Privacy Policy

Our commitment to you

We, at Snappy App, Inc. ("us", "we" or "Company"), respect the privacy of our users (each, a "User" or "you") and are committed to protect the privacy of Users who access, download, install, register, use or engage with our website or mobile application (the "Website" and "Application" respectively) and any other service we provide or make available (collectively, the "Service(s)").  

The purpose of this Privacy Policy is to describe to you our practices with respect to collecting, using and disclosing your information when you use the Services. We encourage you to read this Privacy Policy carefully and use it to make informed decisions. By accessing or using the Services, you agree to the terms of this Privacy Policy and your continued access or use of the Services constitutes your ongoing agreement to the Privacy Policy.  This Privacy Policy may change from time to time. Your continued use or access to the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Grounds for data collection

When you use our Services (including, without limitation when you sign up an account). you consent to the collection, storage, use, disclosure and other uses of your Personal Data (meaning any information which may potentially allow your identification with reasonable means) as described in this Privacy Policy.

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 provision of our Services including for administering our Website or Application, and for compliance with legal and regulatory obligations to which we are subject.

What type of data do we collect?

Personal Data

In the course of using the Services, we may collect certain Personal Data to provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Service or as otherwise indicated in this Privacy Policy. We may collect the following Personal Data about you:

• In order to provide our Services, you, or a Gift Sender (as described below), will be required to provide us with your contact details, including your name, phone number, and email address. In cases where we need to ship your gift, we will also process your physical address.

In other cases, we may receive some or all of these contact details from a Gift Sender, who has contracted us to provide you with our Services.

• Our Services include an option to register using your social media account (such as Facebook). If you choose to log in or connect to the Services using your social media account, we will process your social media account information, including your profile picture. We may also process other publicly available information on your social media account, which we believe may be necessary or relevant for the provision of the Services, as described herein. When you use your account on a social media service, to log in to our Services, you acknowledge that such third party service provider will process your personal data in accordance with its own privacy policy and terms of use, as applicable, and that in no event will We be responsible for such third party service provider's privacy practices or otherwise.
• 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.

• Our webserver may also automatically collect your IP address, mobile ad ID and unique online identifiers. These details are pseudonimyzed (cannot directly identify you, but may identify your device) and are collected for the purpose of delivering relevant content and operating and improving our Service (including services from our business partners).

Non-Personal Data

We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:

• Technical information – when you use our Services we may collect such non-personally identifiable data as: your operating system, device type, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), your general location (city and country), and general information regarding your browser and device.

If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data.

How do we use the data we collect?

• Provision of the Service – we may use the Personal Data 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 Data 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 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.
• Enforcing of policies - we may use your Personal Data in order to enforce our policies, including but not limited to our Terms.
• Compliance with legal and regulatory requirements - we may use your 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 use your Personal Data 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, 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 Data.
• 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 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.

Tracking technologies

When you visit or access our Services, we may use (and authorize 3rd parties to use) pixels, cookies, events and other technologies (collectively, "Tracking Technologies"). Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics and customize your experience. In addition, we may merge data we have with data collected through these tracking technologies and data we may obtain from other sources and, as a result, such data may become Personal Data. To learn more about who we use Tracking Technologies, please read our Cookie Policy.

With whom do we share your personal data?

• Internal concerned parties - we share your information with companies in our group, as well as our employees, contractors, services providers, and other third parties we use to support our business as needed or deemed appropriate by us, to provide our Services.
• Business partners (including retailers, consultants and vendors), independent contractors and other service providers  (collectively: "Providers") - We share your information with Providers such as storage and analytics companies who help us with the operation and provision of the Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they do so with the understanding that these parties will use the information for these limited purposes, may not use your Personal Data for any other purpose, and only in a manner consistent with our Privacy Policy.
• Compliance with laws and law enforcement entities - we cooperate with government and law enforcement officials and private parties to enforce and comply with law, rules and regulations. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including in connection to meeting national security or law enforcement requirements. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to  (i) respond to claims and legal process (including but not limited to subpoenas), (ii) protect our or a third party's property and rights, (iii) protect the safety of the public or any person, or (iv) prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable; (v) enforce our Terms; (vi) take precautions against liability; (vii) investigate and defend ourselves against any third-party claims or allegations;  and (viii) protect the security or integrity of the Services.
• Mergers, acquisitions and other business transactions – if Company enters into or becomes involves in a business transaction such as a merger, acquisition, reorganization, dissolution, bankruptcy, or sale of some or all of our assets, whether as a going concern or as part of bankruptcy, we may share your Personal Data in connection with such transaction or potential transaction.   Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Privacy Policy.
  

How we protect your information

We have implemented administrative, technical, and physical safeguards designed to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees, Providers and other third parties described in this Privacy Policy.

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.

Retention

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.

User rights

California User Rights

If you are a California resident, please click here for our California Privacy Notice.

EU/UK/Switzerland (collectively “EU+”) User Rights

The controller of all data collected by us through the Services is Snappy App, Inc.

As an EU+ resident, you may request to:

1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your Personal Data that is in our control.
4. Request erasure of your Personal Data.
5. Object to the processing of Personal Data by us.
6. Request to restrict processing of your Personal Data by us.
7. Lodge a complaint with a supervisory authority.

Please note that these rights pertain to EU+ 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

Users Outside the EU+ - Some of the aforementioned rights are applicable in certain jurisdictions outside the EU+ as well. Users residing outside the EU+ 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.

Transfer of data outside the EU+

If you reside in the EU+, please note that some data recipients may be located outside the EU+. 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 adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

Our policy towards 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 contact our Data Protection Officer (“DPO”) using the details below:

Email: dpo@snappy.com

Mailing address:
Snappy App Inc.
33 Irving Place, #5021
New York, NY 10003
United States

EU Representative

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.

UK Representative

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

This Privacy Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Services (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.