Overview of SnapApp and Data Privacy
March 1, 2018
1. SnapApp overview
The SnapApp interactive content marketing platform provides marketers the power to create, publish, promote, and measure engaging interactive content experiences as part of their demand generation and customer marketing initiatives (each such experience is a separate “App”). SnapApp is a multi-tenant SaaS solution, which customers use in self-serve or managed-services mode to build content to their specification. SnapApp does not provide custom software development or custom agency/professional services to customers.
All such data collected passes through SnapApp’s servers and as such SnapApp is deemed the processor of such data with the Customer remaining the controller of said data. Under the Terms of Service, SnapApp is prohibited from using any of the PII collected, which remains the property of the Customer at all times.
2. Platform infrastructure
SnapApp production applications and services are entirely hosted in an Amazon Web Services (AWS) environment, creating a shared responsibility security model with AWS. AWS operates, manages, and controls the components from the host operating system and virtualization layer down to the physical security of the facilities in which the services operate. In turn, SnapApp assumes responsibility and management of the guest operating system (including updates and security patches), application software, and the configuration of the AWS-provided firewall support.
The specifics regarding SnapApp’s approach to data privacy and security are documented in the SnapApp IT Security (currently v2.1) document, which can be downloaded here.
Information regarding AWS’s approach to data privacy and protection can be found here.
3. Commitment to Data Protection – Privacy Shield Certification
SnapApp considers the security of our customers’ data a top priority. As described in the SnapApp IT Security document referenced above, we have enacted measures designed to maximize protection of customer data, while being as unobtrusive as possible.
SnapApp meets globally recognized EU-US and Swiss-US Privacy Shield data privacy requirements and has achieved Truste Certified Privacy certification. The Truste Certified privacy seal is displayed on the SnapApp.com website and details about SnapApp’s EU-US and Swiss-US Privacy Shield certification are available on the official Privacy Shield website here.
4. SnapApp and GDPR
SnapApp’s position on the EU General Data Protection Regulation (GDPR) has been formulated in conjunction with our European counsel and is summarized as follows:
Based on the territorial scope of GDPR, it is our position that SnapApp itself, to the extent that it acts as a controller of personal data, is not required to adhere specifically to the GDPR requirements. SnapApp does not offer goods or services to data subjects in the European Union (Art. 3(2)(a) GDPR, and it also does not track the behavior of data subjects in the European Union (Art. 3(2)(b) GDPR).
As it relates to SnapApp’s obligations in supporting its customers who are subject to GDPR, where SnapApp is the processor of its customers’ personal data, our continued certification under the EU-US and the Swiss-US Privacy Shield framework is considered to allow our customers to fulfill their obligations regarding the transfer of personal data to recipients outside the European Union. SnapApp will enter into an appropriate Data Processing Addendum (DPA) as required under GDPR and can provide a standard form DPA or review a customer’s preferred form.