Made by Sober Bar
Last updated February 04, 2025
This Privacy Policy explains how personal information is collected, used, stored, disclosed, and otherwise processed in connection with the Snusless mobile application, website, and related services (collectively, the “Services”).
The Services are owned by Jonne, a private individual established in Finland (the “Controller”).
The Controller determines the purposes and essential means of processing personal data relating to the Services.
Studio A55 Oy, a Finnish limited liability company (the “Operator”), operates, publishes, maintains, markets, and administers the Services on behalf of the Controller under a separate licence, administration, and data-processing arrangement.
For the processing described in this Privacy Policy, references to “we,” “us,” and “our” mean the Controller unless expressly stated otherwise.
The Operator does not acquire independent ownership, sale rights, or independent commercial usage rights in the Snusless customer register or personal data merely because it hosts, stores, accesses, administers, or otherwise processes that data on behalf of the Controller.
If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact:
Controller: Jonne Country: Finland Email: support@snusless.com
For purposes of the EU General Data Protection Regulation (“GDPR”), the UK GDPR where applicable, and other data protection laws using comparable concepts:
Jonne is the data controller for the personal data processed in connection with the Snusless Services, except where another party is expressly identified as an independent controller for a particular processing activity.
The Controller determines, among other things:
Studio A55 Oy assists in operating the Services.
Depending on the activity, the Operator may perform tasks including:
When carrying out these activities on behalf of the Controller, the Operator acts as a processor and processes personal data only for the purposes and according to the instructions determined by the Controller.
The fact that a server, database, developer account, hosting account, support account, or other technical resource is registered to or administered by the Operator does not by itself change the Controller's role in relation to the Snusless customer register.
The Operator may separately act as an independent controller where it is legally required to process limited information for its own statutory purposes, such as accounting, taxation, fraud prevention, establishment or defence of legal claims, or compliance with legal obligations applicable directly to the Operator. Such processing is separate from the Operator's processing of the Snusless customer register on behalf of the Controller.
This Privacy Policy applies when you:
This Privacy Policy does not govern the independent processing activities of third parties, such as Apple, Google, payment providers, or other services that process personal data for their own purposes under their own privacy policies.
The personal data we collect depends on which features you use.
We may process:
We do not require you to provide more information than is reasonably necessary for the relevant functionality.
Snusless is designed to help users monitor, understand, manage, and potentially reduce their nicotine use.
If you choose to use these features, we may process information such as:
Depending on applicable law and the context in which it is used, this information may constitute health data, consumer health data, sensitive personal data, or another specially protected category of personal information.
We therefore apply enhanced safeguards to this information.
We do not use your nicotine-use or health-related information for third-party advertising.
We do not sell your nicotine-use or health-related information to data brokers or advertisers.
When you use the Services, certain technical information may be collected automatically, including:
We use this information primarily to operate, secure, troubleshoot, and improve the Services.
We do not intentionally collect precise location information unless a feature clearly requests it and you affirmatively enable that feature.
We may process information about how the Services are used, such as:
Where applicable law requires consent for non-essential analytics technologies, those technologies will only be used after the required consent has been obtained.
We seek to avoid sending identifiable nicotine-use or health information to general-purpose advertising or analytics providers.
If you contact us, we may process:
Please avoid including unnecessary health or other sensitive information in customer-support messages.
Subscriptions may be processed through Apple or another authorised payment platform.
We may receive limited transaction-related information such as:
We generally do not receive your full payment-card information when payments are processed by an app store or external payment provider.
The relevant payment platform may independently process payment information under its own privacy policy.
Where the Services offer a third-party sign-in method, we may receive limited information from that provider that is necessary to create or authenticate your Snusless account.
The specific information depends on the authentication provider and the permissions you choose to provide.
The third-party provider independently processes information under its own privacy terms.
Where Snusless uses Google APIs, information received through those APIs will be used in accordance with the applicable Google API Services User Data Policy, including applicable Limited Use requirements.
We only request access to Google information necessary for the specific Snusless feature you choose to use.
We may obtain personal data:
We do not purchase health-related information about users from data brokers.
We process personal data only for identified and legitimate purposes.
We use personal data to:
Information you enter may be used to provide personalised statistics, reminders, progress indicators, goals, and insights within Snusless.
Health-related information is used for the user-facing functionality of Snusless and not for unrelated advertising purposes.
We may use account, device, log, and technical information to:
We may analyse technical and usage information to:
Where reasonably possible, we use aggregated or de-identified information for these purposes.
We may use your contact information to:
You can opt out of optional marketing communications at any time.
We may process information where necessary to:
If the GDPR applies to you, we rely on one or more of the following legal bases.
We process personal data where necessary to provide the Services you request or to take steps at your request before entering into a contractual relationship.
This may include account administration, authentication, subscription functionality, customer support, and delivery of core application features.
GDPR Article 6(1)(b).
We rely on consent where you voluntarily enable optional processing and consent is the appropriate legal basis.
This may include certain:
GDPR Article 6(1)(a).
You may withdraw consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.
Nicotine-use information may reveal information concerning your health.
Where such information constitutes special-category personal data under the GDPR, we process it on the basis of your explicit consent, unless another lawful exception under Article 9 of the GDPR clearly applies.
The relevant legal bases are generally:
GDPR Article 6(1)(a) and Article 9(2)(a).
You can withdraw your consent to the processing of this information.
If processing particular nicotine-use information is necessary for a feature that you request, withdrawing consent may mean that we can no longer provide that feature and may require deletion of the relevant information, subject to legal retention requirements.
We may rely on legitimate interests for limited processing necessary to:
GDPR Article 6(1)(f).
We do not rely on legitimate interests as the Article 9 basis for processing health data.
We may process information where necessary to comply with a legal obligation.
GDPR Article 6(1)(c).
Because nicotine-use information may receive heightened protection under privacy laws, the Services may request a separate consent before you begin storing or otherwise processing such information.
Where explicit consent is required, the request for consent will be distinguishable from general acceptance of the Terms of Service.
You may withdraw this consent through the functionality provided in the Services or by contacting support@snusless.com.
Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.
Where required by law, we will stop the relevant processing and delete or anonymise affected information unless another legal basis requires or permits limited continued retention.
Snusless may automatically calculate statistics, trends, progress, goals, streaks, reminders, or similar insights based on information you provide.
These functions are intended to help you understand your own use patterns.
Snusless does not use your health-related information to make automated decisions that produce legal effects concerning you or similarly significantly affect you, such as decisions about employment, credit, insurance, healthcare eligibility, or access to essential services.
We do not sell personal data to advertisers or data brokers.
We may disclose personal data only where reasonably necessary for the purposes described in this Privacy Policy.
The Controller may provide personal data to Studio A55 Oy so that it can operate and administer Snusless on the Controller's behalf.
For such processing, the Operator acts under the Controller's instructions and may not independently monetise, sell, repurpose, or use the Snusless customer register for unrelated purposes.
We may use service providers for functions including:
These providers may access personal data only to the extent necessary for their respective functions and subject to appropriate contractual and legal safeguards.
A current list of material processors or subprocessors may be made available at [SUBPROCESSOR URL] or upon request at support@snusless.com.
If you download Snusless or purchase a subscription through Apple or another app-distribution platform, that platform may independently process information relating to your account, device, download, purchase, and payment.
Those activities are governed by the platform's own privacy policy.
We may disclose information where we reasonably believe disclosure is necessary to:
For clarity regarding the administration of the Services:
The Controller, Jonne, determines the purposes and essential means of processing the personal data contained in the Snusless customer register.
The Operator administers and processes that register on behalf of the Controller.
The Operator's technical possession of, access to, storage of, or administration of a database does not give the Operator an independent right to:
Nothing in this section limits the legal rights that individuals have in relation to their own personal data.
Personal data is not treated as property free from data-protection obligations. Any processing, disclosure, or transfer remains subject to applicable privacy law.
The Controller may in the future sell, assign, licence, or otherwise transfer the Snusless application, its intellectual property, related business assets, or associated customer relationships to another person or organisation.
If such a transaction occurs, personal data associated with the Services may be transferred to the purchaser or successor only to the extent permitted by applicable law.
In connection with such a transaction:
The Operator may provide technical assistance with such a transfer on the Controller's instructions but has no independent right to sell or dispose of the Snusless customer register merely because it operates the application.
Following a completed transfer, the purchaser may become the new controller for transferred personal data. The purchaser's privacy policy will then govern its subsequent processing, subject to applicable law.
The Controller is established in Finland.
However, some service providers used by Snusless may process information outside Finland or outside the European Economic Area (“EEA”), including potentially in the United States.
Where GDPR-protected personal data is transferred outside the EEA, we use a legally recognised transfer mechanism where required, such as:
Where appropriate, we also assess whether supplementary technical, contractual, or organisational safeguards are necessary.
You may contact support@snusless.com for additional information about the safeguards relevant to your personal data.
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, subject to applicable legal obligations.
Retention periods may vary depending on the type of information.
Account information is generally retained while your account remains active.
After account deletion, we delete or anonymise account information within a reasonable period unless continued retention is required for legal, security, fraud-prevention, dispute-resolution, backup, or compliance purposes.
Health-related tracking information is retained while needed to provide the relevant Snusless functionality or until you delete it or withdraw the relevant consent, subject to lawful exceptions.
Where technically feasible, deleted active data may remain temporarily in secure backup systems until the relevant backup cycle expires.
Backup copies are not used for ordinary active processing.
Support communications may be retained for a reasonable period to resolve issues, maintain records of requests, protect legal rights, and improve support quality.
Information required for accounting, tax, legal, or regulatory purposes may be retained for the period required by applicable law.
We use technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.
Depending on the relevant system, safeguards may include:
No internet-connected system can be guaranteed to be completely secure.
If we become aware of a personal-data breach, we will assess and handle it in accordance with applicable law, including notifying supervisory authorities or affected individuals where legally required.
Snusless is intended for adults.
We do not knowingly permit persons under the age of 18 to create an account or provide nicotine-use information through the Services.
If we learn that we have collected personal data from a person under 18 in violation of this policy, we will take reasonable steps to delete the information.
If you believe a minor has provided personal data to Snusless, contact support@snusless.com.
If the GDPR applies to you, you may have the right to:
These rights are subject to conditions and exceptions provided by applicable law.
You can submit a request:
Email: support@snusless.com Support page: https://snusless.com/en/support
We may request information reasonably necessary to verify your identity before completing a request.
We will not request more information than reasonably necessary for verification.
Because the Controller is established in Finland, you may contact the Finnish Data Protection Ombudsman if you believe that your personal data has been processed unlawfully.
You may also have the right to complain to the data-protection authority in your country of residence, workplace, or the place of the alleged infringement.
Where available, you may delete your account or certain information directly through the application.
You may also request deletion by contacting support@snusless.com.
Subject to applicable law, deletion of your account generally results in deletion or anonymisation of personal data that is no longer required for a lawful purpose.
You may request a copy or export of eligible personal data by contacting us.
Certain information may be retained where necessary to:
We may send marketing communications where you have consented or where another applicable legal basis permits us to do so.
You can unsubscribe from marketing communications at any time using the unsubscribe mechanism provided or by contacting us.
Service-related communications, such as security notices or important account information, are not marketing and may still be sent where necessary.
If you enable push notifications, Snusless may send reminders and service-related notifications.
You can disable push notifications through your device settings.
The content of notifications is designed to avoid unnecessarily exposing sensitive information on a locked device where reasonably possible.
The Snusless website or application may use cookies, local storage, SDKs, or similar technologies where necessary to provide functionality, maintain security, remember settings, or perform analytics.
Where applicable law requires consent for non-essential technologies, those technologies will not be activated until the required consent has been obtained.
We do not use nicotine-use or health-related information for cross-context behavioural advertising.
If you reside in a U.S. state with an applicable comprehensive privacy law, you may have rights concerning your personal information, depending on the law and whether it applies to the Controller.
These may include rights to:
Snusless does not sell personal data to data brokers or advertisers.
We do not use nicotine-use information for targeted advertising.
Requests can be submitted to support@snusless.com.
Where applicable law permits an authorised agent to submit a request, we may require evidence that the agent is authorised to act for you.
We may also verify your identity before fulfilling a request.
This section applies where a U.S. consumer-health privacy law, including the Washington My Health My Data Act or a similar applicable law, governs our processing.
Depending on your use of Snusless, we may process:
We obtain consumer health data primarily:
We do not purchase consumer health data from data brokers.
We use this information to:
We do not use consumer health data for third-party advertising.
We may provide consumer health data to processors only to the extent necessary to operate the Services.
Depending on the infrastructure used, those processors may include providers of:
Processors may not use consumer health data for their own independent purposes except where expressly permitted by applicable law.
The principal operational processor is:
Studio A55 Oy, Finland.
A current list of other material service providers that may process consumer health data is available by contacting support@snusless.com.
We do not sell consumer health data to advertisers, data brokers, or other third parties for their independent commercial use.
If a transfer associated with a future sale or transfer of Snusless is legally treated as a “sale” of consumer health data under an applicable consumer-health privacy law, we will obtain any separate authorisation required by that law before carrying out the transfer.
Depending on applicable law, you may have rights to:
Submit requests to support@snusless.com.
Where California or another state privacy law applies, the categories of personal information processed by Snusless may include:
Identifiers: such as name, email address, account identifier, IP address, or device identifiers.
Customer-record information: such as account and contact information.
Commercial information: such as subscription status and transaction identifiers.
Internet or electronic activity: such as application interactions, logs, and technical events.
Sensitive or health-related information: such as nicotine-use information you voluntarily enter into Snusless.
Inferences: such as trends, progress indicators, or statistics generated from information you provide.
We collect and use these categories for the purposes described in this Privacy Policy.
We do not sell personal information to data brokers or advertisers.
We do not use sensitive nicotine-use information for targeted advertising.
Where applicable law gives you additional rights, you may exercise them by contacting support@snusless.com.
Some browsers and devices offer Do-Not-Track or other privacy preference signals.
Because technical and legal requirements differ by jurisdiction and signal type, we respond to legally recognised opt-out preference signals where applicable law requires us to do so.
A traditional browser “Do Not Track” signal may not by itself trigger a particular action where no applicable technical or legal standard requires recognition of that signal.
The Services may contain links to or integrations with third-party services.
We are not responsible for the independent privacy practices of those third parties.
Before providing personal information directly to a third party, you should review that party's privacy policy.
We may update this Privacy Policy from time to time.
When we make changes, we will update the “Last updated” date at the top of the policy.
If a change materially affects how we process sensitive information or otherwise requires notice or consent under applicable law, we will provide the required notice and obtain consent where legally necessary before beginning the new processing.
We encourage you to review this Privacy Policy periodically.
The controller responsible for the Snusless customer register is:
Jonne Private individual Finland Email: support@snusless.com
Operational processor:
Studio A55 Oy Business ID: 3464860-6 Registered office: Helsinki, Finland
The Operator administers the Services on behalf of the Controller and does not independently control the Snusless customer register except for any limited processing it must perform as an independent controller to satisfy its own statutory obligations.
Privacy requests should be directed to:
or:
https://snusless.com/en/support
The Snusless application, its intellectual property, brand, software, and associated business rights may be owned and transferred separately from the Operator that provides day-to-day administration.
For purposes of the Snusless customer relationship, Jonne acts as Controller, while Studio A55 Oy acts as the operational processor, except for the Operator's limited independent legal obligations described above.
This allocation of roles does not reduce or transfer any privacy rights belonging to individual users.
Any future transfer of Snusless or its customer relationships will continue to be subject to all applicable data-protection, consumer-health, transparency, consent, and security requirements.