Last Updated: May 1, 2024
We, at Snappy App, Inc., together with our affiliated companies (collectively: “we”, “us” or “our”) put great efforts to make sure that we secure personal data related to you and use it properly.

The term “personal data” refers to any information relating to an identified or identifiable natural person.

This notice applies to personal data about you (“you”) that we collect, process, use, and retain in connection with:
  • your use of our websites (“Websites”), available at: www.snappy.com and www.snappygifts.com, and any of their sub-domains, including any data you provide through registration and contact pages (“Website Visitor”). See additional details below on the various types of end-users to which this privacy notice applies below;
  • our marketing activities, including registrations as part of webinars, conferences, events, demo requests, emails, etc.;
  • your use of our gifting platform (“Services”) to facilitate the sending of gifts (“Gift Sender”), either on your own behalf or as an end-user facilitating the sending of gifts on behalf of our customers (each, a “Customer”); and
  • your use of our Services when receiving a gift from a Gift Sender (“Gift Recipient”).
The following Notice at Collection and Summary will provide you with a quick and clear view of our practices.

Please take the time to read our full privacy notice, and if you do not agree with its terms, please do not access or otherwise use the Website and Services.

NOTICE AT COLLECTION AND SUMMARY

THE PRIVACY NOTICE

What Types of Personal Data Do We Process?
We receive, collect, and store any information you enter on the Websites and Services or give us in any other way. 

Below is a description of the categories of personal data related to you that we process, categorized by the type of interaction:
Personal Data We Process About Gift Senders and Website Visitors
Usage and Interactions
We automatically collect and process data on how you use the Services and Websites to help us improve them. 

Such information includes: the Internet Protocol (IP) address used to connect your device to the Internet; mobile ad identifier (or similar unique identifiers); login; email address; password; access device and connection information such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform. Additionally, we also collect and process data on how you interact with any of our emails or other communications, including if you have opened and engaged with such communications.

We store and process such data automatically by using cookies and other tracking technologies. To learn more about how and why we use cookies and other tracking technologies, please read our cookie notice, available here: https://www.snappy.com/legal/cookies.
Marketing and Communication Preferences
We collect and process data about whether you want to receive marketing communications from us and what your communication preferences are.
Third Party Data
We collect and process data we get from third parties, including our business partners, service providers, and publicly available information.

Depending on your interaction with our Website and Services, such information includes: your full name, physical address, email address, place of employment and additional employment-related information.
Support
When you contact us to receive support, we process your full name, contact information, any other data you choose to provide us, and data related to your use of the Websites and Services to provide you with support.
Feedback
When you provide us with feedback via the Services or the Website, we will collect any personal data you choose to provide as part of the feedback.
Contacting Us
When contacting us via registration forms, contact forms, or email, we will collect your full name, email address, phone number, and any other information you choose to provide us.
Additional Personal Data We Process About Gift Senders
Creating an Account
When creating an account to use our Services, we will collect your full name and email address, as well as your chosen password.

The Services can also include an option to register using your existing personal or work email account or other social media account, such as your Google account. If you choose to log in or connect to the Services using your existing email account or social media account, we will process your social media account information, including your profile picture.
Sending a Gift
When you send a Gift, you will provide us with the relevant Gift Recipient’s contact details, including email address and at your option – phone number, and the Gift Recipient’s shipping addresses. 

Note that you are responsible to inform and provide this notice to the Gift Recipients you are sending gifts to.
Payments
When we offer you to use an online payment service, as a paying Customer, we will receive your payment transaction details (for example: your name, contact information, address, the amount paid, and the date of payment) from the payment service provider that processed your payment.
Customer Onboarding
We process personal data as part of on-boarding processes to send gifts, including information we obtain from third parties to complete on-boarding compliance checks.
When you receive Services-related training from us, we collect and process data about training you received.
Surveys
While using our Services, you may choose to participate in optional surveys. These surveys may ask for demographic information such as gender, race, and ethnicity. We use this data to improve our understanding of our user base, to ensure our services are inclusive and to publish aggregated demographic insights.
Sales Cycles and Fulfilling Orders
Financial Incentive Programs
We record meetings, correspondence, and other communication channels, including by screen capture, for monitoring, compliance, quality assurance, training, and other purposes. 

We also video record or screen capture training seminars, presentations, and webinars for the same purposes.

Specifically, we also make use of sessions replay software to monitor interactions with our Services and Demos (see below). Such activities can capture and record keystrokes, mouse movements, page visits, form field entries, etc. We only use this information for compliance verification and service improvement.
Demos
When booking a demo of our Services, we will collect your full name, email address, and company name.

When booking or during the demo, we will also collect any additional data you choose to provide us, and we will also record, including by screen capture, your use of the demo. See additional information above under “Meeting Recordings.”
Shipping Your Gift
Recipients’ Platform (‘My Gifts’)
When creating an account to use our Services, we will collect your full name and email address, as well as your chosen password.

The Services can also include an option to register using your existing personal or work email account or other social media account, such as your Google account. If you choose to log in or connect to the Services using your existing email account or social media account, we will process your social media account information, including your profile picture.
We collect and process data about whether you want to receive marketing communications from us and what your communication preferences are.
Your Responsibilities

‍If you give us personal data about someone else through use of the Services, you must do so only with that person’s express authorization. 

You must inform them how we collect, use, disclose, and retain personal data related to them according to this privacy notice before you provide us with such personal data.

Minors

‍Our Services and Websites are not meant for users under the age of 16.

We reserve the right to request proof of age, via a recognized identification method, at any stage so that we can verify that minors are not using our Services or Websites without appropriate consent. 

If we become aware that a minor is using our Services as a Gift Sender, we will prohibit and block the individual from accessing the Services until the individual’s guardian consents to their use of the Services. 

If you are a parent or legal guardian, and you believe that your child or ward has provided us with personal data without your consent, please contact us at privacy@snappy.com.
Why Do We Process Personal Data?
We commit to process personal data related to you solely for the purposes described in this privacy notice.

Below is a description of the purposes for which we process personal data about you, categorized by the type of interaction:
With Whom Do We Share Personal Data, and Why?
We will share personal data related to you only subject to the terms of this privacy notice, or subject to your prior consent.

We do not sell personal data to others for monetary or other consideration. However, we engage service providers to help us provide the Website and market our Services.  U.S. laws may consider our sharing of data for these purposes as Selling or Sharing of personal information. 

At any time, you can opt out of the collection of personal data by such service providers by contacting us or by visiting our “Your Privacy Rights” webpage. 

We share personal data related to you with our vendors and with third-party service providers which process personal data related to you on our behalf in connection with the provision of the Website and Services. 

For example:
  • Marketing and Business Development. To deliver our marketing and business development campaigns we will share information with digital marketing providers, social media and advertising companies, market research partners, potential customers, event organizers and registration providers, and other trusted vendors who assist in the performance of our marketing campaigns.
  • Sales, Finance, Business Operations and Delivering Service. We use (A) third-party sales tools to track pipeline activity and order information, (B) finance and invoicing tools to assist in managing orders, customer billing and fulfillment, (C) legal and compliance tools to assist in our contracting and compliance activities, (D) consultants, contractors, and other specialists to provide professional services, and, (E) other vendors which support our business operations.
Such vendors and service providers are contractually bound to keep personal data related to you confidential and appropriately secure.

As a Gift Recipient, we will also share personal data that you provide us with the relevant Gift Sender, for billing purposes, gift monitoring, fraud detection, and other purposes related to sending you the gift.  

We will also share personal data related to you with our affiliates, meaning companies within the Snappy group (subsidiaries, sister-companies, and parent companies), and with certain employees and external service providers, as necessary to provide you with our Websites and Services, operate our business and improve your service experience, as further detailed under this notice. We require all such parties to only process personal data related to you in accordance with the terms of this notice.

We will need to disclose personal data related to you, as we believe to be necessary or appropriate:
  • under applicable law, including laws outside your country of residence;
  • to comply with legal process;
  • to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
  • to enforce our terms and conditions;
  • to protect our operations or those of any of our Affiliates;
  • to protect our rights, privacy, safety, interests, or property, and/or that of our affiliates, you, or others;
  • if we are involved in any discussions related to the sale or merger of all or part of our business; and,
  • to allow us to pursue available remedies or limit the damages that we can sustain.
A merger, acquisition, or any other structural change will require us to transfer personal data related to you to another entity, as part of the structural change, provided that the receiving entity complies with this privacy notice.
How Long Will We Retain Personal Data?
We retain different types of personal data related to you for different periods, depending on the purposes for processing the information, our legitimate business purposes, and pursuant to legal requirements under applicable law.

We will maintain your contact details, to help us stay in contact with you. At any time, you can contact us to delete your contact details by submitting your request here. Note that we will keep your details without using them if necessary, and for the necessary period of time, for legal requirements and proceedings.

We will retain personal data related to you after you have terminated your use of the Services, if retention is reasonably necessary to resolve disputes between our users, to prevent fraud and abuse, or to enforce this privacy notice and our terms and conditions, available here.

We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information in identifiable form.

In any case, we will keep information about you for as long as you use the Services, unless applicable law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this privacy notice and our terms and conditions.
What Are My Choices?
We will give you choices about the ways we use and share personal data related to you, and we will respect the choices you make.

Opting Out of the Services

‍You can 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 submitting your request here. 

Please note that even if you unsubscribe from marketing or promotional emails, we can continue to send you service-related updates and notifications or reply to your queries and feedback you provide us. 

We can also still use and share such 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 notice), can collect information about your online activities over time and across the Services and other third-party online properties or services.

These companies can use information about your visits to the Services 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.

Opt-Out Preference Signals – Specific Jurisdictions

‍In jurisdictions where required by law, we respond to opt-out preference signals from web browsers, and we will comply with these requirements. In such jurisdictions, you can stop using the Services at any time, thereafter we will stop collecting personal data related to you. You can also request that your account with us be terminated, and that personal data related to you be deleted by contacting us.

Any termination of your account will involve deletion of your account information from our live databases and all the information and data stored for the account in the service. When we process personal data related to an individual who is our customer’s customer, we handle the deletion request in collaboration and discussions with our customer. You can request a copy of the personal data related to you that we store about you by contacting us.

When we delete personal data related to you that we have collected from or about you, it will be deleted from our active databases, but we will keep a reasonable number of copies in our archives. Although we will deactivate your account, we will continue to retain the personal data related to you for legitimate business purposes as set forth above.

If you wish to exercise any of your rights in relation to personal data related to you, including exercising your choices or opt out rights in applicable jurisdictions, please submit a request here.
What Are My Privacy Rights and How Do I Exercise Them?
To exercise the access, data portability, and deletion rights described under this privacy notice, please submit a request here.

Only you or a person authorized to act on your behalf can make a request related to personal data related to you. 

Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note that the sections below provide a description of rights you may have under specific laws applicable to our processing of personal data related to you. Under other laws, you may have similar rights applicable to our processing of personal data related to you. 

In such cases, we will provide you with similar rights to those detailed under the section entitled ‘Processing of Personal Data Under the Laws of the EEA, UK, and Switzerland’, with the necessary changes made.

You may request to exercise such rights by submitting your request here.
Processing Under Specific Laws
Processing of Personal Data Under U.S. Privacy Laws

‍This section applies solely to all Services and Website visitors, users and others who reside within the United States of America. We have adopted this section to comply with U.S. state privacy laws, and any terms defined under U.S. state privacy laws will have the same meaning when used in this section. This section supersedes any contradicting provisions under the other sections of this privacy notice.

‍Categories of Personal Data

‍In the preceding twelve (12) months we have collected the personal data related to you which is described above under the section “What Types of Personal Data Do We Collect?” of this privacy notice. Such Information consists of the following categories:
  • Identifiers and Personal data categories listed in the applicable laws, such as the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Services.
  • Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Inferences drawn from any of the above-mentioned information.
Categories of Sensitive Data

Our Services are not intended to collect sensitive information (within the meaning of U.S. Privacy Laws).

However, as further detailed above, if you choose to electively participate in our surveys, we may ask for demographic information about you, such as gender, race, and ethnicity. 

Categories of Data Sources

We obtain the categories of personal data related to you listed above from the following categories of sources:
  • Directly and indirectly from you and your activity on the Services and the Website.
  • Third parties such as reliable service providers.
We use the personal data related to you that we collect or receive for the purposes mentioned under this privacy notice.

We disclose personal data related to you to third parties for business purposes as described above under the section titled “With Whom Do We Share Personal Data?”. 

Selling and Sharing Personal data

We do not sell personal data to others for monetary or other consideration. However, we engage service providers to help us provide the Website and market our Services.  U.S. laws may consider our sharing of data for these purposes as Selling or Sharing of personal information. 

At any time, you can opt out of the collection of personal data by such service providers by contacting us or by visiting our “Your Privacy Rights” webpage.

Your Rights under U.S. Privacy Laws

In addition to your rights under other sections under this privacy notice, if you are a resident of California or any other applicable US State, you are entitled also to the following specific rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) or other applicable US state consumer privacy acts, regarding personal data related to you:
  • Access to specific personal data and data portability rights – you have the right to request that we disclose certain information to you about our collection and use of personal data related to you over the past 12 months preceding your request. Upon verification of your request, we will disclose to you:
  • The categories of personal data we collected about you.
  • The categories of sources for the personal data we collected about you.
  • Our business or commercial purpose for collecting that personal data.
  • The categories of personal data that we disclosed for a business purpose, and the categories of third parties with whom we disclosed that particular category of personal data.
  • The specific pieces of personal data that we collected about you.
  • If we disclose personal data related to you for a business purpose, we will provide you with a list which will identify the personal data categories that each category of recipient obtained.
  • Deletion rights – you have the right to request that we delete any personal data related to you. Upon confirmation of your request, we will delete personal data related to you from our records, unless an exception applies.
  • Opt-out of Selling or Sharing – you have the right to opt-out of the sale or sharing of personal data related to you, or otherwise the use of such data for targeted advertising or profiling for the purpose of making decisions that produce legal or similarly significant effects concerning you. As detailed above, We do not sell your personal information to others for monetary or other consideration. However, we engage service providers to help us provide the Website and market our Services.  U.S. laws may consider our sharing of data for these purposes as Selling or Sharing of personal information. At any time, you can opt out of the collection of personal data by such service providers by contacting us or by visiting our “Your Privacy Rights” webpage.
  • Non-discrimination – you also have a right not to be discriminated against for exercising your rights under applicable United States privacy laws.
  • Limit the Use of Sensitive Personal Data – you have the right to limit our use of sensitive personal data related to specific purposes detailed under applicable United States privacy laws. As detailed above, we only collect sensitive personal data (within the meaning of United States privacy laws) when you participate in one of our elective surveys, such as your ethnic origin or gender. We only use such data to verify and maintain the quality of our Services, and to improve, upgrade, and enhance the Services in a way that will make them more inclusive. Accordingly, we do not provide you with an option to limit our use of such sensitive personal data, as we already use it solely for permitted purposes under applicable United States privacy laws. If you have further questions about our use of sensitive personal data about you, please contact us at privacy@snappy.com.
We cannot respond to your request or provide you with the requested personal data if we cannot verify your identity or authority to make the request and confirm the personal data related to you. We will only use the personal data provided in your request to verify your identity or authority to make the request.

We will do our best to respond to your request within 30 days of its receipt. If we require more time (up to an additional 30 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such a decision and provide you with a cost estimate before completing your request.

We will not require that you create an account in order to exercise your rights under this privacy notice and we will not increase the cost, or decrease the availability, of the Services based solely on the fact that you have chosen to exercise one of your rights herein. 

After receiving our reply, you can appeal against our decision by contacting us. We will review your appeal and provide you with our answer and our explanation of the reasons for our decision(s) within 60 days of receiving it. We will also provide you with a link (to the extent available) where you can submit a complaint with the relevant State Attorney General.

Processing of Personal Data Under the Laws of the EEA, UK, and Switzerland 

‍If European Economic Area (EEA), the United Kingdom (UK), and Switzerland data protection laws apply to the processing of the personal data related to you by us, then the following terms apply. This section supersedes any contradicting provisions under the other sections of this privacy notice. 

‍Lawful Grounds

‍Where we process personal data related to you when you visit or use the Services, our processing activities are based on the following lawful grounds: 
  • All processing activities of personal data related to you which are not based on the lawful grounds indicated below, are based on your consent. 
  • We will process personal data related to you to comply with a legal obligation and to protect your and others' vital interests. 
  • We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes: 
  • Communications with you in the following circumstances:
  • Where you contact us through the Services and other digital assets.
  • After you sign up for our marketing or newsletter.
  • After you, on behalf of your company, sign up for any of the Services.
  • Cyber security.
  • Support, customer relations, service operations, service improvement.
  • Fraud detection and misuse of the Services.
Your Rights

‍In addition to your rights under other sections in this privacy notice, you have the following rights:
  • At any time, contact us if you want to withdraw your consent to the processing of personal data related to you. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
  • Request to delete or restrict access to personal data related to you. We will review your request and use our judgment, pursuant to the provisions of applicable law, to reach a decision about your request. 
  • If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you can request to be informed that third parties that hold personal data related to you, in accordance with this privacy notice, will act accordingly.
  • You can ask to transfer personal data related to you in accordance with your right to data portability. 
  • You can object to the processing of personal data related to you for direct marketing purposes. Additional information about this right is available under the “What Are My Choices?” section in this privacy notice. 
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
  • You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR. 
A summary and further details about your rights under European Union data protection laws, is available on the European Union Commission's website available at: Rights for citizens | European Commission (europa.eu).

Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us with credentials to make sure that you are who you claim to be and will further ask you some questions to understand the nature and scope of your request. 

If we need to delete personal data related to you following your request, it will take some time until we completely delete residual copies of personal data related to you from our active servers and from our backup systems. 

If you have any concerns about the way we process personal data related to you, you are welcome to please submit your request here. We will look into your inquiry and make good-faith efforts to respond promptly. 
‍
Data Protection Team and European Union and United Kingdom Representatives

Our Data Protection Team can be reached at: privacy@snappy.com.

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. 

Pursuant to Article 27 of the United Kingdom General Data Protection Regulation (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.
Where Do We Store Personal Data?
We store and process information, including personal data, either directly or using third parties, such as data hosting service providers, in the European Economic Area, the United States, and in other regions to support the Services. The laws of the territories where personal data will be stored and processed can differ from the laws of the jurisdiction in which you live.

If you are located in the European Economic Area (EEA), note that we will transfer personal data related to you to other jurisdictions, which are not deemed to provide an adequate level of data protection. In such case, we will use appropriate safeguards, in particular, by way of entering into the European Union Standard Contractual Clauses as amended from time to time with the relevant recipients, or by adhering to equivalent data transfer regulations to protect the security and confidentiality of such personal data.

You can obtain a copy of the suitable safeguards that we use when transferring personal data as described above or receive further information about data transfer by submitting your request to privacy@snappy.com.  

We make sure that our third-party service providers provide us with adequate confidentiality and security commitments, and we will take all steps reasonably necessary to ensure that personal data related to you is treated securely and in accordance with this privacy notice.
Do We Use Cookies?
We or our third-party partners can store some information on your device or device hard drive as a cookie or similar type of tracking technologies (such as beacons, pixel tags, etc.) to collect data related to use of the Services.

You can set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. However, if you set your browser to disable all cookies, some features of the Services cannot function properly. 

‍To learn more about how and why we use cookies and other tracking technologies, please read our cookie notice, available here: https://www.snappy.com/legal/cookies.
Aggregated and Analytical Data
We use anonymous, statistical, or aggregated information and will share it with our partners for legitimate business purposes. 

It has no effect on your privacy because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically with you.

In addition, we work with third-party service providers who use the technologies described in this section to conduct website and service analytics to help us track and understand how visitors use the Services. One such provider is Google Analytics, a web analytics service provided by Google, Inc., and its privacy practices are subject to its own privacy policies, available here: https://policies.google.com/privacy?hl=en-US.
Information Security
We are committed to ensuring the security of personal data. 

Accordingly, we and our hosting services implement systems, applications, and procedures to secure personal data related to you, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

These measures provide sound industry standard security. However, no security system is impenetrable, and although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
Changes to this Privacy Notice
From time to time, we will change or update this privacy notice.

Where the changes or updates have minor, if any, consequences, they will take effect 7 days after we post a notice. Where the changes or updates have substantial consequences, they will be effective 30 days after we initially posted the notice.

Until the new privacy notice takes effect, if it materially reduces the protection of your privacy right under the then-existing privacy notice you can choose not to accept it and terminate your use of the Services.

Continuing to use the Services after the new privacy notice takes effect means that you agree to the new privacy notice.

Note that if we need to adapt the privacy notice to legal requirements, the new privacy notice will become effective immediately or as required by law.
Contact Us
If you have any questions about this privacy notice, or if you believe that your privacy rights are compromised, please email privacy@snappy.com.  

We can only process requests received with sufficient information to enable us to process your request. If we need to request additional information in order to complete your request, we will do so. If you do not provide sufficient information initially and do not respond to our request for additional information, we will not be able to complete your request.

Please note that email communications are not always secure, so please do not include any sensitive information in your emails to us.
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