LAST UPDATED: December 10, 2018
Collection and Storage
We process, store and transmit User Provided Information and Automatically Collected Information (each as defined below).
We store all information on servers located in the United States. If You reside outside of the United States, please be aware that Your information will be transferred to, and processed and stored in, the United States consistent with commercial online privacy standards in the United States or in other countries where We have facilities or where We have engaged a service provider. This storage, maintenance or processing will be performed under privacy and security laws and standards that may not be as protective as those in your jurisdiction.
User Provided Information
The Mobile Application obtains the registration information that You provide when You access the Mobile Application. Registration is mandatory in order to be able to use the features of the Mobile Application.
When You register with Us, You fill out a form that requires information such as Your name, the name of Your employer or company, Your SNAGG userID and password (or Your Facebook or Twitter ID, if You prefer), Your email address, and the CRM system You use (“User Provided Information”).
Automatically Collected Information
In addition, the Mobile Application may collect certain information automatically, such as the brand and type of the mobile device, its unique device ID, its IP address, its operating system, the user agent string, and the SNAGG URLs visited (“Automatically Collected Information”). We do not ask You for, access or track any location based information more specific than city from Your mobile device at any time while downloading or using our Mobile Application.
The Automatically Collected Information is collected when You send feedback, roam with Your mobile device, and/or access SNAGG records from the Mobile Application.
We may collect information about Your usage of, and interaction with, the Mobile Application, such as the searches conducted, the features used, and/or the pages viewed.
We may occasionally send You through the Mobile Application service-related push notifications that may be of importance to You. You may at any time opt-out from receiving these types of communications by turning them off at the device level through Your mobile device settings.
1) HOW WE USE THE COLLECTED INFORMATION
User Provided Information
We may use the information that You provide to Us through the registration process for product notifications, marketing communications, and/or research as follows:
To perform the SNAGG Services. Communications about the services that You requested, including administrative and service notification emails and communications about the features allowed based Your subscription level.
For marketing purposes. For example, We may contact You to discuss Your interest in SNAGG or send You promotional communications or other information regarding SNAGG and its partners, which may be customized based on Your usage patterns.
For research and analytics purposes. We may use aggregated usage data to understand utilization and improve the Service.
Automatically Collected Information
We may use Automatically Collected Information as follows:
Calendar Events. If You participate in a meeting through the Mobile Application, We may retrieve the attendees’ email address from the participant list in the related calendar entry so that You can display information about those who are participating in the meeting, unless You have opted out from this option.
Maintenance and Fraud Purposes.We may use IP addresses to help diagnose problems with Our server, to administer the Site, and/or for fraud prevention.
R&D. We may use Your mobile device information and usage information, such as the searches conducted, the features used, the pages viewed, and for our internal research and development purposes.
2) WITH WHOM WE SHARE INFORMATION
We may disclose the information We have collected:
To Our service providers.We may have contracts with third parties to provide products or services in connection with the services that are offered through the Mobile. As a result, We may share Your personal information with those third party service providers but only in connection with providing services to You. For example, We share Your phone number or email with third parties in order to communicate with You or when You register with SNAGG. We require these third parties to use Your personal information for the specific purpose for which We have retained them and to use appropriate security measures to protect Your personal information.
To Our business partners.
As required by law. Such as to comply with a facially valid judicial or governmental subpoena, warrant, legal process or other order or other decree that has asserted its lawful authority to obtain the information. Except in cases where prohibited by law enforcement agents or judicial decree, SNAGG will notify the affected Customer(s) of such disclosures.
Protections/Fraud Investigations. If We believe in good faith that disclosure is necessary to protect our rights, protect Your safety or the safety of others, or investigate fraud.
Business Transfer. If a company sells a substantial portion of its assets or equity including through a merger or acquisition, goes out of business, or enters bankruptcy, user and/or customer information is typically one of the business assets transferred in connection with such a transaction. In such an event You will be notified via email and/or by a prominent notice on our website of any change in ownership, uses of Your personal information, and choices You may have regarding Your personal information. You acknowledge that such transfer may occur and that any acquirer of SNAGG may continue to use Your personal information as set forth in this Mobile Policy.
3) WHAT ARE MY OPT-OUT RIGHTS?
The following options are available for users of the Mobile Application:
Opt-out of all information collection by uninstalling the Mobile Application. You can stop all collection of information by the Mobile Application by uninstalling the Mobile Application. You may use the standard uninstall processes as may be available as part of Your mobile device or via the Mobile Application marketplace or network.
Opt-out of receiving promotional information. If You wish to opt-out from receiving promotional communications on Your mobile device, You may opt-out by contacting Us at email@example.com.
If You are using our cost-free services, please be aware that by opting out, You may no longer be able to continue using our Services.
Administrators of paid Services may not opt-out of receiving administrative notices that are not promotional in nature.
4) ACCESS AND DELETION RIGHTS
All individuals have the right to obtain confirmation that We hold Your personal information and access to any personal profile and/or User Provided Information that we hold about him or her. To request access, addition and/or correction of Your personal profile and/or User Provided Information, please contact Us as indicated in the “How to Contact Us” section of this policy. We will respond to Your request within a reasonable time in accordance with our internal policies on access, addition or correction to profiles and sources of information.
Registered users of the Service can access their profile page from their mobile device and from their computer to update or change Your registration information by editing Your user or organization record. To update a user profile, please click on “My Profile” or email Us at firstname.lastname@example.org if You require any assistance.
Registered users of the Service can request that the information collected about them be deleted by contacting Us as indicated in the “How to Contact Us” section of this policy. We will disconnect access to information stored in our database to the extent reasonably feasible. However, We may retain and use users’ personal information as reasonable or necessary to comply with our legal obligations, resolve disputes, and enforce our contracts.
5) DATA RETENTION POLICY, MANAGING YOUR INFORMATION
User Provided Information
We will retain User Provided Information for as long as You use the Mobile Application and for a reasonable time thereafter. If You would like Us to delete User Provided Information, please contact Us as indicated in the “How to Contact Us” section of this policy. Please note that some or all of the User Provided Information may be required in order for the Mobile Application to function properly, and We may be required to retain certain information by law.
Automatically Collected Information
We will retain Automatically Collected Information for so long as You keep an account on SNAGG. However, the data may be overwritten by more recent Automatically Collected Information.
We do not make the Mobile Application available for the purpose of knowingly soliciting data from, or to market to, children under the age of 13. If a parent or guardian becomes aware that his or her child has provided Us with information, he or she should contact Us as indicated in the “How to Contact Us” section of this policy. We will delete any such reported and verified information from our files within a commercially reasonable timeframe.
7) MOBILE ANALYTICS
We use mobile analytics software to allow Us to better understand the functionality of the Mobile Application. This software may record information such as how often You use the Mobile Application, the events that occur within the Mobile Application, aggregated usage, performance data, and the app store from which the Mobile Application was downloaded. This information is for internal analytics purposes only, and, while we do store some personal information You have submitted within the Mobile Application, such access is restricted.
8) EU-U.S. PRIVACY SHEILD AND SWISS-U.S. PRIVACY SHIELD
SNAGG adheres to the EU – U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of all personal data transferred from the EU and Switzerland to the United States. We have certified adherence to the Privacy Shield Principles in respect of all personal information received in reliance on the Privacy Shield. To learn more about the Privacy Shield, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
SNAGG is responsible for the processing of personal data it receives under the Privacy Shield and subsequent transfers to a third party acting as an agent on its behalf, unless we prove that we are not responsible for the event giving rise to the damage. We commit to giving you an opportunity to opt out if personal information we control about you is to be used for a purpose materially different from those that are set out in this Policy.
With respect to personal data received or transferred pursuant to the Privacy Shield, SNAGG is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SNAGG may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have any questions or concerns regarding our data use or our Privacy Shield certifications, you can contact us using the contact information provided below and we will respond within 45 days of receipt. If we do not address your concern satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
We are concerned about safeguarding the confidentiality of User Provided Information. For this reason, We use physical, electronic, and procedural safeguards to protect the information that We process and maintain. Such measures include, but are not limited to, limited and controlled access by employees, physical security for servers and data, and use of security software and hardware (such as virtual private clouds and encryption).
User Provided Information is stored in protected databases on SNAGG servers. Only the user, user’s administrator, and SNAGG authorized support personnel have access to the user information.
User passwords are used to secure access to the SNAGG service and subscriber information. We encrypt the transmission of user IDs and passwords using Transport Layer Security (TLS). We send a cookie to the mobile device to remember the user for automatic log in. The login page provides a service for registered users to obtain a new password in case they forget their password.
Sensitive information entered on our registration or order forms will be encrypted in transit using TLS.
Please be aware that, although We endeavor to provide reasonable security for information We process and maintain, no security system can prevent all potential security breaches. . SNAGG will not be liable for unauthorized disclosure of profile or other information that occurs through no fault of SNAGG, including, but not limited to, error in transmission, misuse of a subscriber’s password and login credentials, a subscriber’s failure to comply with its security obligations, the unauthorized acts of SNAGG’s employees or third parties. If You have any questions about security on our Site, You can contact us at email@example.com.
10) LINKS TO OTHER SITES
This Policy may be updated from time to time. If we make any material changes to this Policy we will notify You by email (sent to the email address specified in Your account) or by posting a notice on our Site or Mobile Application, or comply with other procedures as required by applicable laws, prior to the change becoming effective.
Please remember to consult this Policy regularly for any changes. Your continued use of the Mobile Application after the effective date of a change will be deemed an acceptance of the new terms.
12) HOW TO CONTACT US
If You have any questions regarding privacy while using the Mobile Application, or have questions about our practices, please contact Us via email at firstname.lastname@example.org or by mail at: SNAGG Technologies Inc., Attn: Legal / Privacy Officer, 43 West 23rd Street, 2nd Floor, New York, NY 10010 USA.