Privacy Policy

Your privacy is very important to us and we believe that it is our responsibility to keep your personal data private and confidential. In this document, we outline our privacy policy and your rights. If you need more information, please contact: legal@snapt.net.

1. Purpose

This Privacy Policy explains the way that Snapt, Inc., Snapt Systems (RF) (Pty) Ltd and their affiliates (collectively, "Snapt") handle information about you.

2. What Does This Policy Apply To?

This policy apply to personal information/ data that we collect about you, your company or employer in connection with:

• management of our customer relationship
• accounts you set up with Snapt.
• the sale, use, provision, distribution and resale of our products or services
• our certification and training programs
• our events and webinars
• our marketing and advertising initiatives
• management of our websites, products, services and technology in relation to the above.

In many cases, Snapt is considered a “controller” of the relevant personal information data (under EU General Data Protection Regulation (“GDPR”) and other similar laws) because Snapt determines how that data will be handled. Snapt, Inc. is typically the primary controller within the Snapt stable of companies and affiliates.

For certain products and services, Snapt may act only as a “processor” (not a controller) with respect to the personal data it collects. This means that Snapt handles the personal data solely pursuant to the relevant customer’s instructions, unless legally required to do otherwise. This will depend on a number of factors.

3. What Personal Information/Data Do We Process?

The personal information /data we collect and process from time to time includes:

• Contact details and professional details, such as name, email address, phone number, job title, and employer's name.
• Information about our users' experiences with Snapt products, services, events, webinars, and online forums and communities, such as Snapt Community
• Contact information derived from interactions with Snapt by our actual or prospective customers’ employees (e.g., interactions with customer service).
• Information about actual or prospective users' interests.
• Payment information for purchases with Snapt.
• information related to the browsers or devices you use to access our websites or services;
• your URL, IP address, internet browser and operating system;
• information relating to your use of our products and services;
• time spent on our website;
• where you originate from;
• recordings of calls you make to our customer support team
• other personal data collected in connection with our products and services and/or which you provide from to time.

We obtain personal data directly from you or your employer; third-party marketplaces where our products are offered (such as AWS and Google Cloud Platform); data brokers; marketing companies; referrals from customers, and users; and from publicly available sources such as company websites and LinkedIn. Through some products and services, we obtain personal data from our customers, or from individuals who interact with our customers or their online properties.

4. Non-Personal Data

Snapt collects and processes information / data that is not personal in nature. Snapt may also de-identify your personal data so that the information cannot be linked to you and is no longer personal data.
This may include data on how our products and services are used, as well as anonymized information or aggregated data about a group or category of services, features, or users which does not contain personal information.

We process and share this data for many reasons that are important to us, including to: help us understand customer needs and trends in usage of our products and services; improve and develop new products, services, websites, tools and content; monitor compliance with our terms of service; and advertising and marketing purposes. We do not share this data with third parties in a way that would enable them to identify you personally.

Our use and disclosure of non-personal data is not subject to this Privacy Policy, and we may use or disclose it for any reason permitted by law.

5. How does Snapt Use, Share and Process Personal Data?

Snapt uses, shares and processes personal data and information for the following purposes:

• To improve Snapt products and services
• To monitor usage of our products and services
• To monitor service levels and delivery standards
• To understand customer satisfaction levels
• To provide our products, services, events, websites, communities, training, and other business offerings.
• To process payments.
• To manage our relationships with customers, partners, resellers, distributors, event attendees, investors, and others (which may involve sharing personal data with them).
• For marketing, advertising, and other communications (including customizing those communications for specific recipients).
• To provide a third party (such as an employer) with confirmation or denial of an individual's claimed certification status.
• For surveys and other market research.
• For security, IT management, and related research.
• To enforce the legal terms that govern our business and commercial relationships
• To provide security and business continuity.
• To follow the law, or in other cases where we believe that using or disclosing the data is appropriate to protect the rights, safety, and property of Snapt or others
• For an actual or contemplated business sale, merger, consolidation, change in control, transfer of substantial assets, or reorganization, or due diligence in anticipation of such an event .
• For other purposes requested or permitted by our customers or users.

For those purposes, we may share personal data with, for example:

• our affiliates;
• our customers;
• third parties that assist us, event providers, payment processors, marketing providers, testing providers, analytics providers, providers of technical services (e.g., providers of data storage, data backup, and CRM systems), and other subcontractors;
• joint marketing partners;
• security researchers;
• employers and others who seek verification of an individual’s claimed certification status;
• entities involved in dispute resolution (such as an arbitrator or an opposing party);
• entities involved in potential or actual significant corporate transactions or events;
• governmental entities.

These uses and disclosures are also subject to our contractual obligations.

6. Why is Snapt Legally Allowed to Process my Information?

Our legal grounds include the following:

• Consent:
  
  • If the law requires consent, and in some other cases, we handle personal data on the basis of consent. For example, we conduct some of our direct marketing on the basis of consent.
  • If the law requires explicit consent, we use personal data on that basis.
  • If the law allows, we may be able to infer consent from the circumstances.
• Contractual Commitments
  Some of our handling of personal data is necessary to meet our contractual obligations to persons, or to take steps at the person's request because we are planning to enter into a contract with that person.
• Legitimate interests
  We handle personal data because it furthers the legitimate interests of Snapt (or of our customers, business partners, or suppliers) in business activities such as the ones listed below, and because that handling of data does not unduly impact your interests, rights, and freedoms:
  
  • Provide access and services to our customers and partners
  • Improving and developing our products and services
  • Understanding customer requirements
  • Providing cybersecurity and managing information technology assets
  • Protecting business activities, individuals, and property
  • Marketing and advertising (including sending certain direct marketing)
  • Analyzing and improving business activities
  • Managing risks and legal issues

7. What Rights Do You Have As a Data Subject?

Without limiting any rights that you may have under applicable data protection laws, you have the following rights if we collect and process information about you.

You have the right to ask us not to store your personal data for marketing purposes. Our marketing email messages, and certain other communications include instructions about how to unsubscribe, which you can use to limit or stop those communications. Alternatively, to remove your name from future mailings, please submit your request here or send your request in writing to: legal@snapt.net. Opt-out processes may take some time to complete, but we will work to meet your request as quickly as possible.

You cannot opt out of certain communications (such as billing-related communications or emergency service messages).

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us in writing at legal@snapt.net.

You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your personal data; (c) if you object to the use of your personal data and we don't have a good reason to continue to use it; or (d) if we haven't handled your personal data in accordance with our obligations.

You may contact us at the email address above with any concerns or complaints regarding our privacy practices, and you also may submit a complaint to the relevant governmental authority.

For your protection, we will only implement requests with respect to personal data after we have verified your identity to our satisfaction, taking into consideration the nature of your request.

8. Does Snapt use cookies and similar technology?

In our websites, emails and/or other applications, we and third parties may collect certain information by automated means such as cookies, web beacons, and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers, geolocation, other device information, Internet connection information, as well as details about your interactions with our apps, websites, and emails.

We and third parties may use these automated means to read or write information on your devices, such as in various types of cookies and other browser-based or plugin-based local storage or to collect pieces of information that together may uniquely identify your device.

Cookies and local storage are files that contain data, such as unique identifiers, that we or a third party may transfer to or read from your devices for the purposes described in this Privacy Policy, such as to recognize the devices, to improve your use of our website and services, for cybersecurity, to prevent fraud, to provide services, and for record-keeping, analytics, and marketing, depending on the context of collection.

These technologies help us:

• Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you.
• Remember your settings on the pages you visit so that we can display your preferred content the next time you visit.
• Display personalized content.
• Perform analytics, measure traffic and usage trends, and better understand the demographics of our users.
• Diagnose and fix technology problems.
• Plan for and enhance our business.

Also, in some cases, we assist with the collection of information by advertising services provided by third parties. The ad services may track your online activities over time by collecting information through automated means such as cookies, and they may use this information to show you ads that are tailored to your individual interests or characteristics and/or based on your prior visits to certain sites or apps, or other information we or they know, infer, or have collected from the users like you.

For example, we and these services may use different types of cookies, other automated technology, and data to:

• Recognize users and their devices.
• Inform, optimize, and serve ads.
• Report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to specific sites or apps).

You are able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent.

If you replace, change, or upgrade your browser, or delete your cookies, you may need to use these opt-out tools again.

9. For How Long Do We Store Your Personal Data?

We will retain personal data as long as necessary to fulfill the purposes outlined in this Privacy Policy unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described in this Privacy Policy, we make backups of certain data, which we may retain for longer than the original data.

10. Security

To help protect personal data, we have put in place physical, technical, and administrative safeguards. However, we cannot assure you that data that we collect will never be used or disclosed in a manner that is inconsistent with this Privacy Policy.

11. Additional detail for California residents

This Section applies only to “personal information” about California residents, as that term is defined in the California Consumer Privacy Act (“CCPA”), and it supplements the information in the rest of our Privacy Policy above. Data about individuals who are not residents of California is handled differently and is not subject to the same rights described in this Section. The provisions of this Section does not apply to data that Snapt handles in its capacity as a processor, even when such data is about a resident of California, or to other data or activities that are not subject to the relevant provisions of the CCPA.

Collection, Use, and Disclosure of California Personal Information:

During the 12 months leading up to the effective date of this Privacy Policy, Snapt collected all of the information described in our Privacy Policy. This information generally falls into the categories listed in the chart below, to the extent it is personally identifiable.

The chart also indicates the categories of third parties to whom we disclosed the data during the 12 months leading up to the effective date of this Privacy Policy.

CCPA Right to Access or Delete Personal Information

If you are a California resident, California law also may permit you to request that we:

• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we have about you.

Certain information is Exempt

For security and legal reasons, Snapt will not accept requests that require us to access third-party websites or services. We reserve the right to take steps verify your identity to our satisfaction before responding to your request, which may include, depending the type of request you are making, the sensitivity of any data you are requesting, and the nature of your relationship with us: verifying your name, asking you to click on a link that we send to your email address, requesting that you login to an account you maintain with us, or requesting that you provide us with information about our relationship that only you are likely to have.

You also may have the right to receive information about the financial incentives that we offer to you (if any). You also have certain rights under the CCPA not to be subject to certain negative consequences for exercising CCPA rights.

12. Links

The Snapt website and applications may contain links to third-party websites. We are not responsible for the privacy practices or the content of such websites.

Changes to this Policy

Snapt may change this Privacy Policy at any time, including to reflect changes in the law or our data practices. Any updated Privacy Policy will be accessible from the footer of our website or another convenient location.

13. Contact us

To request to exercise your data protection rights under data protection laws, or have any other request, question, or complaint, please email legal@snapt.net.
If you regarding your personal data or this Privacy Policy, please contact us at legal@snapt.net.

333 West San Carlos Street
San Jose, CA 95110

Data Protection Officer

Aalia Manie
legal@snapt.net
333 West San Carlos Street
San Jose, CA 95110