SnapApp and Data Privacy

Overview of SnapApp and Data Privacy

August 15, 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.

Customers usually configure their Apps to gate marketing content and securely deliver user lead data to their marketing automation platform through either APIs or web-forms, provided by each marketing automation provider.   The data collected through their Apps is at each Customer’s discretion and as such is subject to their individual Privacy Policy. While the content collected is often Personally Identifiable Information (PII) it is of a general business nature.  SnapApp’s Terms of Service expressly prohibit customers from using the SnapApp platform to collect “Sensitive Information” such as financial, health, government, or employment information. 

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 is a multi-tenant web hosted solution that enables customers to build and host the Apps they create on the SnapApp platform and then use embed code to serve the content to targeted end users from a variety of web sources including CMS landing pages, social media platforms, and responsive mobile web pages.  Apps are served as javascript within an iframe. 

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 Security Systems and Procedures document, which is available upon request.

Information regarding AWS’s approach to data privacy and protection can be found here.


3. Data Retention Approach 

Any data collected through the platform by Customers (including PII) is stored actively in the SnapApp production environment for 30 days.  By default the data is configured to be pushed in real-time to the Customer’s marketing automation platform through either APIs or web-forms, provided by each marketing automation provider.  Alternatively, Customer’s may instruct SnapApp in writing to provide access to enable secure download of the data directly from the SnapApp platform.  At the end of 30 days all collected data is deleted.


4. Commitment to Data Protection – GDPR and Privacy Shield Certification

The technical and process measures that SnapApp has implemented regarding data security, as described in the SnapApp Security Systems and Procedures document, have been designed to ensure we are supporting our customers who are subject to GDPR, where SnapApp is considered the processor of data collected through its platform. 

SnapApp’s continued certification under the EU-US and the Swiss-US Privacy Shield framework is considered to allow our customers to fulfil 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. 

The Truste Certified privacy seal is displayed on the web site and details about SnapApp’s EU-US and Swiss-US Privacy Shield certification are available on the official Privacy Shield website here.

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