Privacy Notice

Introduction

99pouches.com (the "Site") is operated by Northerner Scandinavia, Inc. ("Northerner," "we," "us," or "our"), which also operates Nicokick.com. This Privacy Notice explains what personal information we collect through this Site, why we process it, with whom we share it, and the rights and choices available to you.

99pouches is a product catalog. You can browse nicotine pouch products and build a cart, and we then direct you to Nicokick to complete your purchase. We do not process payments, take orders, or ship products on this Site. When you proceed to checkout you leave 99pouches and enter Nicokick, and information collected there is governed by the Nicokick Privacy Notice.

This Site is intended only for adults 21 or older in the United States.

1. What personal information do we collect?

Through this Site, we may collect information that is personally identifiable to you. This information may include:

• Contact details you choose to give us, such as your name, e-mail address, and phone number — for example when you contact us or when you enter your details before continuing to checkout on Nicokick.
• Product interest information, such as products viewed, products added to your cart, searches you run on the Site, and clicks through to Nicokick.
• Account information, such as e-mail address, password, and date of registration, for the administrative accounts we use to operate the Site.
• Correspondence and other information you provide to us related to support or privacy matters, such as e-mails and messages sent through our contact form.
• Information we collect automatically about your use of the Site, for example IP address, approximate geolocation derived from your IP address, device information (technical information about the computer, mobile phone, or other device you use, such as browser settings, time zone, and operating system), browsing, and searches.
• Campaign information, such as the UTM tags contained in the link you arrived on.
• Privacy-choice information, such as whether you accepted or declined advertising cookies and the information needed to remember and honor that choice.

We do not ask for or store payment card information on this Site, and we do not collect biometric information on this Site. Age and identity verification takes place at checkout on Nicokick.

2. From which sources do we collect information about you?

We collect information through direct interactions with you, as well as through automated technologies such as cookies and pixel tags. For example, you provide information when you use our contact form, enter your details before continuing to checkout, or sign in to an administrative account. We may also combine information collected on the Site with information we receive from third parties such as analytics providers and advertising networks.

3. Why do we process personal information?

We process personal information for the purposes described below and for any other purposes stated at the point of collection. This is a general description, and not all processing may apply to your personal information.

• To operate the catalog, remember the contents of your cart, and pass your product selection and the details you enter to Nicokick so you can complete your purchase.
• To administer the administrative accounts used to operate the Site.
• To manage support and privacy matters, for example responding to questions submitted through our contact form.
• To market and advertise our products and services. This may include tailoring content and advertisements to you, including "interest-based" or "personalized" advertising and cross-device tracking, through the advertising partners described in Section 7.
• To measure the performance of our advertising and to produce anonymous, aggregated datasets and analytics that help us understand which products and searches are popular and set our business and marketing strategies.
• To evaluate, develop, and improve the Site, our services, and our systems, for example technical troubleshooting and backup storage.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• To communicate important messages, such as material changes to our Terms and Conditions or this Privacy Notice.
• To fulfill our legal obligations, including age-restriction requirements, and to establish, exercise, or defend legal claims.

4. Regarding your age and minors

This Site is age-restricted. We do not knowingly collect or maintain personal information from any person under the age of twenty-one. No parts of our Site are directed to or designed to attract anyone under the age of twenty-one. Age verification for a purchase is carried out by Nicokick at checkout.

5. How may we share information?

• Service providers. We share information with the providers we engage to host the Site, run our database, provide functionality, store analytics, and deliver our e-mails, so they can perform those functions for us.
• Nicokick. When you click through to checkout, your product selection, any discount code, your campaign tags, and the e-mail address and phone number you entered travel in the link so your purchase can be completed. Information subsequently collected through Nicokick is governed by the Nicokick Privacy Notice.
• Third-party advertising partners. These partners may set cookies, pixels, and other tracking tools on the Site to collect information regarding your activities and your device (for example your IP address, cookie identifiers, pages visited, location, time of day). They may use this information, together with similar information collected from other services, to deliver personalized advertisements to you across their networks. This practice is commonly referred to as "interest-based advertising," "cross-context behavioral advertising," or "personalized advertising." See Section 7 and Section 8 for your choices.
• Other companies of the Haypp Group and our affiliates, for business and operational purposes.
• Legal and corporate purposes. We may share information as needed to enforce our rights, protect our property, or protect the rights, property, or safety of others, and to support external auditing, compliance, and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request, or other legal or regulatory process, and in connection with a change of ownership or control of us or any affiliated entity.

6. How do we protect your information?

We strive to protect your personal information by implementing a variety of administrative, technical, and organizational security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition, or misuse of your information. However, the security of information transmitted over the internet cannot be guaranteed. By using the Site or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site.

7. What about cookies and other information collection tools?

We, as well as third parties that provide content, advertising, or other functionality on our Site, may use cookies, pixel tags, and other technologies ("Technologies") to automatically collect information through your use of the Site. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. Pixel tags are small blocks of code on a web page or e-mail that allow a server to read and record certain information.

We use Technologies that are strictly necessary (for example to keep your cart, secure the Site, and remember your privacy choice), Technologies that support performance and analytics, and advertising- or targeting-related Technologies. Advertising Technologies load only after you accept advertising cookies. Some of the advertising and analytics Technologies we use include:

• Meta Platforms, Inc.. Meta Pixel. Used to measure the performance of our advertising and support relevant advertising on Facebook and Instagram. See their privacy policy and their Meta ad preferences.
• Google LLC. Google Ads conversion tracking and remarketing. Used to measure the performance of our advertising on Google and to show relevant ads across Google's services and partner sites. See their privacy policy and their Google ad settings.
• StackAdapt. StackAdapt programmatic advertising services. Used to serve, target, measure, and analyze digital advertising. See their privacy policy and their StackAdapt targeted advertising opt-out.

To opt out of our disclosure of your personal information to these advertising partners, visit our Your Privacy Choices page. Details of the individual cookies used on this Site are in our Cookie Policy.

Cookie and privacy choices made on 99pouches apply only to 99pouches.com and do not automatically carry over to Nicokick.com. You can manage Technologies used on Nicokick through the Your Privacy Choices link on Nicokick.

8. What privacy rights and choices may be available?

In accordance with applicable law you may have the following rights:

• Request to know. The specific pieces and categories of personal information we collected about you, the categories of sources, the categories of personal information disclosed for a business purpose, the categories of third parties to whom it was disclosed, and our business or commercial purpose for collecting it.
• Request to delete personal information we collected from you and retained, subject to certain exceptions.
• Request correction of your personal information where it is inaccurate or incomplete.
• Request restriction of, or opt out of, certain processing, including processing of sensitive personal information for certain purposes and profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Request to opt out of the sale of personal information or the sharing of personal information for cross-context behavioral or targeted advertising.
• Appeal our denial of a privacy request, and not be discriminated against for exercising these rights.

We do not sell personal information as the term "sale" is typically understood, and we have no actual knowledge of the "sale" or "sharing" of personal information of consumers under 16 years of age. However, we share information with the third-party advertising partners described in Section 7 for the purpose of promoting our Site and products. To the extent that such sharing is considered a "sale," "sharing," or is otherwise subject to an opt-out right under applicable law, you may opt out as follows:

• Cookies and personalized advertising. When you first visit our Site you are presented with a banner that informs you about the categories of Technologies used and your options for controlling them. You can change your choice at any time through the Your Privacy Choices link. Please note that cookies are browser and device specific, so your request is linked to your browser identifier only. If you use a different computer, mobile device, or browser, or clear your cookies, you will need to renew your choice. You may also stop or restrict Technologies through your browser or device settings, although the Site may then not work properly.
• Partner opt-outs. You can also use each advertising partner's own controls, listed in Section 7 above.
• Industry opt-outs. You can opt out of receiving targeted ads from participating companies through the Network Advertising Initiative, the Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. You can learn more about cookies at www.allaboutcookies.org.
• Global Privacy Control. You may exercise your opt-out right by broadcasting an opt-out preference signal, called the Global Privacy Control (GPC), on browsers and browser extensions that support such a signal. We honor this signal automatically as an opt-out. It is likewise linked to your browser only.
• Contact us. E-mail privacy@northerner.com or call +1 (816) 336-0041.

The categories of data we share for cross-context behavioral and targeted advertising include online identifiers such as IP address, marketing IDs, and device identifiers and characteristics; internet or other electronic network activity, such as browsing and usage information; and inferences about individual preferences, characteristics, and behaviors.

We will respond within the timeframe your state law requires. You may use an authorized agent; we may need to verify your identity or the agent's authority before acting on a request. If we deny your request, you may appeal our decision by submitting an appeal through the same method you used for your original request.

9. How long do we retain personal information?

We store personal information for as long as necessary to fulfill the purposes for which it was collected, provide and protect the Site, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable law, or based upon other criteria including the sensitivity and volume of the data. In practice:

• Contact and support correspondence is retained for up to 18 months from the completion of the matter.
• Details you enter before continuing to checkout are passed to Nicokick in the link; what Nicokick retains is governed by the Nicokick Privacy Notice.
• Site usage and analytics information is retained for up to 27 months from collection. Statistics and reports on an aggregated level that contain no personal information are stored until further notice.
• Technical logs and backups are retained for up to 13 months from the date of the log entry or backup.
• Cookies and local storage are retained for the periods described in our Cookie Policy.
• Information needed to manage or defend a legal claim is retained for as long as necessary for that claim.

When personal information is no longer needed, we delete it or convert it into aggregated or deidentified information.

10. Supplemental notice for residents of certain US states

This supplemental notice is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time, including but not limited to California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia ("Applicable State Laws").

In the preceding 12 months we have collected the following categories of personal information through this Site, and disclosed them as described:

We do not collect biometric information, payment card information, or government identification through this Site. Sources of the information and our purposes for collecting it are described in Sections 2 and 3 above. To exercise any right, or to opt out of "sales" or "sharing" for targeted advertising, use Your Privacy Choices or contact us as set out in Section 13.

11. Third-party websites

Our Site links to third-party websites, including Nicokick.com. We are not responsible for the privacy practices or the content of websites we do not operate. We encourage you to read the privacy notice of any website you visit.

12. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. Material changes will be reflected in the "last updated" date above, and we will provide any additional notice required by applicable law.

13. Contact us

Privacy requests and questions: privacy@northerner.com or +1 (816) 336-0041.