TRACK

We do not support Do Not Track (DNT).

INFORMATION SECURITY

We implement and maintain reasonable security measures, including access controls and encryption, to protect the information we collect and maintain. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.

AGE RESTRICTION

The Services are not intended for individuals under the age of eighteen (18).

CHANGES

We may amend this Privacy Policy. We will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on our Website and obtain your consent, if required.

CONTACT US

If you have any questions regarding this Privacy Policy, please contact us at +44 (0) 191 461 6829 or legal@ahern.com.