This Privacy Policy explains the way that Snapt, Inc., Snapt Systems (RF) (Pty) Ltd and their affiliates (collectively, "Snapt") handle information about you.
This policy apply to personal information/ data that we collect about you, your company or employer in connection with:
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.
The personal information /data we collect and process from time to time includes:
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.
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.
Snapt uses, shares and processes personal data and information for the following purposes:
For those purposes, we may share personal data with, for example:
These uses and disclosures are also subject to our contractual obligations.
Our legal grounds include the following:
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.
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:
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:
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.
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.
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.
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.
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 classification, and explanation, of the California personal information we collected. |
Categories of third parties to whom we disclosed it. |
| Identifiers (such as name, address, email address and other contact information). |
|
| Commercial information (such as information about an individual’s interests and interactions with Snapt, our partners, or our customers, including transaction data). | Same as first row. |
| Financial data (such as payment information). | Same as first row. |
| Categories of personal information described in California Civil Code Section 1798.80(e). | Affiliates, testing providers, providers of technical services (e.g., providers of data storage, data backup), other subcontractors, and governmental entities. |
| Internet or other network or device activity (such as IP addresses, device identifiers, Cookie data, device attributes, device usage information, browsing information, metadata, and other information described in Section 7 of our Privacy Policy or Service-specific Privacy Statements). | Same as first row. |
| Geolocation information. | Same as first row. |
| Professional or employment related data (such as title). | Same as first row. |
| Other information that identifies or can be reasonably associated with an individual. | Same as first row. |
| Inferences drawn from any of the above. | Same as first row. |
If you are a California resident, California law also may permit you to request that we:
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.
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.
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.
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
Aalia Manie
legal@snapt.net
333 West San Carlos Street
San Jose, CA 95110