California Privacy Notice
Last Updated: November 1, 2022Introduction
This notice ("California Privacy Notice") addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. Code § 1798.100 et seq.) and the implementing regulations ("CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice. If you are a California resident, this California Privacy Notice applies to you.
This California Privacy Notice outlines the practice of Snappy App, Inc. (“Snappy”, “we”, "us", "our" and/or "Company") with respect to the information we collect from you when you access, download, install, register, use or engage with our website or platform (collectively, our “Site”) or any other service we provide or make available online or offline including through customer support channels and in-person promotional activities (collectively, the “Services”), the manner in which we use such information and the choices available for you.
In order to provide our Services to our customers, we may process Service Data (as further described in our Privacy Policy) that we receive from or on behalf of our customers. If you are a California resident, you may have certain CCPA rights pertaining to such information. Under the CCPA, we act as a “service provider” (not as a “business”) over Service Data, and only process such information through our Services as necessary to provide our services to our customers, at our customers’ direction. If you wish to exercise any of your rights under CCPA in regards to such information, please contact the relevant business that collected the information from you, and which controls and determines how your information is processed.
By accessing, downloading or using our Service, you acknowledge that you have read, understood and accepted the terms of this California Privacy Notice. If you disagree with any term(s) provided herein, please do not install or use the Service.
In addition to this notice, please also review our Privacy Policy and applicable Terms of Use referenced on our Site, to which this California Privacy Notice is incorporated by reference.
If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this California Privacy Notice.
Information We Process
We may collect and process certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). We treat information that is specifically connected or linked to any Personal Information – as long as such connection or linkage exists – as Personal Information.
We may also disclose Personal Information we have collected with our service providers for a business purpose (as further detailed in the “Business Purpose for Collection” section below), subject to a contract that describes the purpose and restricts the use of Personal Information disclosed.
In the 12 preceding months, we have collected and disclosed the following categories of Personal Information:
| Category of Personal Information Collected | Personal Information Collected | Categories of third parties to whom Personal Information was disclosed for a business purpose |
|---|---|---|
| Identifiers | Full name, email address, physical address, IP, social media credentials and identifiers |
|
| Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)) | Telephone number |
|
| Protected classification characteristics under California or federal law | Date of birth |
|
| Internet or Other Electronic Network Activity Information | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
|
| Geolocation Data | Approximate geolocation |
|
Sources of Personal Information
In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:
- Consumer directly;
- Employers;
- Advertising networks;
- Data analytics providers; and
- Social Networks.
Business Purpose for Collection
We only collect and process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a general matter, for all categories of data we collect, we may use the information we collect (including Personal Information, to the extent applicable) for:
- Provision of the Service – we may use the Personal Information you provide us for the provision and improvement of our Service, providing customer support and to respond to your queries.
- Service announcements - we may use your Personal Information to communicate with you and to keep you informed of our latest updates to our Service and offer you service and product offers that we believe you 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 your Personal Information when we believe it’s necessary or appropriate in order to take precautions against liabilities, investigate and defend ourselves or third parties against any third-party claims or allegations, investigate and protect ourselves 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.
- Enforcing of policies - we may use your Personal Information in order to enforce our policies, including but not limited to our applicable Terms of Use referenced on our Site.
- Compliance with legal and regulatory requirements - we may use your Personal Information 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 use your Personal Information in the following ways: we may send you promotional material concerning our Service, or our business partners' services, which we believe might interest you; we may also display certain adverts on our Service and/or on third-party websites and platforms, which we believe will be relevant for you. We try to show you only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Information.
- Opt-out of receiving marketing materials - 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. 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 Information 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 Information are authorized to use your Personal Information only as necessary to provide these non-marketing services.
User Rights under the CCPA
In addition to the right to opt out of sales explained above, subject to certain limitations, California consumers have the right to (1) request to know more about the specific pieces and categories of personal data we collect, use, sell and disclose, (2) request deletion of their personal data, (3) opt out of the sale of their personal information, (4) request a copy of the personal data we have collected and maintained about you in the past 12 months, (5) request that we correct inaccurate personal data we have collected and maintained about you, and (6) not be discriminated against for exercising their rights. You may make a request to know more about or delete your personal data by submitting this online form or emailing privacy@snappy.com. Additionally, access requests under the CCPA can be made by calling +1 (833) 649-3151. We will verify your request by contacting you after receiving your request to verify your identity. Please note that we may retain certain information as required or permitted by applicable law. If you request to delete your personal data, certain of our products and services may no longer be available to you. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. You further have a right not to receive discriminatory treatment for exercising your privacy rights under the CCPA. Unless permitted by the CCPA, we will not: (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you a different level or quality of goods or services or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Record Keeping
We will maintain records of consumer requests made pursuant to the CCPA and our responses to said requests for a minimum period of 24 months. Such information will not be used for any other purpose other than records keeping requirements under the CCPA or other legal requirements such as law, court order, subpoena, warrant or other legal judicial process. Further, our retention periods for personal data are based on business needs and legal requirements. 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.
Children's Information
Our Service is not intended for minors below the age of 16 years or otherwise below the legal age for providing consent that is not subject to authorization by the holder of parental responsibility, in accordance with the laws in the jurisdiction you reside in (“Age of Consent”), and we will not knowingly collect Personal Information from children. If we become aware that a user is under the age of Age of Consent, we will remove their information from our files. We reserve the right to request proof of age at any stage so that we can verify that children are not using the Service.
California “Shine the Light”
Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. If you are a California resident: (i) to request the above information, or (ii) if you do not want your personal information shared with any third party who may use such information for direct marketing purposes and wish to opt out of such disclosures, please contact us by email at privacy@snappy.com.
Please note that under Shine the Light, we are not responsible for removing your personal information from the lists of any third party who has previously been provided with your information, and any elections or privacy choices you may make with respect to receipt of certain types of e-mails or marketing communications from us will not apply to any such third parties. You should directly contact any third parties that send you communications regarding choices that they may make available to you concerning such communications.
Updates or Amendments to the California Privacy Notice
We reserve the right to change this California Privacy Notice at any time, so please revisit this page frequently. All changes to this California Privacy Notice are effective as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.
How to Contact Us
If you have any questions (or comments) concerning this California Privacy Notice, you are welcome to contact us by submitting a request here, or contacting us at privacy@snappy.com, +1 (833)-649-3151 or through the following contact details:
Snappy Gifts
Attn: Privacy
33 Irving Place, #5021
New York, NY 10003
United States
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time.