PRIVACY POLICY

1         Purpose

Under applicable data protection laws, including the general data protection regulation (EU) 2016/679(”GDPR”)¹ and the Act (2018:218) with supplementary provisions to the EU’s data protection regulation², NoseOption AB (556861-2294), Observatoriegatan 5, 113 29 Stockholm, Sweden (”NOSA”, “we”, “us”), is the data controller for its processing of your Personal Data in connection to your use of its products and services.

NOSA is fully committed to protecting your individual rights and keeping your Personal Data safe. This Privacy Policy is meant to help you understand what information we collect about you, why we collect it, our storing and sharing practices, and what your privacy rights are.

2        Scope

NOSA protects the privacy of customers and partners and is always careful to comply with applicable data protection regulations.
NOSA has adopted this Policy to inform you of its processing of your Personal Data.

In this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable natural person.

3        Personal Data collection

3.1        Information provided by you

We collect information you provide directly to us.

For example, when you

become a new customer, we may collect Personal Data such as name, e-mail address and phone number. We may also collect payment details to be able to provide you with the product or service requested. NOSA may also collect information which you provide to us, such as messages you have sent as feedback or a request in our digital channels.

You provide us with information when you:

• shop for products in our webshop;
• add or remove an item from your cart, or place an order through or use our webshop;
• use our mobile application for smell training;
• communicate with us by phone, email, or otherwise;
• complete a questionnaire or provide and rate reviews; or
• complete a form to order samples or other goods.

As a result of those actions, you might supply us with such information as:

• identifying information such as your name, address, and phone numbers;
• payment information;
• your age;
• information about your well-being and health;
• your professional title, workplace and department;
• your location information;
• your IP address;
• content of reviews and emails to us; and
• corporate and financial information.

3.2       Information collected via automated means

• In addition, we may process information collected via automated means.
• Examples of the information we collect and analyze include:
• the internet protocol (IP) address used to connect your computer to the internet;
• email address;
• the location of your device or computer for language selection at the website;
• phone numbers used to call our customer service number; or
• cookies (for further information, please see our Cookie Policy https://nosaplugs.com/policies/

3.3       Information collected from other sources

To be able to offer you our products and services and to comply with statutory requirements, we will also collect Personal Data from third parties, such as publicly available and other external sources.

Examples of information we receive from other sources include:

• updated delivery and address information from our carriers or other third parties, which we use to correct our records and deliver your next purchase or communication more easily;
• information about your interactions with products and services offered by our distributors; and
• publicly available data, for example from social media or via search engines. Social media may also share data with us in accordance with your personalized privacy settings in those channels/media.

4       How will we use your Personal Data?

We use your Personal Data to operate, provide, develop, and improve the products and services that we offer our customers. These purposes include:

Purchase and delivery of products and services. We use your personal information to confirm and handle orders, deliver products, process payments, and communicate with you about orders, products, and promotional offers.

Provide, troubleshoot, and improve NOSA services. We use your personal information to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of NOSA’s services, such as our mobile application.

Recommendations and personalization. We use your personal information to recommend products that might be of interest to you.

Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws. For instance, we collect information from sellers regarding place of establishment and bank account information for identity verification and other purposes.

Communicate with you. We use your personal information to communicate with you in relation to NOSA via different channels (e.g., by phone, email).

Advertising. We use your personal information to display interest-based ads for features, products, and services that might be of interest to you.

5       Legal Basis for the processing of Personal Data

If you are located in the EU/EEA, we only process your Personal Data based on a valid legal basis, including:

Your consent. You have consented to the Personal Data being processed for one or more specific purposes.

Fulfillment of an agreement. The processing is necessary to fulfill an agreement to which the data subject is a party or to take measures at the request of the data subject before entering into such an agreement.

Legal obligation. The processing is necessary to fulfill a legal obligation incumbent on NOSA. Examples include control data submitted to the Swedish Tax Agency.

Legitimate interest. The processing is necessary for purposes relating to NOSA’s or third party’s interests, unless the data subject’s interests or fundamental rights and freedoms outweigh and require the protection of Personal Data.

5.1        Processing of special categories of Personal Data

If you use our mobile application for smell training, we will process data about your well-being and health. These types of data are considered special categories of personal data. We only process these types of personal data based on your consent. You have the right to withdraw your consent at any time by contacting us.

6       Marketing

NOSA would like to send you information about products and services of ours that we think you might like and where you might find them, e.g., information about our distributors.

If you have agreed to receive marketing, you may always opt out later.

You have the right at any time to stop NOSA from contacting you for marketing purposes or giving your data to other members within NOSA.

6.1        Deregistration from receiving marketing information

If you no longer wish to receive marketing information such as newsletters, product information and updates in the IP area from NOSA, you can contact us at grdp@nosamed.com and / or unsubscribe from our newsletters via the “unsubscribe link” or “unsubscribe” that you find in our emails.

7        Data Transfers

7.1        Data transfers to third parties

We may share your Personal Data with third parties in certain cases. These include:

Service providers. We work with third party service providers to operate our site and mobile application. As part of their provision of services to us, our service providers may access some of your Personal Data. We conclude appropriate agreements with all of our service providers to ensure that your Personal Data is secure.

Legal requirements. We may disclose your Personal Data if required to do so by law or regulations.

7.2       Data transfers to third countries

We may transfer your Personal Data to countries outside of the EU/EEA, including to the U.S. or any other country in which we or our service providers maintain facilities. We ensure that such transfers are governed by appropriate mechanisms to ensure the safety and security of your Personal Data, including by transferring your Personal Data to countries for which adequacy decisions have been issued, using contractual protections for the transfer of Personal Data or to organizations which have implemented EU binding corporate rules, where applicable.

8       Security measures

NOSA processes your Personal Data in a way that ensures appropriate security for the Personal Data using technical and organizational measures. Organizational security measures include that access control is used for the systems that contain Personal Data, including logging of access to Personal Data. Examples of technical measures include ensuring that NOSA has sufficient back-up routines, sufficient firewalls, password-protected wireless networks, updated virus protection, password protection for mobile devices such as mobile phones and tablets, protection against unauthorized internal access, password requirements, encryption where necessary, access to and use of IT systems, etc.

9       Data Retention

In accordance with its Data Retention schedule, NOSA only stores your Personal Data as long as necessary for the purposes of the processing. Personal Data no longer necessary for the purposes of the processing is either anonymized or deleted.

10     Your data protection rights

NOSA would like to make sure you are fully aware of all of your data protection rights.

Under applicable data protection laws, you are entitled to the following:

The right to access – You have the right to request NOSA to provide copies of the Personal Data that we process about you. If you ask for several copies, we may charge you a small fee for this service.

The right to rectification – You have the right to request NOSA corrects any information you believe is incomplete or incorrect.

The right to erasure. You have the right to request that NOSA erases your Personal Data, under certain conditions.

The right to restrict processing. You have the right to request that NOSA restricts the processing of your Personal Data, under certain conditions.

The right to object to processing.You have the right to object to NOSA’s processing of your Personal Data, under certain conditions.

The right to data portability. You have the right to request that NOSA transfer the data that we have collected to another organization, or directly to you, under certain conditions.

The right to object to automated decision making. You have the right to object to automated decision making, including profiling.

The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint directly with a supervisory authority, for example with the Swedish supervisory authority Integritetsskyddsmyndigheten.

If you would like to exercise any of these rights, please contact us using our contact details below.

11      Contact details and changes

If you have any questions or would like to exercise any of your rights under data protection laws, please use the below contact details to contact us.

NoseOption AB

Email: gdpr@nosaplugs.com

Phone: +46 (0)771 112 000

Address: Surbrunnsgatan 42, 113 48 Stockholm, Sweden

We may update this Privacy Policy from time to time. The latest version is always available on our website, www.nosaplugs.com