Last updated 30 January, 2020.
The Personal Data we collect varies based on who you are and what you choose to share with us. When you contact us or interact with our Service we collect categories of Personal Data as follows:
When you create an account or start using the Service, we will generally collect your name, email, phone number, mailing address, your address book (if you are a Customer and you consent), and, if you are a Photographer, profile information (including a photograph and a description of your expertise).
We collect certain payment and billing information needed for us to (i) pay Photographers and (ii) accept payments from Customers. This information may include billing address, payment card or PayPal details, and, if you are a Photographer, your social security or tax identification number. We collect Payment Data via secure payment processing services.
We collect details relating to shoots you book through the Service (i.e., the time and place of the shoot) and we collect and store the photographs that Photographers take for Customers. In addition, Customers in certain jurisdictions can make use of tools enabled by facial recognition. (Please note that facial recognition tools are only available in Australia and certain areas of the United States.) These tools will identify similar faces in the Customer’s photographs. The Customer can then tag someone, at which point the Service will identify the other photographs in which the tagged person appears and allow the Customer to easily share those photographs with the tagged person.
We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing this information is optional to you.
We have pages on social media sites like Instagram, LinkedIn, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us through your settings on the Social Media Site, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
We may receive information about Customers from third parties based on their professional email address, including your job title, employer, and location of work.
For Photographers, we may collect information from third-party service providers in connection with performing background checks.
When you visit, use and interact with the Site or App, we may automatically receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Site, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation pattern.
The following information is created and automatically logged in our systems when you use the Site:
The following information is automatically logged in our systems when you use the App:
We use Personal Data to provide the Service, including to connect allow Customers to book photoshoots, to ensure Photographers are paid, and to facilitate the transmission of photographs from Photographers to Customers. This processing is necessary to perform our contract with you.
We also use Personal Data as necessary for the following legitimate business interests:
For information about what we mean by legitimate interests and the rights of individuals in the European Union (“EU”), please see the “EU Users” section below.
We may contact you to provide information we believe will be of interest to you. For instance, if you elect to provide your email address, we may use that information to send you promotional information about our products and services. If we do, where required by law, for example if you are in the EU, we will only send you such emails if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving emails by following the instructions contained in each promotional email we send you or by contacting us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Service and to respond to your requests.
In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:
To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors, including database, infrastructure, integration, and hosting providers; email communication providers; data and background check providers; customer support and customer relationship management services; payment processors; marketing partners; and analytics services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
If required to do so by law or in the good faith belief that such action is necessary to (i) comply with legal or regulatory obligations, including to respond to lawful requests from public authorities and to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Site, or the public, or (v) protect against legal liability.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you need to change or correct your Personal Data you may contact us. We will address your request as required by applicable law.
California Civil Code Section § 1798.83 permits users of our Site that are California residents to request the categories of Personal Data we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties. These requests may be made once per year. To make such a request, please email us at email@example.com or write us at:
101 California Street, Suite 2710, San Francisco CA 94111.
The following disclosures are intended to provide additional information to California residents about (1) the categories of Personal Data we collect, (2) the sources of Personal Data we collect, (3) how we use each category of Personal Data, and (4) how we disclose Personal Data. Nothing in this Notice limits our ability to use or disclose information as described above.
We do not and will not sell your Personal Data.
To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the Personal Data we collect:
• The right to know what Personal Data we have collected and how we have used and disclosed that Personal Data;
• The right to request deletion of your Personal Data;
• The right to be free from discrimination relating to the exercise of any of your privacy rights.
In order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Data for verification. If we cannot verify your identity, we will not provide or delete your Personal Data.
You may submit a request to know or a request to delete your Personal Data through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.
Our Service is not directed to children who are under the age of 16. Snappr does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Snappr through the Service please contact us using the details in the “Contact Us” section below and we will endeavor to delete that information from our databases.
This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway, the United Kingdom, and, to the extent applicable, Switzerland).
Snappr is the data controller for the processing of your Personal Data. You can find our contact information in the “Contact Us” section below.
Pursuant to the European Union General Data Protection Regulation (or GDPR), you have the following rights in relation to your Personal Data, under certain circumstances:
Please see the “Contact Us” section below for information on how to exercise your rights.
Where we transfer your Personal Data out of the EU we will take steps to ensure that your Personal Data receives an adequate level of security protection where it is processed and your rights continue to be protected. Some of our service providers (such as Google, LLC, Freshworks, Inc., and SendGrid, Inc.) are certified to the Privacy Shield framework for data transfers (for more information visit https://www.privacyshield.gov/welcome). For more information, please contact us as described below.
You use the Service at your own risk. We comply with industry standards to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Snappr via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.