Snappic Privacy Policy

INTRODUCTION

 

This is the privacy policy of Three Commas Proprietary Limited (we or us). We respect your privacy and are committed to protecting your personal information. This privacy policy (together with our end-user licence agreement (EULA)) and any additional terms of use incorporated by reference into the EULA), applies to your use of:

  • Snappic Booth mobile application software (App) available on the Apple App Store (App Site), once you have downloaded or streamed a copy of the App onto your handheld device;
  • Any of the services accessible through the App that are available on the App Site or other sites of ours; and
  • Our website, getsnappic.com (regardless of where you visit it from).

This privacy policy will tell you about your privacy rights and how the law protects you.

Our website and our App are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This privacy policy supplements the other notices and is not intended to override them.

It is also important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

We review this privacy policy regularly and occasionally may need to change or update it.  Any updated versions will be posted on the website and will be effective from the date of posting.  This privacy policy was last updated on the 25th of May 2020. Where appropriate, you will be notified by email OR when you next start the App or log onto the website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App 

CONTROLLER

Three Commas Proprietary Limited is the controller and is responsible for your personal information.

OUR CONTACT DETAILS 

Three Commas Proprietary Limited is a limited company with company number 2015/440326/07 and registered office at 11B Riley Road, Eastwood Office Park, Unit 7 Eastwood Office Suites, Bedfordview, Johannesburg Gauteng 2008, South Africa.

info@getsnappic.com

Third Party Links

This website and our App may include links to third-party websites, plug-ins and applications, partner networks, advertisers and affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. Accordingly, we have no responsibility for the content and activities of these linked sites and hereby disclaim any and all liability of any nature whatsoever and howsoever arising which may arise from the products and/or services procured from such third parties.  Nonetheless, we seek to protect the integrity of our site and welcome any feedback our site visitors may have about these sites and their content.

If you are an EU citizen, Section A will apply to you.  If you are a US citizen, Section B will apply to you. The information relating to cookies and Google Advertising at the end of this privacy policy applies to everyone.

Section A: EU Citizens

We may collect, use, store and transfer different kinds of personal information about you and process the following about you:

Identity information – such as your first name, maiden name, last name, username or similar identifier, title, date of birth and gender;

Contact information – such as your postal or billing address, email address and telephone numbers;

Financial information – such as your bank account and payment card details;

Transaction information – such as details about payments from you and other details of products and services that you may have purchased or ordered from us and details of in-App purchases;

Device information – such as the type of mobile device that you use;

Content information – such as information stored on your device including friends’ lists, login information, photos, videos or other digital content, check-ins;

Technical information – such as information from your visits to our website, App Site or our App, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices that you use to access our website;

Profile information – such as your username and password, in-App purchase history, your interests, your preferences, feedback and survey responses and your Facebook or Twitter handles;

Usage information – including information about how you use our website, App Site or App including but not limited to traffic data whether this is required for our own billing purposes or otherwise;

Marketing and communications information – includes your preferences in receiving marketing from us and our third parties and your communication preferences; 

Location information – includes your current location disclosed by GPS technology; and/or

Biometric information – facial recognition information.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We use different methods to collect information from and about you including through:

Information you give us. This is information that you consent to giving us about you by filling in forms on the App Site and/or our website getsnappic.com, or by corresponding with us (for example by email or chat). It includes information when you register to use the App Site, download or register an App, subscribe to any of our services, make an order on our website, search for an App or service and when you report a problem with our App or website. If you contact us we will keep a record of that correspondence.

Information we collect about you and your device. Each time you visit our website or use our App we will automatically collect personal information including device, content and usage data. We collect this data using cookies and other similar technologies. As you interact with our website, we may automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and/or

information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources. We may receive information about you from various third parties and public sources as set out below:

Device data from analytics providers, advertising networks, search information providers;

Contact, financial and transaction data from providers of technical, payment and delivery services;

Identity and contact data from data brokers or aggregators; and/or

Identity and contact data from publicly available sources.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate certain of your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.

 

COOKIES

 

We use cookies to distinguish you from other users of the App, our website, the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our website and also allows us to improve the App and our website.

 

HOW WE USE YOUR PERSONAL INFORMATION

 

We will only use your personal information when the law allows us to do so. Most commonly we will use your personal information in the following circumstances:

to administer and protect our business, website and App, including troubleshooting, auditing and monitoring its use;

to install the App and register you as a new App user;

data analysis, system maintenance and support and survey processes;

to register new customers of our business who have signed up to our website and/or our App;

to process your order including managing payments, fees and charges and in-App purchases;

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

to monitor trends so that we can improve the App and our services to you;

to notify you about changes to our service, terms or privacy policy;

to deliver relevant website and/or App content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;

to ensure that content from our website and App is presented in the most effective manner for you and for your device;

to make suggestions and recommendations to you about goods or services that may be of interest to you; and/or

if you are an attendee at an event and have your photograph taken through the use of our App, we will use your personal information (including your name, email, telephone number, Facebook or Twitter handles) to share your photograph to your social media account. With your consent, we will collect facial recognition markers to tag you in photographs taken using our App. You can withdraw your consent at any time. We may also process aggregated personal information gathered from photographs taken using our App for the purpose if quantifying photograph metrics of an event and to provide richer analytics.

 

We use your personal information on the following bases:

  • where you have consented before the processing;
  • to perform a contract that we are about to enter or have entered with you so that we can provide our services to you;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
  • where we need to comply with a legal or regulatory obligation. 

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means. We also take into account legal and regulatory requirements which require the retention of personal information for a minimum period of time, limitation periods for taking legal action, good practice and our general business purposes.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may be required to share your personal information with certain trusted third parties in accordance with certain contractual obligations that we have with them and to assist us in providing you with our services, including:

  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • analytics and search engine providers that assist us in the improvement and optimisation of our website and/or App;
  • when you submit personal information to download our App, your personal information might not only be disclosed to us, but it might be disclosed to the Appstore provider (possibly automatically through its operating software), your mobile network operator, or a payment processing services provider (if the App is not free of charge);
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacypolicy; and/or
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions, contracts and other agreements; or to protect the rights, property, or safety of Three Commas Proprietary Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

HOW WE PROTECT YOUR PERSONAL INFORMATION

 

We have put in place appropriate technical, organisational and security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. All information you provide to us is stored on our secure servers or processed through a gateway provider.

 

Any payment transactions carried out by us or our third party provider of payment processing services will be encrypted via Secure Socket Layer (SSL) technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website or our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

Once we have received your information, we will use strict procedures and security features to try to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way.

 

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

 

We will only keep your personal information for as long as necessary to fulfil the purposes we collected it for.

 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means. We also take into account legal and regulatory requirements which require the retention of personal information for a minimum period of time, limitation periods for taking legal action, good practice and our general business purposes.

 

INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

 

We may transfer your personal information to third parties who provide services to us (for example data storage providers) including those who are situated outside of the European Union. Whenever we transfer your personal information out of the European Union we ensure a similar degree of protection is afforded to it. In particular, if we use storage providers in the US, we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information data between Europe and the US.

 

Please contact us if you want further information on the specific mechanisms used by us when transferring your personal information out of the European Union.

 

YOUR RIGHTS

 

If you are a European citizen:

 

You have certain rights under the European Union’s General Data Protection Regulations and other data protection laws in relation to your personal information. You can:

 

  • request access to your personal information and how we process it;

 

  • request correction of the personal information that we hold about you;

 

  • ask us to delete your personal information;

 

  • object to us processing your personal information;

 

  • request the restriction of processing of your personal information;

 

  • request the transfer of your personal information to you or to a third party; and/or

 

  • withdraw consent at any time where we are relying on consent to process your personal information.

 

However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our services to you. We will advise you if this is the case at the time you withdraw your consent.  Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

 

If you are a South African citizen:

 

  • You have the right to contact us at any time requesting:
    • confirmation that we have your personal data;
    • access to the records containing your personal data or a description of the personal data that we hold about you; and
    • the identity or categories of third parties who have had, or currently have, access to your personal data.
  • When making a request, we require adequate proof of your identity.

 

  • We will try to provide you with suitable means of accessing information, where you are entitled to it, by for example, posting or emailing it to you.

 

  • There may be instances where we cannot grant you access to your personal data. If we refuse access, we will give written reasons for our refusal.

 

  • If you believe that any personal data that we hold about you is inaccurate, irrelevant, outdated, incomplete or misleading, you may ask us to correct it. If you believe that any personal data that we hold about you is excessive or has been unlawfully obtained or that we are no longer authorised to retain it, you may ask us to destroy or delete it.  We will consider if the personal data requires correction, deletion or destruction and if we do not agree that there are grounds for action, you may ask us to add a note to the personal information stating that you disagree with it.

 

  • We may charge a reasonable fee to cover our administrative and other reasonable costs in providing personal data to you. We will not charge you for simply having made the request or for making any corrections to the personal information.

Section B: US Citizens

 

 

Section B of this privacy policy has been compiled for the benefit of those visitors to our website and/or customers who are concerned with how their Personally Identifiable Information (PII) is being used online.  PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.  Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle the PII which we obtain from your visits to our website and/or use of our products.

 

What PII do we collect from the people that visit our blog, website or App?

 

When ordering from, or registering on our website as a customer, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, Facebook or Twitter handle or other details to help you with your experience.

 

When using our App at an event, users will be asked to enter their email, phone number, Facebook or Twitter handle in order to share their photographs to their social media.

 

When do we collect PII?

 

We collect PII from you when you register on our site, place an order, subscribe to a newsletter, respond to a survey, fill out a form or enter information on our site.

 

We collect information from users of our App when they make use of the application at an event.

 

How do we use the PII which is collected?

 

We may use the PII we collect from customers and/or users of the SNAPPIC application in the following ways:

 

  • to personalise the customer’s and/or user’s experience and to allow us to deliver the type of content and product offerings in which our customer’s and/or user’s are most interested;

 

  • to administer a contest, promotion, survey or other site feature; and/or

 

  • to send periodic emails regarding your order or other products and services.

 

 

How do we protect PII?

 

All PII collected by us is stored in secured networks and is only accessible to a limited number of persons who (a) have a need to access such information, (b) have special access rights to such systems, and (c) are under an obligation to keep the PII strictly confidential.  In addition, all sensitive and/or credit information which is supplied to us is encrypted via Secure Socket Layer (SSL) technology.

 

In addition to the above, we implement a variety of security measures when a user enters, submits or accesses their information to maintain the safety of the PII.

 

All transactions are processed through a gateway provider and are not stored or processed on our servers.  All PII collected by us is hosted on our service provider’s servers in the United States of America.

 

California Online Privacy Protection Act (CalOPPA)

 

CalOPPA is the first state law in the United States of America to require commercial websites and online service providers to post a privacy policy on their website.  The CalOPPA’s reach stretches well beyond California and requires a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California based consumers to post a conspicuous privacy policy on its website:

  • stating exactly what information is being collected and those individuals with whom it is being shared; and
  • to comply with this policy.

 

For more information on the CalOPPA, please follow this link http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf.

 

Please note that this privacy policy constitutes our privacy policy in accordance with CalOPPA.  Furthermore, and in accordance with CalOPPA we agree to the following:

 

(1)        visitors to our site can visit our site anonymously;

(2)        a link to our privacy policy is available on our home page;

(3)        our privacy policy link includes the word “Privacy” and can be easily found on our home page;

(4)        visitors to our site will be notified of any privacy policy changes on our Privacy Policy Page; and

(5)        visitors to our site and users of the SNAPPIC application are able to change their personal information by emailing us at the following email address: info@getsnappic.com.

 

Do you disclose the PII you collect to Third-Parties?

 

We do not sell, trade or otherwise transfer the PII of our customers to third parties without the prior consent of such customers.

 

When a customer hosts an event, however, we do share certain of the PII gathered from users of the App with the relevant customer.  The PII which is shared in this regard includes a user’s name, screen name or user names, phone number and/or email address.  These details are made available to the customer for download so that they can have a better understanding of what demographic has attended their event.  Please note however that this PII is only shared with the customer if the user of the SNAPPIC application has consented to such information being shared.

 

How does our website handle do no track signals?

 

We honour do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

 

Does our website allow third party behavioural tracking?

 

We do allow third-party behavioural tracking.

 

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control.  The Federal Trade Commission, the United States of America’s consumer protection agency, enforces the COPPA Rule which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

In compliance with the provisions of COPPA, we do not specifically market our products to children under the age of 13.

Fair Information Practices Principles

The Fair Information Practices Principles form the backbone of privacy law in the United States of America and the concepts they include have played a significant role in the development of data protection laws around the globe.  Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with the Fair Information Practices Principles, should a data breach occur we will notify the affected parties of such data breach via email within seven business days of such data breach occurring.

We also agree to the Individual Redress Principle which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law.  This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN-SPAM Act

The CAN-SPAM Act is a law that:

  • sets the rules for commercial email;
  • establishes requirements for commercial messages;
  • gives recipients the right to have emails stopped from being sent to them; and
  • spells out tough penalties for violations.

To be in accordance with the CAN-SPAM Act we agree to the following:

  • we will NOT use false or misleading subject lines or email addresses in any communications with you;
  • in the event that our message to you is an advertisement, we will identify the message as an advertisement in some reasonable way;
  • we will include the physical address of our business or site headquarters in all communications with you;
  • we will monitor third party email marketing services for compliance with the CAN-SPAM Act, if such third party email marketing service is used;
  • we will honour opt-out/unsubscribe requests quickly; and
  • we will allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails from us, you can email us at info@getsnappic.com and we will promptly remove you from ALL correspondence.

Snappic Cookie Policy 

What are “cookies” and do we use them?

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow it to do so) that enables the site’s or service provider’s systems to recognise your browser and capture and remember certain information.  For instance, we use cookies to help us remember and process the items in your shopping cart.  They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services.  We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use the following cookies:

  • Strictly necessary cookies.These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of any e-billing services.
  • Analytical or performance cookies.These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies.These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies.These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

Can I disable cookies?

Yes.  You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies.  You do this through your browser’s (like Internet Explorer) settings.  Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify and/or disable your cookies.

Please note however that if you disable cookies in your browser some of our website’s features that make your site experience more efficient will be disabled and some of our services will not function properly.  You will however still be able to place orders through the website.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles.  These principles are put in place to provide a positive experience for users and can be accessed at the following link: https://support.google.com/adwordspolicy/answer/1316548?hl=en.

We use Google AdSense Advertising on our site.

Google, as a third-party vendor, uses cookies to serve advertisements on our site.  Google’s use of the DART cookies enables it to serve ads to our users based on previous visits to our site and other sites on the Internet.  Users may opt-out of the use of the DART cookie by visiting the Google Advertising and Content network privacy policy which can be accessed at the following link:

https://www.google.com/policies/technologies/ads/.

With regards to Google, please note that we have implemented the following on our site:

  • remarketing with Google AdSense; and
  • demographics and interests reporting.

We, along with third party vendors such as Google, use first-party cookies (such as Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our site.

 

Opting out

Visitors to our site can set preferences for how Google advertises to you using the Google Ad Settings page.  Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

 

Contacting us

If there are any questions regarding this privacy policy, you may contact us using the information below:

www.getsnappic.com

11B Riley Road

Eastwood Office Park

Unit 7 Eastwood Office Suites, Bedfordview

Johannesburg, Gauteng 2008

South Africa

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