Legal · privacy
Privacy statement
We sell phones, not data. This statement explains in plain English which data we process, why and for how long, deliberately limited to what we need to deliver your order.
Who we are
Snowden Phone supplies degoogled Google Pixels with GrapheneOS, configured by hand. For privacy questions and requests about your data, you can reach us at info@snowden-phone.nl. Snowden Phone is registered with the Dutch Chamber of Commerce (KvK) under number 67353274, based at Nieuwegracht 16-11, Soest, the Netherlands. Our VAT identification number is NL002388991B77.
What data we process
When you place an order, we process only the data needed to handle and deliver it. In practice that means:
- your name;
- your delivery address;
- your contact details (email address and, if you share it yourself, phone number);
- your order details (which phone you order and the arrangements we make with you);
- if you withdraw from your order with the Withdraw from contract here button: the details in your notice (name, email address, order number or order date, and phone) and the date and time you submitted it. We do not store your IP address for this.
Messages sent over WhatsApp, Signal or email travel through those services themselves and fall under the privacy policy of the provider concerned. We only keep the content we need to handle your order and support request.
What we use your data for
- handling your order;
- delivering your phone;
- providing support and answering your questions;
- meeting our legal obligations, such as our bookkeeping and record-keeping duties.
Forms and emails on this site
Besides placing orders, you can send us data through a few forms. For each form, you can read here what we keep, what for and for how long. We do not store your IP address with any of these forms.
- Compatibility check (Does it work with my bank? page): your email address, the apps you mention and, if you fill it in, your name. We use these only to answer your question and keep them until three months after our answer.
- Privacy checklist: your email address. You receive the checklist and after that no more than four emails about privacy on your phone, based on your consent. You can unsubscribe with one click at the bottom of every email. We delete your address no later than three months after you sign up.
- Checkout: the email address you enter before payment. We send your order confirmation to that address. If you do not complete the payment, we send one reminder, with a link to unsubscribe. We delete the data from a checkout that does not lead to an order no later than three months afterwards.
- Pixel 11 waiting list: your email address and, if you fill it in, your name. We use these only to email you once, as soon as we can deliver the Pixel 11 with GrapheneOS, based on your consent. After that one email we delete your data, and in any case no later than 12 months after you sign up. Want to come off the list sooner? Email info@snowden-phone.nl.
- Withdrawal (Withdraw from contract here button): see above and under Retention periods.
After an order, we may ask you once for a review. If you unsubscribe from our emails, we keep only the fact that you have unsubscribed, so that you receive no more email from us.
Legal basis
We process your data on the basis of the performance of the agreement you enter into with us and, where applicable, on the basis of a legal obligation (for example the tax record-keeping duty). For the privacy checklist and the emails that follow it, and for the Pixel 11 waiting list, the legal basis is your consent, which you can withdraw at any time. We answer the compatibility check at your own request. We send the single reminder about an unfinished payment and the review request on the basis of our legitimate interest; you can unsubscribe from these.
Retention periods
We keep your data for as short a time as possible and no longer than needed or legally required. We keep invoice and bookkeeping records for the statutory tax retention period of seven years. A notice of withdrawal is part of those records; we also keep it for seven years (Dutch tax record-keeping duty, Article 52 AWR). The periods stated above apply to the forms. We delete other data as soon as it is no longer needed for the purposes listed above.
Sharing with third parties
We share your data only with parties we need in order to serve you:
- Stripe processes your payment, including payments by iDEAL, Klarna and PayPal, and creates the invoice. For this, Stripe receives your name, email address, address and payment details. If you choose Klarna or PayPal, that party receives the data needed for that payment method.
- Hostinger hosts this website and our email. Order and form data and our emails are stored on their servers.
- PostNL delivers your parcel and receives your name and address for that purpose. Outside the Netherlands, PostNL works with a local delivery company, which also receives your name and address.
Stripe is (also) an American company. If your data goes to the United States as a result, this happens on the basis of the EU-US Data Privacy Framework, for which Stripe is certified. Stripe also uses standard contractual clauses of the European Commission where necessary.
We do not sell your data and do not share anything with advertising networks or data platforms. We sell phones, not data.
Statistics and cookies
This website does not place tracking cookies and does not build visitor profiles. We keep visit statistics with our own counter on this site, which we manage ourselves. For each visit, the counter records the page, where you came from (the referring website or the campaign name in the web address), a rough device type (phone, tablet or computer) and the steps in the order flow. To count visitors per day, the counter makes a shortened hash of the date, your IP address and your browser type. We do not store your IP address itself, and the hash is different every day. To link the steps of one order attempt, your browser keeps a random code in session storage, which disappears when you close the tab. We only look at this data as totals. We keep the counter's data for 12 months; after that we delete it automatically.
If you arrive on our site through a Google ad, the web address contains a click identifier from Google. We do not store it, not in your browser and not on our server, and we do not report your visit or order to Google. Our statistics only record that the visit came from an ad.
Your rights
Under the GDPR you have the right of access to, rectification (correction) and erasure of your data, the right to restriction of processing, the right to data portability and the right to object to processing. Would you like to exercise one of these rights? Send a message to info@snowden-phone.nl.
If you are not satisfied with how we handle your data, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). You can also lodge a complaint with the data protection authority in the EU country where you live or work.
Contact
Do you have questions about this privacy statement or about how we process your data? Please contact us at info@snowden-phone.nl.