This Privacy Policy describes how we at Snappy App, Inc. and its subsidiaries and affiliates (“Snappy,” "us", "we," “our” and/or "Company") handles the Personal Data (meaning any information which may potentially allow your identification with reasonable means) of our users (each, a "User" or "you") who access, download, install, register, use or engage with our website or platform (the "Website" and "Platform," respectively) or any other service we provide or make available online or offline including through customer support channels, and in-person promotional activities (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 Personal Data 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.
With respect to the information that our enterprise customers collect from you and provide to us either directly or on their behalf (“Service Data”), we process such information only as a service provider/data processor on behalf of our customers in connection with their business. Our customers are the businesses that control the use of the Service Data and determine the purposes for which we process such information. Those customers are responsible for their own practices in collecting, using, and disclosing information they collect from you. To learn more about our customers’ use of your information and your rights that you may have over such information, please consult the privacy policy of the applicable company.
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.
Click on the links below to jump to the different sections of our Privacy Policy:
Information We Collect Directly
Information We Collect Automatically
How Do We Use The Data We Collect?
With Whom Do We Share Your Personal Data?
How We Protect Your Information
When you use our Services (including, without limitation, when you sign up for an account), you consent to the collection, storage, use, disclosure and other uses of your Personal Data 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 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.
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 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, 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:
Cross-Device Matching. We may now or in the future have the ability to match a User’s devices using the data collected, making educated predictions, and, in some cases, using deterministic data (e.g., unique identifiers) or other content across devices. We may then, subject to the limitations otherwise set forth in this Privacy Policy and applicable law, display targeted advertisements to you across your devices unless it is an Opted-Out Device (as defined below) as further described in YOUR CHOICES below.
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.
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.
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 privacy@snappy.com. 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.
Interest-Based Advertising Opt-Out. Third parties, such as ad networks, web analytics companies, and social networking platforms (some of whom are discussed elsewhere in this Privacy Policy), may collect information about your online activities over time and across our Website and other third-party online properties or services. These companies may use information about your visits to our Website and other sites, and general geographic information derived from your IP address, in order to provide advertisements about goods and services of interest to you. For more information about third-party advertisers and how to prevent them from using your information, please visit https://www.networkadvertising.org/choices/. This is a site offered by the Network Advertising Initiative ("NAI") that includes information on how consumers can opt out from receiving interest-based advertising from some or all of NAI's members. You can also visit https://www.aboutads.info/choices, which is a site offered by the Digital Advertising Alliance ("DAA") that includes information on how consumers can opt out from receiving internet-based advertising from some or all of DAA's participating companies. Opting out of interest-based advertising does not mean that you will no longer see any advertisements. Rather, you will still see advertisements that are general and not tailored to your specific interests and activities. Further, cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt-out will not necessarily be effective on your mobile device. In the event we are performing cross-device matching (as described above), once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes and we will not use data from another device for interest-based advertising purposes on the Opted-Out Device.r enter into legal agreements ensuring an adequate level of data protection.
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 privacy@snappy.com.
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:
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 Requests
If 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:
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.
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.
If you wish to exercise any of the aforementioned rights, or receive more information, please submit a request here, or contact us at privacy@snappy.com or at the following mailing address:
Mailing address:
Snappy Gifts
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.
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.
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 Revised" heading). You are advised to check for updates regularly. All changes to this Privacy Policy 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.
