OUR COMMITMENT TO YOU
If you are a California resident, please click here for additional information regarding the collection and use of your information, and the rights that you have under California law
GROUNDS FOR DATA COLLECTION
We also rely on other lawful grounds for processing your Personal Data, namely: the performance of our contractual obligations towards you or whomever provides us with your information for your benefit (such as your employer, friends or family) (a “Gift Sender““), our legitimate interests in the provision of our Services including for administering our Website or Platform, for compliance with legal and regulatory obligations to which we are subject, and otherwise described herein. We may collect information that is not Personal Data (“Non-Personal Data”), including the following information: lawfully made available from federal, state, or local government records; collected by tracking technologies such as cookies; or from aggregate or de-identified information. Because Non-Personal Data does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine Non-Personal Data with Personal Data. If we combine any Non-Personal Data with Personal Data, the combined information will be treated by us as Personal Data.
INFORMATION WE COLLECT DIRECTLY
We may collect the following Personal Data about you:
- In order to provide our Services, you, or a Gift Sender (as described above), may be required to provide us with your contact details including your name, phone number, and email address. In cases where we need to, or have a third party, ship your gift, we will also process the physical address you provide for shipment. Other information we may collect directly from you may include: Account information, such as your username and password; billing information, such as credit card details and billing address; optional information you may choose to provide, such as your social handles, age, gender; and any other information you choose to provide, such as product reviews, responses to surveys or quizzes or to receive customer support.
In other cases, we may receive some or all of these contact details from a Gift Sender, who has contracted with us to provide you with our Services.
- We may utilize session replay software to monitor your interaction with our Website or Platform which may capture and/or record your interaction(s) with the Website or Platform, including without limitation keystrokes, mouse movements, and form field entries. We utilize this information for our compliance verification purposes and to improve our Services, and User experience.
- We often invite eligible Users to tell a friend about our products or services. Where permitted, you may provide us with your friend’s name, email address and/or other contact information (“Referral Information”). We may use this information to automatically send your friend emails or other messages inviting them to use our Services. Your friend may opt-out of future marketing emails by clicking the “unsubscribe” link or otherwise following the opt out instructions provided within the invitation and may contact us at email@example.com to request that we remove their information from our database.
- When you send us an email or otherwise contact us, we will collect any information, including Personal Data that you choose to include in your inquiry to us.
INFORMATION WE COLLECT AUTOMATICALLY
We, our service providers, or our third-party partners may also automatically collect information from a User when a User visits our Website, our Platform or otherwise use our Service. Such information may include:
- Clickstream Data. As you use the Internet, a trail of electronic information is left at each website a User visits. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a website's server. Clickstream data can tell us the type of computer and browsing software a User uses and the address of the website from which a User linked to the Website. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of a User’s Website, how visitors navigate throughout the Website and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Website and our Services.
HOW DO WE USE THE DATA WE COLLECT?
- Provision of the Service – we may use the Personal Data a User provides us for the provision and improvement of our Service, providing customer support and to respond to a User’s queries.
- Service announcements – we may use Personal Data to communicate with a User by email and text message to keep a User informed of our latest updates to our Service and offer a service and product offers that we believe a User may have an interest in.
- Analytics, surveys and research – from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Services and offerings (including to our business partners), and develop new and exciting features for our Users.
- Protecting our interests – we may use Personal Data when we believe it’s necessary or appropriate in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves or third parties from fraud, protect the security or integrity of our Services and protect the rights and property of the Company, its Users, partners and/or other third parties.
- Compliance with legal and regulatory requirements – we may use Personal Data to investigate violations, and as required by law, regulation, rule or other governmental authority, or to comply with a subpoena or similar legal process.
- Marketing and advertising – we may send a User emails and text messages with promotional material concerning our Service, or our business partners' services, which we believe might interest a User; we may also display certain adverts on our Service and/or on third-party websites and platforms, which we believe will be relevant for a User. We try to show a User only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on a User’s Personal Data.
- Service Data – We may receive Personal Data from our customers in the form of Service Data. We use this information solely at the direction of these customers in order to provide them with our Services.
We may use information we collect (alone or in combination with information provided by third parties and service providers) to deliver targeted advertising (about us or other third party products and services) to you when you visit our Website or other websites. Information about a User may be used in this process. For example, if you are searching for information on a particular product, we may use that information to cause an advertisement to appear on other websites you view with information on that product. We may, now or in the future, have the ability to engage in “cross-device matching” to display targeted advertisements to you across browsers and devices (as described above).
To further clarify, we partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you or your business. Our partners may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share Personal Data with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners use this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, and Smart TVs, over time for advertising, analytics, attribution, and reporting purposes.
If you would like to opt out of these interest-based advertisements or “cross-device matching,” please see the section titled “YOUR CHOICES”, below.
HOW WE PROTECT YOUR INFORMATION
While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Service, and you do so at your own risk.
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing Personal Data, communications and anything else as required by applicable laws and regulations.
We strive to offer you with choices about how information is used and shared. There are several ways in which you may opt out of the various programs and services we provide. Some of the ways in which you may opt out are described below.
Opting Out of Our Services. You may choose not to receive our promotional or marketing emails by clicking on the “unsubscribe” link in the emails that you receive from us, or by sending an unsubscribe request to us at firstname.lastname@example.org. Please note that even if you unsubscribe, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us. We may also still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests and orders, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.
NEVADA PRIVACY RIGHTS
If you are a Nevada resident, you have the right to request that we do not sell your covered information (as those terms are defined in N.R.S. 603A) that we have collected, or may collect, from you. We do not sell your covered information, however, if you would like to make such a request you may do so by contacting us at email@example.com.
EU/UK/SWITZERLAND PRIVACY DISCLOSURES
EU/UK/Switzerland (collectively “EU+”) User Rights
The controller of all data collected by us through the Services is Snappy App, Inc. We may obtain Personal Data and other information about you through public sources and/or our third- party partners who help us provide our products and services to you. We may also obtain Personal Data from our customers in the form of Service Data. With respect to Service Data, our customers are the data controllers and we act as their data processor.
As an EU/UK/Switzerland resident, you may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
- Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your Personal Data that is in our control.
- Request erasure of your Personal Data.
- Object to the processing of Personal Data by us.
- Request to restrict processing of your Personal Data by us.
- Lodge a complaint with a supervisory authority.
Please note that these rights pertain to EU/UK/Switzerland residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
Data Subject RequestsIf you are an EU/UK/ Switzerland resident, you have the right to access Personal Data we hold about you and to ask that your Personal Data be corrected, updated, or erased. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may submit a request here.
Use of your Personal Data for marketing purposes
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have consented to our use of your Personal Data for marketing purposes.
Users Outside the EU/UK/Switzerland - Some of the aforementioned rights are applicable in certain jurisdictions outside the EU/UK/Switzerland as well. Users residing outside the EU/UK/Switzerland are welcome to contact us for any questions or requests at the details below.
If you wish to exercise any of your rights or submit a request regarding your Personal Data processed by us, please refer to the contact information below.
Transfers of Data Outside of the EU, UK, and Switzerland
If you reside in the EU, UK, or Switzerland, please note that some data recipients may be located outside the EU, UK, or Switzerland. In such cases we will transfer your data only to such countries as approved by the European Commission and other applicable data protection authorities as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
OUR POLICY TOWARD CHILDREN
We understand the importance of protecting children’s privacy, especially in an online environment. Our Services are not designed for or directed at children under the age of 16 years old (“Minors”).
We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided below.
HOW TO CONTACT US?
If you wish to exercise any of the aforementioned rights, or receive more information, please submit a request here, or contact us at firstname.lastname@example.org or at the following mailing address:
33 Irving Place, #5021
New York, NY 10003
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time.
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Snappy has appointed European Data Protection Office (EDPO) as its GDPR Representative in the European Union. You can contact EDPO regarding matters pertaining to the GDPR by (i) using EDPO’s online request form: https://edpo.com/gdpr-data-request/ or (ii) writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
Pursuant to Article 27 of the UK GDPR, Snappy has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by (i) using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/ or (ii) writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.
UPDATES TO THIS POLICY