Last Updated December 1, 2018
SnapApp may, subject to applicable law, transfer your information outside the country where you are located and to where information protection standards may differ (e.g. your information may be stored on servers location in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your personal information. Specifically, SnapApp participates in and has certified its compliance with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework. SnapApp is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland respectively, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list
SnapApp is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. SnapApp complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, SnapApp is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SnapApp may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) here.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
We regularly review our compliance with this Policy. SnapApp may edit this Policy from time to time and in the event the policy is revised we will notify you by means of a notice on this website prior to the change becoming effective of any significant/material change. Please direct any questions or concerns regarding this Policy via email to email@example.com.
I. Collected Information
Registration Information: Registration is required to create SnapApp applications or purchase the SnapApp Service. You will be asked for PII as part of the registration process. SnapApp requires that account holders be eighteen (18) years of age or older.
Marketing Information: In addition we collect information at our site and through our own use of the Service that we use for marketing to current and prospective customers. Additional information collected through our use of the Service may include responses to questions.
Payment Information: Credit Card and direct debit payments for SnapApp are processed through a third-party payment processing provider. SnapApp does not store your personal Credit Card information. For payments requiring an invoice rather than credit card or direct debit, SnapApp will store billing information, such as name and billing address.
Other Information: In addition to PII, additional information may be collected, such as system information, browser type (e.g., Netscape, Internet Explorer, Firefox), IP address, the type of operating system you are using (e.g., Windows or Mac OS), what version of Adobe Flash you are using (e.g., Flash 9.0), CPU type (e.g. Pentium), your manner of connecting to the Internet (e.g., connection speed through narrowband or broadband access), and the domain name of your Internet service provider and stored in log files. We do not link this automatically collected data to other information we collect about you. We and our marketing partners, affiliates, or analytics or infrastructure service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. In addition, SnapApp uses third-party service provider partners to employ cookies for analytical, accounting and data integrity purposes.
Behavioral Targeting: We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Other sources: We may receive information about you from other sources, including publicly available information or information available from third party sources, such as updated delivery and address information from our carriers or third parties, and add it to our account and marketing database information, generally for updating purposes. We may also obtain information about you through optional co-registration and/or advertisements on sites operated by third parties.
Other website related Information: Our website includes links to other websites whose privacy practices may differ from those of SnapApp. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit. With your consent we may post your testimonial along with your name. Our website may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through SnapApp public message boards, blogs, or forums, this information may be collected and used by others. To request removal of your personal information from our testimonial, blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Social Media Widgets: Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
SnapApp’s website currently does not respond to “do not track” or similar signals.
II. Use of Collected Information
Marketing: By submitting PII to SnapApp you grant SnapApp the right to use that information for marketing purposes, such as contacting you about new features and promotions offered by SnapApp. Your PII is also used in a variety of other ways, including:
- Provisioning your use of the SnapApp software platform
- Ensuring better presentation of site content to match demographic interests
- Contacting you regarding your SnapApp account, and confirming your registration with SnapApp
- Tracking your compliance with the SnapApp Master Service Agreement
- Improving content and acquiring feedback
III. Information Sharing and Disclosure
We may share your personal information with other companies so that they can market their products or services to you. If you do not want us to share your personal information with these companies, contact us at email@example.com. We also share PII with other companies or individuals outside of SnapApp in the following limited circumstances:
Third Party Service-Providers: SnapApp may from time to time share email addresses and other PII with third parties to perform functions on our behalf, such as sending informational emails about our products and services, lookup and reference, data enhancement, suppression, and validation. In these cases, SnapApp uses only trusted partners who are prohibited from using your information except to provide services for and on behalf of SnapApp and are required to maintain the confidentiality of your information.
Protection of SnapApp and others: We reserve the right to access, use, preserve or disclose PII: as required by law, regulation, legal process or governmental request and when we believe that access, use, preservation or disclosure is necessary to protect our or our users’ rights, property or safety and / or comply with a judicial proceeding, court order, legal process or governmental request served upon our company; enforce the terms and conditions of SnapApp, including investigation of potential violations; and to detect, prevent, or otherwise address fraud, security or technical issues.
Aggregated Information: We may share, publish or disseminate aggregated information about our users, such as reports we publish about overall usage of SnapApp. This information may include demographics, usage, or characteristics of SnapApp participants as a group.
IV. Access to Information and Preferences/Opt-Out
Upon request SnapApp will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at firstname.lastname@example.org.
If your personally identifiable information changes, or if you no longer wish to use our Service, you may correct, update, and/or request deletion on our site at https://manage.snapapp.com/profile or by emailing us at
email@example.com. If you request that your user information be deleted from our records, there may be a brief delay in our processing that request, while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your information be deleted, we reserve the right to terminate and/or limit your access to the SnapApp website and services. We will respond to your request within a reasonable timeframe.
We will retain your information, and on behalf of our customers, for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
To the extent we use PII to email you about our products and services, our email practices are in compliance with the U.S. laws. We also provide you the opportunity to opt out of having your PII used for certain purposes, when we ask for this information. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication, or by emailing us at firstname.lastname@example.org. We offer an opportunity to opt out of certain communications at http://info.snapapp.com/UnsubscribePage.html. If you do opt out from receiving promotional communications from us, this does not prohibit us from sharing PII for non-marketing purposes listed above.
To opt-out of interest-based advertising, by participating companies in the following consumer choice mechanisms, please visit:
To opt-out of interest-based advertising, by participating companies in the following consumer choice mechanisms, please visit:
- TrusArc’s Preferences Manager (http://preferences-mgr.truste.com/) and/or the mobile application-based “TRUSTe Privacy App” download page (https://trustarc.com/consumer-resources/privacy-app/)
- European Interactive Digital Advertising Alliance (EDAA)’s self-regulatory opt-out out page (https://youronlinechoices.eu).
No method of safeguarding information is 100% secure. SnapApp uses a variety of security technologies and procedures to help protect your PII from unauthorized access, use or disclosure. SnapApp maintains the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When sensitive personal information is collected on our site and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
VI. California Privacy Rights
California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of personal information with third parties for direct marketing purposes. SnapApp does not share any California consumer personal information with third parties for marketing purposes without consent.
VII. European Union (EU) Visitors
SnapApp’s Site is hosted and operated in the United States (“US”). In accordance with European Union law, SnapApp must provide notice and disclosure of, among other items, it’s legal basis for processing and the individual rights available to citizens of the EU.
1. Legal Basis for Processing
2. EU Citizen Individual Rights
Where EU data protection laws apply, you will have the rights described below. In certain situations, SnapApp, as a processor, does not have a direct relationship with individuals whose Personal Information it processes. An individual who seeks access, or who wishes to change, correct, or remove Personal information may want to first direct such inquiries to the Controller to whom they provided the information. You may exercise your privacy rights by contacting us at email@example.com and we will handle your request under applicable law. When you make a request, we will verify your identity to protect your privacy and security.
- Right of access – the right to be informed of and request access to the personal data we process about you.
- Right to withdraw consent – to the extend we requested your consent to process your Personal Information, you have the right to withdraw your consent to the processing of your Personal Information at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
- Right of rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete.
- Right to erasure – the right to request that we delete your personal Information.
- Right to data portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.
- Right to restriction – the right to request that we temporarily or permanently stop processing all or some of your Personal Information.
- Right to object to processing – the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes.
- Right not to be subject to automated decision making – the right not to be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on your or produce a similarly significant effect;
- Right to lodge a complaint – the right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place or work, or place of alleged infringement.
SnapApp account holders must be 18 years of age. We employ commercially reasonable measures to prevent the creation of SnapApp accounts by minors under the age of 18, and to terminate accounts found to be in violation of this policy. SnapApp does not knowingly collect personal information from minors under the age of 13. If you are under the age of 13, please do not provide us with your personal information. If you have reason to believe that a child has provided us with their personal information, please contact us at firstname.lastname@example.org and we will delete that information from our databases.
SnapApp is not responsible for information obtained from underage users who have provided false information regarding their age. However, in these instances, parents may contact SnapApp at email@example.com and have his/her information removed.
IX. Contact Information
200 Clarendon Street, 21st Floor, Boston, MA, 02116