Privacy Policy

Last updated: 4^th December 2023

SNA Europe is part of the Snap-on Incorporated group of companies. SNA Europe is referred to as “we”, “us” or “our” in this privacy policy. “Personal information” is information that identifies you as an individual or relates to you as an identifiable individual. The protection of your personal information is an important concern to which we pay special attention.

This privacy policy answers frequently asked questions about the kinds of personal information we collect from you or from third parties and how it is used, disclosed, shared, and retained.

This privacy policy does not apply to our employees or job applicants.

Should you have any questions or concerns regarding this privacy policy, please contact SNA Europe Data Protection Coordinator at [email protected]

Notice at Collection

1. What types of personal information do we gather?

Subject to applicable local laws, we may collect and process a range of personal information including the following:

Identifiers: Such as a real name, alias, postal address, telephone number, online identifier, internet protocol address that identifies you as an individual or relates to an identifiable individual, email address, account name, social security number, driver’s license number, passport number, other state or national identification number(s), your signature, physical characteristics or description, insurance policy number or other similar unique personal identifiers.

Commercial Information: Such as transaction and purchase information and history.

Financial Information: Such as your bank account number, credit card number, debit card number or any other financial information.
Technical and Usage Information: Such as login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and information on other technology on the devices using our websites or products; information about how you use our website, products and services, such as browsing history, search history, or other information on interactions with our websites, applications, products and services. For detailed information on the tracking technologies we use on this website, see Cookie Policy.

Educational or Professional/Employment-Related Information: Such as education or training history, work history and current and prior employers.

Sensory information: Such as audio, electronic, visual and similar information, such as call and video recordings.

California, Virginia, Colorado, Utah and Connecticut Residents:Protected Class Information: including classifications protected by law such as: If any of these items are collected they should be added specifically: sex, pregnancy, childbirth, breastfeeding, and related medical conditions, age, race, colour, religion, creed, philosophical beliefs, ancestry, national origin, disability, medical conditions, genetic information, AIDS/HIV status, marital status, sexual orientation or history, gender identity and expression, citizenship, primary language, immigration status, military/veteran status, political affiliation/activities, domestic violence victim status, request for leave, political opinions, trade union memberships, criminal offence data, and biometric information, such as fingerprints and voiceprints.

European Union or European Economic Area or UK Residents: Special categories of personal data: as defined under Article 9.1 of the General Data Protection Regulation (GDPR), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
We do not intend to collect personal information of Children: We do not knowingly collect personal information from children under 16. Our website is not intended for children under 16 years of age. If you are under 16, do not use or provide any information on this website or through any of its features. If you believe we might have any information from or about a child under 16, please contact us at [email protected].
California, Virginia, Colorado, Utah and Connecticut Residents: Sensitive Personal Information:
- Government issued identification numbers: Personal Information that reveals an individual’s social security, driver’s license, state identification card, or passport number
- Payment information: Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
- Precise/specific geolocation information
- Racial or ethnic origin, data revealing religious affiliation, philosophical beliefs, citizenship, immigration status, or union membership
- The contents of mail, email, and text messages unless Company is the intended recipient of the communication
- Genetic data
- Medical data: Personal Information collected and analysed concerning an individual’s health; Information on medical history, mental or physical health conditions, or medical treatment or diagnosis by a health care professional
- Biometric information used for the purpose of uniquely identifying an individual
- Personal Information collected and analysed concerning an individual’s sex life or sexual orientation.

2. How is that personal information used by us?

We use and disclose your personal information for the following purposes to the extent the use of your personal information is reasonably necessary and proportionate for these purposes:

Business Uses, such as:
- Register you as a new customer, supplier or distributor;
- Register you as a user in our products or services, and provide those services;
- Arrange and deliver trainings, events, travels and accommodation;
- Process and deliver your order, manage your subscriptions, or carry out our obligations arising from any other contracts you enter into with us;
- Manage payments, fees and charges and collect and recover money owed to us;
- Managing our relationship with you by sending you statements, notifying you of product or service information, asking you to leave a review or take a survey, or enabling you to partake in a prize draw or competition;
- Service and/or enforce contracts or other agreements you may have with us;
- Fulfil your requests, answer your questions, respond to your comments, and measure how effectively we address your concerns;
- Analyse and develop new products and services;
- Make suggestions and recommendations to you about goods and services that may be of interest to you;
- Provide customer support;
- Detect and prevent fraud; or
- Fulfil any legal obligations we may have.

We engage in these activities to manage our contractual relationship with you, based on our legitimate interest, or with your consent and/or to comply with a legal obligation.

Mobile Applications: to make available mobile applications and to enable registration on our mobile applications.

We engage in these activities based on our legitimate interest, to manage our contractual relationship with you or with your consent.

Website Experience: for the technical administration of the website; for internal operations; for customer administration; for product surveys; for troubleshooting; for information analysis, information analytics, testing, and research and development purposes; to ensure that content from our site is presented in the most effective manner for you and for your computer; and as part of our efforts to keep our site safe and secure.

We engage in these activities based on our legitimate interest or your consent, where required by applicable law.

Protecting our Rights and Property: to protect our rights or property or that of our business partners, suppliers, distributors, customers or others when we have reasonable grounds to believe that such rights or property have been or could be affected; to recover debts; to prevent, detect, identify, investigate, respond, and protect against potential or actual claims, liabilities and prohibited behaviour or activities.

We engage in these activities based on our legitimate interest.

Information for our Business Partners and Distributors: to administer and develop our business relationship with you, the business partner or distributors you represent, including sharing information with our group, to enter into or perform a transaction with you, to contact you as part of satisfaction surveys or for market research purposes.

We engage in these activities to manage our contractual relationship with you, based on our legitimate interest or with your consent.

Marketing: to communicate about, and administer participation in, including via our social media accounts, special events, programs, surveys, contests, sweepstakes, and other offers and promotions; to provide you with information about other goods and services we offer, or offered by others, that are similar to those that you have already purchased or enquired about and to send informational or promotional email messages to you, which you may opt out of receiving as described below.

We engage in these activities based on our legitimate interest or your consent, as required by applicable law.

European Union or European Economic Area or UK Residents: Special categories of personal data: We do not collect such Data from you.

3. Is my personal information transferred or provided to third parties?

We disclose your personal information in the following situations:

Other companies within the Snap-on Incorporated group (“Snap-on Group”): We are a global organization with affiliates, subsidiaries, business processes, management structures and technical systems that cross borders. As such, we will share the personal information we collect with companies within the Snap-on Incorporated group and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this privacy

Service Providers: We need to disclose your personal information to third parties who need this information to provide services to us. These can include providers of services such as website hosting, data analysis, payment processing, order fulfilment, return authorization, fraud prevention, translators, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.

Other Third Parties: We will also disclose your personal information to selected non-affiliated third parties, such as social media, credit reference agencies, debt collection agencies, professional service providers (including legal advisers and accountants) and other Third Parties in response to a legal obligation.

We also use and disclose your personal information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

To comply with applicable law and regulations.
- This may include laws outside your country of residence.
To cooperate with public and government authorities.
- To respond to a request or to provide information we believe is necessary or appropriate.
- These can include authorities outside your country of residence.
To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.

For other legal reasons.
- To enforce our terms and conditions; an
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

In connection with the establishment, exercise or defense of a legal claim.
- In such cases we may have to provide personal information to adverse parties who have a legal right to receive such information and their counsel and experts.
In connection with a sale or business transaction.
- Circumstances may arise where, whether for strategic or other business reasons, we decide to sell, buy, merge or otherwise reorganise our business. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is our practice to seek appropriate protection for information in these types of transactions.

4. How is each category of my personal information used, disclosed, or shared?

The following chart details which categories of personal information we may collect and process, what we use them for, as well as which categories of personal information we may disclose to third parties for our operational business purposes, including within the 12 months preceding the date this privacy policy was last updated.

Categories of personal information	Disclosed to Which Categories of Third Parties for Operational Business Purposes (as described in the “Is my personal information transferred or provided to third parties?” section)	Processing Purposes *(as described in the* “*How is that personal information used by us?” section)*

Identifiers	Other companies within the Snap-on Incorporated group (“Snap-on Group”), Service Providers, other Third Parties.	Business Uses, Mobile Applications, Website Experience, Protecting our Rights and Property, Information for our Business Partners, Product Development, Marketing,
Commercial Information	Other companies within the Snap-on Group, Service Providers, other Third Parties.	Business Uses, Mobile Applications, Website Experience, Protecting our Rights and Property, Information for our Business Partners, Product Development, Marketing,
Financial Information	Other companies within the Snap-on Group, Service Providers, other Third Parties.	Business Uses, Website Experience, Protecting our Rights and Property, Information for our Business Partners, , Product Development, Marketing
Technical and Usage Information	Other companies within the Snap-on Group, Service Providers, other Third Parties.	Business Uses, Mobile Applications, Website Experience, Protecting our Rights and Property, Information for our Business Partners, Product Development, Marketing,
Educational or Professional/Employment-Related Information	Other companies within the Snap-on Group, Service Providers, other Third Parties.	Business Uses, Mobile Application, Information for our Business Partners, Product Development, Marketing,
Sensory Information	Other companies within the Snap-on Group, Service Providers, other Third Parties.	Business Uses Protecting our Rights and Property,

5. How long will my personal information be kept for?

We will endeavour not to keep your personal information in a form that allows you to be identified for any longer than is reasonably necessary for achieving the permitted purposes. This means that information will be destroyed or erased from our systems or anonymized when it has reached the applicable retention period.

We retain each category of personal information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you or provide services to you, for example, for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; and
Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.

6. How do I update or access my personal information?

We ask that you keep your information as up-to-date as possible so you may get the maximum benefit from us.

If you have an account with us then you may be able to access and correct personal information that we keep in your online account by reviewing your account and entering your user ID and password. For other questions related to updating or changing your account information or if any errors in your personal information cannot be corrected by accessing your account, please send a request to SNA Europe Data Protection Coordinator at [email protected]. The Data Protection Coordinator will need information about the account you are attempting to correct.

7. What are my choices and rights in relation to my personal information?

If you would like to request to access, correct, update, suppress, restrict, or delete personal information, object to or opt out of the processing of personal information, or if you would like to request to receive a copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us by emailing SNA Europe Data Protection Coordinator at [email protected].

We will respond to your request consistent with applicable law.

European Union or European Economic Area or UK Residents:

You have the right to lodge a complaint with a data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of EU/EEA data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080. Details of the UK data protection authority can be found at https://ico.org.uk/. We have appointed a Data Protection Manager who is responsible for addressing any reported data protection issues related to GDPR, and we would like the opportunity to respond to your concerns before you approach a supervisory authority so please feel free to contact SNA Europe Data Protection Manager at [email protected]

California, Virginia, Colorado, Utah and Connecticut Residents:

You may, subject to applicable law, make the following requests:

To know whether we process your personal information, and to access such personal information. If you are a California resident, you may also request that we disclose to you the following information:
1. The categories of personal information we collected about you and the categories of sources from which we collected such personal information;
2. The business or commercial purpose for collecting personal information about you; and
3. The categories of personal information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such personal information.
To correct inaccuracies in your personal information.
To have your personal information deleted.
To receive the specific pieces of your personal information, including a copy of your personal information in a portable format.

You have the right not to be unlawfully discriminated against for exercising your privacy rights.

Exercising Access, Data Portability, and Deletion Rights. To exercise the rights described above, please submit a verifiable consumer request to us by either:
- Calling us toll-free at 844-972-1285; or
- Contacting our data protection manager at [email protected]

8. How will process your requests?

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. In some instances, we may decline to honour your request where the law or right you are invoking does not apply or where an exception applies. We may need to request – subject to applicable laws – your company name, business partner number, account number, name, telephone number, email address, financial details file, delivery address, and/or purchase, warranty, repair or calibration history, device serial number, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your personal information. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

9. How can you appeal our decision with regard to your request?

If you are Colorado, Connecticut or Virginia resident and if we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us via [email protected] or +(1) 844-972-1285.

10. How can my authorized agent make a request on my behalf?

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “What are my choices and rights in relation to my personal information?” Not all kinds of requests can be made by authorized agents in all states. As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “How will we process your requests?” or confirm that you provided the agent permission to submit the request.

If you are a California resident and an agent makes a request on your behalf, we may request a power of attorney provided to the agent by you pursuant to California Probate Code sections 4121‑4130. If you have not provided a power of attorney, we may require proof that you have provided signed permission authorizing the agent to make a request on your behalf. (“Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.) We may also require you to: (i) verify your own identity directly with us; or (ii) directly confirm with us that you provided the agent permission to submit the request. If an agent wants to make a request to opt-out of the sale or sharing of your personal information or a request to limit our use of your Sensitive personal information] on your behalf, we may only ask for the proof that you have provided signed permission authorizing the agent to make a request on your behalf.

11. How do we use anonymised information?

Where we maintain or anonymise information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

12. What are the sources of personal information we have gathered?

We collect personal information from a variety of sources, including:

From You. You may directly give us personal information when you:
- Apply for, purchase, register or use our products and services;
- Receive customer support;
- Register on training course;
- Subscribe to our publications;
- Request marketing be sent to you;
- Create an account, fill in forms to enter a competition, promotion or survey;
- Correspond with us in person at trade shows, events, or otherwise;
- Interact with us as a potential or existing supplier, distributor, or sales representative, or as an employee of the above
- Make a claim under a warranty policy for which we provide claims administration services;
- Give us feedback or provide us other information when you contact us; or
- When you connect your social media account to your account with us.
From automated technologies or interactions. As you interact with our website or application, we will automatically collect Technical and Usage Information (more fully described in the “What types of personal information do we gather?” Section.) We collect this data by using cookies, server logs and other similar technologies. For detailed information on the technologies we us on this website, see Cookie Policy
From third parties or publicly available sources. We will receive personal information from various third parties that confirmed they are authorized to share it with us or other public sources, such as:
- Consumer reporting agencies, credit reference agencies and publicly available databases;
- Your employer or school in order for you to use our products or services;
- Your representatives, which may include your spouse, employees, legal and financial advisors or others you authorize;
- Our distributors or sales representatives;
- Independent service contractors;
- Advertising networks;
- Operating systems and platforms;
- Social networks;
- Social media providers;
- Data Analytics Providers
- Banks, Legal advisors, Insurance companies, brokers, and other financial institutions;
- Third party services to investigate claims;
- Vendors and suppliers that you may interact with;
- Insurance companies and brokers;
- Other Snap-on group companies that you may interact with through other websites, products, services, or social media pages;
- Search information providers; or
Will my personal information be transferred to other countries?

We are a global company and your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by engaging with us you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

ADDITIONAL INFORMATION REGARDING THE EEA and the UK:

Some non-EEA and UK countries are recognized by the European Commission and ICO as providing an adequate level of data protection according to EEA or UK standards (the full list of these countries is available here for the EEA and here for the UK. For transfers from the EEA and UK to countries not considered adequate by the European Commission or the ICO, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and the ICO (including with the members of the Snap-on Incorporated group) to protect your personal information. You may obtain a copy of these measures by contacting [email protected].

What security measures are in place to protect my personal information?

We endeavour to protect the security of your personal information. We will seek to maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of your personal information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we endeavour to protect your personal information, we cannot guarantee the security of your personal information transmitted to us; any transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to try to prevent unauthorised access. These procedures include physical, electronic, and managerial procedures.

13. How do I opt out of being contacted for promotional purposes?

You have the right to ask us not to send you marketing communications. We will usually inform you (before collecting the personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect personal information. If you have initially given your consent to our marketing communication, you can also exercise the right to prevent such processing at any time by:

Clicking the unsubscribe link in any informational or promotional email that we send you.
Contacting our Customers Service Center if you have any questions about changing your contact preference or require assistance in removing your name from our subscription lists.

14. How do we use cookies and similar technologies?

Please refer to our Cookies Policies here Cookies Policy

15. Modifications to this Privacy Statement

We may change or update this privacy policy from time to time. If we make a material change that affects personal information that we collected prior to the change, depending on the nature of the change, we might notify you of the change and we might request your consent to the change. We will post any changes on our website so please check regularly for the most recent version of our privacy policy. We will post the revised Privacy Policy on this page with a new “Last Updated” date. This version is dated, 4th December 2023.

16. Links

This site contains links to other sites. We are not responsible for the content or privacy practices of those sites, and our privacy policy does not apply to information collected from you by those sites. We encourage you to read the privacy statements of each site that collects information from you. When you are leaving our site via a link to interact with a site that is not governed by our privacy policy, a new browser window will open. If your interaction with our site will require sending your information to a third-party site that is not governed by our privacy policy, we will clearly inform you before your information is sent.