Privacy Policy

SNOMAD SKI LTD Privacy Notice

SNOMAD SKI LTD ("we") are committed to protecting and respecting your privacy.

This notice (together with our terms of use and any other documents referred to in this notice) sets out the basis on which any personal data we collect from you, that you provide to us, or that we obtain about you from other sources, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website you agree to the matters set out in this notice – if you do not wish to agree to them, please do not visit the site.

SNOMAD SKI LTD (registered in England and Wales under number 15276260 with registered address at 12 Erncroft Way, Twickenham, United Kingdom, TW1 1DA)

For the purpose of the Data Protection Act 2018 and thereafter and the General Data Protection Regulation (Regulation (EU) 2016/679) as amended or replaced from time to time (“Data Protection Law”) Snomad Ski Ltd is the data controller According to Data Protection Law an individual may exercise his or her rights against the data controllers. You should contact Daniel Lever, MD, at the above address or by email at hello@snomad.ski in the event that you have any issues related to data protection or this notice. Where we are processing data on behalf of a customer of ours, we will be doing so as a “processor” for the purposes of Data Protection Law, and the customer will be the “controller”.

Information we collect from you

• Information you give us
  • This is information about you that you give us by filling in forms on our websites, applications or other media ("our sites") or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our sites, enter a competition, promotion or survey and when you report a problem with our sites or services. The information you give us may include your name, email address, as necessary for us to do what we need to do.
• Information we collect about you
  • We use our website and communications to facilitate the provision of information about us or our customers to you. With regard to each of your visits to our sites and any correspondence that may flow between us (including emails), we may automatically collect the following information: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information for using the site/application, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and information about your visit, including the full Uniform Resource Locators (URL) clickstreamed to, through and from the site/application (including date and time); page response times, download errors, timing of your responses, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Cookies and Tracking

• Our website uses cookies for the purposes of site/application functionality. Cookies are very small text files that are stored on your computer when you visit some sites or use some applications. They are used by most websites to tailor information and marketing messages to better suit your needs, as well as to store login or personal information for your convenience. Most web browsers allow some control over most cookies through the browser settings. For detailed information on cookies, and how to manage them, we suggest that you visit allaboutcookies.org.
• Types of cookies used on our site:
  • Analytics & Tracking - We use these to understand how the site/application is being used in order to improve the user experience. User data is anonymous.
  • Remarketing - We use these cookies to show relevant adverts to users who have previously visited our site/application, as they browse other websites. We also use these cookies to generate profile information in order to allow us to market to people with similar profiles. Remarketing services we use include both Google and Meta. To opt-out from Google’s remarketing program, please edit your Google Ad Settings.
  • Note that we do not use cookies to collect Personal Data unless you have opted in to receive more personalised marketing from us. The information that we do collect may be aggregated and passed to our marketing and other partners.
• Web beacons, such as pixels, may be included in our emails and sites. Web beacons may be used to track users’ activity in relation to our emails and sites.

Purposes for which we may process the information

• Information you give to us. We will use this information:
  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services, or those of our customers, that you request from us;
  • helping to manage our site;
  • market research, where you have

specifically opted in to join the Snomad newsletter, we may contact you about opportunities to take part in research and submit resort reviews via email;

• to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about with us;
• to notify you about changes to our sites or services;
• to ensure that content from our sites is presented in the most effective manner for you and for your computer.
• Information we collect about you We will use this information:
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our site or service, when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
  • to include non identifiable data in compiled data summaries and the published public reporting of aggregated data and statistical analysis of trends;
  • to include non identifiable data in published market research and PR, examining skier trends.
• Information we receive from other sources We may combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out in sections above.

Disclosure of your information

• You agree that we have the right to share your personal information:
  • With any other member of Snomad Ski Ltd, provided that:
    • they are joint controllers for the purposes of Data Protection Law or are processing the data purely for administrative purposes; and
    • they are either (i) within the European Economic Area, or (ii) are in a country that the European Union has decided has adequate data protection laws in place, or (iii) have provided appropriate data protection safeguards of the sort approved by the European Union and provide effective rights and remedies for you.
  • Selected third parties where reasonably necessary for the purpose of carrying out our business, including:
    • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisements on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;
    • analytics and search engine providers that assist us in the improvement and optimisation of our sites;
    • Email newsletter providers that assist us in providing content to our users that you have subscribed to receive

Legal basis of processing

• Data Protection law requires us to meet at least one “legal ground” for processing, currently set out in Article 6 of the General Data Protection Regulation. The grounds applicable to the personal data to which this notice relates are as follows.
  • Where the processing is necessary for us to perform a contract that you are party to, or to take steps at your request prior to entering a contract, including providing you with information at your request, that is the ground on which we are processing that data;
  • Where the processing is necessary for compliance with a legal obligation to which we are subject, that is the ground on which we are processing that data;
  • Where processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, that is the ground on which we are processing that data, provided that your fundamental rights and freedoms which require protection of your data override those legitimate interests (our legitimate interests comprise the management, marketing and promotion of our business and services);
  • If you have given your consent to our processing the data, that is the basis on which we are processing that data.

Where we store your personal data

• The data that we collect from you will be stored on our servers or those of our service providers. It will not be transferred to, and stored at, a destination outside the European Economic Area ("EEA") unless to a member of Snomad Ski Ltd or to a processor acting on our behalf which complies with EU data protection laws.

Length of data storage

• Our policy is to ensure that personal data is only stored for as long as is necessary for the purposes set out above. This may vary according to the type of information and the specific applicable purpose(s). In general, however, we keep personal data for up to 24 months after its

collection.

Your rights

• You have various rights under Data Protection Law, including the right to access the data we hold about you, the right to rectify inaccurate data, the right to delete your data, the right to restrict our processing of your data, and the right to object to our processing of your data.

Accessing your data

• You have the right to obtain from us confirmation as to whether we are processing personal data about you, and if so, you are entitled to be provided with the information outlined above.

Other websites

• Our sites may contain links to other websites. We do not accept any responsibility or liability for these websites' privacy policies. Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

• Any changes to our privacy policy will be posted on this page and, where appropriate, notified to you by email.

Contact

• Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to hello@snomad.ski.

AI Skier Generator

Information Collection Specific to AI Skier Generator:

In addition to the information outlined in our general privacy notice, users of the AI Skier Generator feature on the SNOMAD website will provide specific data to create personalized skier images. This includes:

• Uploaded photos for transformation into a professional skier image.
• Preferences related to the type of skier transformation desired, including hair color, skin complexion, skiing/snowboarding experience, skill level, gender, and age.

Use of Information for AI Skier Generator:

The additional information and photos provided for the AI Skier Generator are used exclusively to:

• Analyze and transform your photo into a skier image resembling you for entertainment purposes.
• Temporarily store the uploaded and generated photos to facilitate ongoing functionality of the AI Skier Generator, such as generating new images or re-accessing recent transformations.

Storage and Deletion of Photos:

• Photos uploaded to the AI Skier Generator, along with the generated skier images, are stored securely on our servers and are deleted within 30 days to ensure privacy and data minimization.

Data Sharing and Third-Party Disclosure:

• We do not share the specific data collected through the AI Skier Generator with third parties unless users have explicitly opted in to such sharing. This opt-in process is made clear on any sign-up forms or within the app interface.
• Data collected through the AI Skier Generator is processed and stored with the same high level of security and compliance with GDPR and other relevant data protection laws, as with all other user data collected by SNOMAD SKI LTD.

User Rights and Data Management:

• Users can request the deletion of their data, including uploaded photos and generated images, at any time by contacting hello@snomad.ski.
• As with all data collected by SNOMAD SKI LTD, users have the right to access, rectify, or object to the use of their data as detailed in our privacy notice.

Security Measures:

• We employ robust security measures to protect data collected through the AI Skier Generator, ensuring the confidentiality, integrity, and availability of user data.

Accuracy and Liability Disclaimer:

• While we strive to use AI to create skier images that closely resemble users, we cannot guarantee the accuracy of the image outcomes, matching complexions, hairstyles, or other specific features, as AI technology is still in its relative infancy. SNOMAD Ski Ltd cannot be held liable for any images that do not match the user's likeness exactly, and the use of the AI Skier Generator is at your own risk.

Contact for AI Skier Generator Queries:

• Users with questions or concerns about the AI Skier Generator and their data can contact Dan Lever at hello@snomad.ski for assistance and information regarding their privacy and data protection.