LAUNCH APRIL 1
LAUNCH APRIL 1
Version: 1.02
Last Updated: March 28, 2025
This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.
TABLE OF CONTENTS
1. General Provisions
2. Use of Information
3. Information We Collect
4. How We Process Your Information
5. SMS Policy
6. Specific Legal Bases for Information Processing
7. Sharing of Personal Information
8. Cookies and Tracking
9. International Transfer of Information
10. Duration of Information Storage
11. Information Security
12. Minors
13. Privacy Rights
14. Controls for Do-Not-Track Features
15. U.S. State-Based Privacy Rights
16. Third Party Analytics
17. Updates to this Privacy Policy
1.1 Purpose. This privacy policy (“Privacy Policy”) for OneRoof App, Co. (referred to herein as “OneRoof”, “Snag”, “Company”, “we”, “us”, “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our Platform or Services.
1.2 Scope. This policy applies when you:
1.2.1 Visit or access Snag’s website (https://www.joinsnag.com/) or any site, application, product, or service of ours that links to this Privacy Policy;
1.2.2 User or access our Platform or Services; or
1.2.3 Engage with us in other related ways, including through sales, marketing, events, or social media.
1.3 Concerns. Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, you should not use our Platform or Services.
2.1 Personal Information. When you visit, use, access, or navigate our Platform or Services, we may process personal information depending on how you interact, the choices you make, and the products and features you use. We may process your data or personal information to serve our legitimate business interests, including, without limitation, to allow Users to interact with our Services. By way of example, but not limitation, we may use User information and data for:
2.1.1 Creation and administration of your account;
2.1.2 Corresponding or communicating with you;
2.1.3 Identifying Users;
2.1.4 Allowing Users to Identify One Another;
2.1.5 Displaying your usage information to other Users or third parties;
2.1.6 Enabling you to access parts of the Services;
2.1.7 Enabling you to connect with or communicate with other Users;
2.1.8 Enabling you to communicate with Snag;
2.1.9 Performing analytics, debugging, and conducting research;
2.1.10 Providing customer service training;
2.1.11 Sending you messages, updates, security alerts, and account notifications;
2.1.12 Allowing you to send or receive communications or data;
2.1.13 Personalizing and customizing your experience based on your interactions with the Services;
2.1.14 Allowing you and other Users to see “friends” or “contacts” (including those that are mutual between Users) including through your voluntary sharing of your contacts;
2.1.15 Displaying your usage information to other Users or outside parties in an anonymized or aggregated format in which you cannot be specifically identified as an individual to improve the Services or to provide trends and insights;
2.1.16 Sending you messages from time to time through the Services to provide you with useful information.
2.2 Sensitive Personal Information: We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
2.3 Third-Party Information. We may receive information concerning our Users from third parties and information about third parties from our Users.
2.4 Processing Information. We process your information to provide, improve, and administer our Platform and Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid reason to do so.
2.5 Sharing Information. We may share your information in specific situations with certain third parties or other Users of our Platform or Services.
2.6 Information Safety: We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
2.7 Phone Number; Contacts. At sign-up, Snag will request that you share your phone number for account verification. Once you have verified, Snag will ask that you share your contacts from your device. You are not obligated to share your contacts, but certain features of the Services will not be accessible to you unless and until you share your contacts. Many of Snag’s features are based on identification of shared contacts you have with other Users. Once you have granted Snag permission to access, import, and store your contacts, Snag may periodically import and store your contacts to improve your experience with the Services. Snag uses information about your contacts and connections to provide and improve our Services.
2.8 Your Rights. Depending on where you are located geographically, applicable privacy laws may mean you have certain rights regarding your personal information.
2.9 Exercising Your Rights. The easiest way to exercise your rights is by reading and following this Privacy Policy, or by contacting us according to your specific rights set forth herein. We will consider and act upon requests as required by applicable data protection laws.
3.1 Personal Information Provided by You. We collect personal information that you voluntarily provide to us when you register to access the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.
3.2 Types of Personal Information: The personal information we collect may include the following:
3.2.1 Names
3.2.2 Phone numbers
3.2.3 Email addresses
3.2.4 Contact or authentication data
3.2.5 Contact preferences
3.2.6 Photos
3.2.7 Social Media Handles
3.3 Sensitive Information. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
3.4 Information Automatically Collected. When you visit our Services, we may collect information such as your Internet Protocol (IP) address and/or browser and device characteristics. We may automatically collect certain information when you visit, use, access, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
3.5 Third Parties and Cookies. Like many businesses, we may also collect information through cookies, web beacons, flash cookies, pixels, and similar technologies.
3.6 Additional Information. We may collect the following additional information:
3.6.1 Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers may automatically collect when you access or use our Services and which we may record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Services (by way of example but not limitation, date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take and which features you use), and device event information (such as system activity, error reports – sometimes called "crash dumps", and hardware settings).
3.6.2 Device Data. We may collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
3.6.3 Location Data. We may collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. If you choose to opt out, you may not be able to use certain aspects of the Services.
3.6.4 Second-Party User Contextual Data. Data analyzed and determined from user contact and role information, such as name, phone number, social media handles, and photos.
4.1 Purpose. We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
4.1.1 To facilitate account creation and authentication or otherwise manage User accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order;
4.1.2 To deliver and facilitate delivery of services to each User. We may process your information to provide you with requested aspects of the Services;
4.1.3 To respond to User inquiries and/or offer support to Users. We may process your information to respond to your inquiries and to solve any potential issues you may have with the Services;
4.1.4 To send administrative information to you. We may process your information to send you details about our products and Services, changes to our Terms and policies, and similar information;
4.1.5 To fulfill and manage your orders or payments. We may process your information to fulfill and manage orders or payments made through the Services;
4.1.6 To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. Additionally, to provide, maintain, and manage our Services, ensuring they function as intended;
4.1.7 To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm;
4.1.8 To communicate. To communicate with you or other Users regarding updates, offerings, and to respond to inquiries and feedback;
4.1.9 To enhance the Services. To improve the functionality and security of our Platform and Services, including upgrading features and enhancing user experience;
4.1.10 To comply with legal obligations. To comply with legal requirements, enforce our Terms of Use, and protect our rights as well as those of our Users.
5.1 Generally. By providing your phone number or otherwise providing express consent, consistent with our Terms of Use, you have consented to receive SMS text messages from us regarding promotional, transactional, and informational communications related to Snag’s Platform, Services, and events.
5.2 Use of Information. We use your mobile phone number solely for the purpose of sending you SMS messages as described in this Policy.
5.3 Personalization. We may use information you provide, including, without limitation, preferences and usage data, to personalize your experience and improve our services.
5.4 Data Aggregation. We may aggregate and analyze usage data for statistical purposes without identifying individual Users.
5.5 Compliance with TCPA and CTIA Guidelines
5.5.1 TCPA Compliance. We strictly adhere to the TCPA by ensuring that:
5.5.1.1 All SMS marketing messages are sent only to Users who have provided explicit consent;
5.5.1.2 You are provided with clear instructions on how to opt-out (e.g. “Reply STOP to unsubscribe”);
5.5.1.3 All messages include the identity of the sender.
5.5.2 CTIA Guidelines. We follow CTIA’s best practices by:
5.5.2.1 Clearly disclosing message frequency and associated costs, if applicable;
5.5.2.2 Including opt-out instructions in every SMS message;
5.5.2.3 Ensuring that any promotional SMS campaigns are conducted in a manner consistent with CTIA guidelines, including not sending messages outside of permissible hours (e.g. between 8 a.m. and 9 p.m. local time).
5.6 Opt-Out and Help Instructions. At any time, you may opt-out of receiving further SMS messages by replying “STOP” to any message. Once you opt-out, you will no longer receive SMS communications from us, except as required to confirm your opt-out, unless and until you resubscribe to receive SMS messages from us.
5.7 Help. If you require assistance or more information about our SMS program, you may contact us at hi@joinsnag.com.
5.8 Security; Data Retention.
5.8.1 Security. We take reasonable measures to protect your mobile number and any other personal data from unauthorized access, disclosure, or misuse;
5.8.2 Data Retention. We will retain your information only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable law.
5.9 Third-Party Service Providers. We may share your information with third-party service providers solely for the purpose of delivering SMS communications. These providers are contractually obligated to safeguard your information and use it only for the purposes for which it was disclosed.
6.1 Generally. We only process your personal information when we believe it is necessary and we have a valid legal basis to do so under applicable law, like with your consent, to comply with laws, to provide you with Services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
6.2 EU or UK. If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases to process your personal information:
6.2.1 Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
6.2.2 Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations, including providing our Services or, at your request, prior to entering into a contract with you.
6.2.3 Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests where those interests do not outweigh your interests and fundamental rights and freedoms. By way of example but not limitation, we may process your personal information for some of the purposes described herein to diagnose problems and/or prevent fraudulent activities.
6.2.4 Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
6.2.5 Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the life, health, welfare, or safety of any person.
6.3 Canada. If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time by emailing us at hi@joinsnag.com. In certain exceptional circumstances, we may be legally authorized under applicable law to process your information without obtaining your consent. Such circumstances may include, but are not limited to, the following:
6.3.1 If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
6.3.2 For investigations and fraud detection and prevention;
6.3.3 For business transactions provided certain conditions are met;
6.3.4 If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
6.3.5 For identifying injured, ill, or deceased persons and communicating with next of kin;
6.3.6 If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
6.3.7 If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
6.3.8 If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
6.3.9 If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
6.3.10 If the collection is solely for journalistic, artistic, or literary purposes;
6.3.11 If the information is publicly available and is specified by regulations.
7.1 Personal Information. We may share information in specific situations described in this section and/or with the third parties as set forth herein. Our Services may include links to third-party websites, which are not governed by this Privacy Policy. We may share your personal information in the following situations:
7.1.1 Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company;
7.1.2 Third Parties. We may share or transfer your information with third-party service providers who support our business operations;
7.1.3 Legal Obligations. We may share or transfer your information to comply with legal obligations, court orders, or governmental requests;
7.1.4 Rights. We may share or transfer your information for the protection of our rights, privacy, safety, or property, and/or that of our affiliates, you, or others;
7.1.5 Sale. We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
8.1 Cookies and Tracking Technologies. We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
9.1 International Transfers. We may transfer, store, and process your information in countries other than your own.
9.2 Servers. Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by third parties with whom we may share your personal information in the United States or in other countries.
9.3 EEA, UK or Switzerland. If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland,, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.
10.1 Retention Period. We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements, including in anticipation of litigation).
10.2 Deletion or Anonymization. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
11.1 Security Measures. We aim to protect your personal information through a system of organizational and technical security measures. We have implemented robust and state-of-the-art security measures to ensure data is protected against unauthorized access, alteration, disclosure, or destruction, aimed to protect the security of personal information we process. These measures include, without limitation, encryption, security audits, and stringent access controls. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and other personal information will be encrypted using SSL technology. If we have given you (or you have chosen) a password for access to certain parts of our Services, you are responsible for keeping that password confidential.
11.2 Limitations. Despite safeguards, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will endeavor to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
12 MINORS
12.1 Minors. The Services are not intended for children under 18 years of age. We do not knowingly solicit to or collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor-dependent’s use of the Services.
12.2 Reporting and Deletion of Data of Minors. If we become aware that personal information from persons under the age of 18 has been collected, or if we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. We will deactivate the account of any person we discover to be under the age of 18 and will take reasonable measures to promptly delete corresponding data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hi@joinsnag.com.
13.1 Rights by Region. In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. These rights may include the ability to review, change, or terminate your account at any time.
13.2 Exercise of Rights. In some regions (such as the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:
13.2.1 to request access and obtain a copy of your personal information;
13.2.2 to request rectification or erasure;
13.2.3 to restrict the processing of your personal information;
13.2.4 if applicable, to data portability; and
13.2.5 to not to be subject to automated decision-making.
In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at hi@joinsnag.com. We will consider and act upon any request in accordance with applicable data protection laws.
13.3 EEA, UK, Siwtzerland Data Complaints. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
13.4 Withdrawing Consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by updating your in-app consent preferences or by emailing us with a request to withdraw consent at hi@joinsnag.com. Please be advised that this will not affect the lawfulness of information processing before consent withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
13.5 Marketing Opt-Out. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by updating your in app preferences for marketing communications. We may still communicate with you — including, without limitation, to sending you Services-related messages that are necessary for the administration and use of your account, to respond to requests, or for other non-marketing purposes.
13.6 Account Information. If, at any time, you would like to review or change the information in your account or terminate your account, you may do so through your account in our Platform.
13.7 Termination Request. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases within a reasonable time period. Notwithstanding the foregoing, we may retain some or all information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our terms, or comply with applicable legal requirements including those regarding the preservation of information in anticipation of potential litigation.
13.8 Cookies and Similar Technologies. Many browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies or to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
14.1 Do-Not-Track. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.
14.2 Current Practices. At this time, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
15.1 State-Based Privacy Rights. If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you have specific rights regarding access to your personal information.
15.2 Categories of Personal Information We Collect. We may collect the following categories of personal information:
We will use and retain the collected personal information as needed to provide the Services or for the following time periods unless required to retain same for longer to comply with legal obligations:
15.2.1 Category A - As long as the user has an account with us;
15.2.2 Category B - As long as the user has an account with us;
15.2.3 Category F - As long as the user has an account with us;
15.2.4 Category H - As long as the user has an account with us;
15.2.5 Category I - As long as the user has an account with us;
15.2.6 Category L - As long as the user has an account with us. Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
15.2.7 Receiving help through our customer support channels;
15.2.8 Participation in customer surveys or contests; and
15.2.9 Facilitation in the delivery of our Services and to respond to your inquiries
15.3 Sharing, Use, and Retention of Personal Information. We may disclose your personal information with our service providers pursuant to a written contract between us and any such service provider, and we may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information. Your personal information may be stored on third-party servers with industry-leading vendors such as Amazon, Google, or Microsoft and may be sold, shared, or communicated to third-parties consistent with this Privacy Policy.
15.4 California Residents. California Civil Code Section 1798.83, also known as the “Shine The Light” law permits our users who are California residents to request and to obtain from us, once a year and free of charge, information about categories of personal information (if any) we have disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. At this time, we do not share user information with third parties for marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to hi@joinsnag.com. If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us at hi@joinsnag.com to furnish all necessary information for your request, including a statement that you reside in California. After processing your request, we will make sure your data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
15.4.1 CCPA Privacy Notice. This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
15.4.1.1 Residents Definition. The California Code of Regulations defines “residents” as: every individual who is in the State of California for other than a temporary or transitory purpose and every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as “non-residents.” If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
15.4.1.2 Personal Data Rights. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
15.4.1.3 Right to be Informed. Depending on the circumstances, you have a right to know:
15.4.1.3.1 whether we collect and use your personal information;
15.4.1.3.2 the categories of personal information that we collect;
15.4.1.3.3 the purposes for which the collected personal information is used;
15.4.1.3.4 whether we sell or share personal information to third parties;
15.4.1.3.5 the categories of personal information that we sold, shared, or disclosed for a business purpose;
15.4.1.3.6 the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
15.4.1.3.7 the business or commercial purpose for collecting, selling, or sharing personal information; and
15.4.1.3.8 the specific pieces of personal information we collected about you.
15.4.1.4 Limitations on Obligations. In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
15.4.1.5 Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. We will not discriminate against you if you exercise your privacy rights.
15.4.1.6 Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct the business to limit its use of your sensitive personal information to that use which is necessary to perform the Services, if the business collects any of the following:
15.4.1.6.1 social security information, drivers' licenses, state ID cards, passport numbers;
15.4.1.6.2 account login information;
15.4.1.6.3 credit card numbers, financial account information, or credentials allowing access to such accounts;
15.4.1.6.4 precise geolocation;
15.4.1.6.5 racial or ethnic origin, religious or philosophical beliefs, union membership;
15.4.1.6.6 the contents of email and text, unless the business is the intended recipient of the communication;
15.4.1.6.7 genetic data, biometric data, and health data;
15.4.1.6.8 data concerning sexual orientation and sex life.
15.4.1.7 Our Limitations. Once we receive your request, we are no longer allowed to use or disclose your sensitive personal information except as otherwise required by law unless you provide consent for the use or disclosure of sensitive personal information for additional purposes. Publicly available information and sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right. To exercise your right to limit use and disclosure of sensitive personal information, please contact us at hi@joinsnag.com.
15.4.2 Identity Verification. Upon receiving a request from you regarding your information, we may need to verify your identity to determine whether you are the same person about whom we have information in our system. Such verification efforts may require us to ask you to provide information, so that we can match it with information you have previously provided us or that we already have on file, or we may contact you through a communication method (e.g., phone or social media) that you have previously provided to us. We may also use other verification methods as specific circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will endeavor to avoid requesting additional information from you for the purposes of verification. If we cannot verify your identity from the information already maintained by us, however, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will not retain such additionally-provided information longer than necessary after completing verification.
15.4.3 Other Privacy Rights. You may object to the processing of your personal information. You may request correction of your personal data if it is incorrect or no longer relevant, or you may ask us to restrict the processing of the information. You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
15.4.4 Opt Out. You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
15.4.5 Exercise of Rights. To exercise these rights, please contact us at hi@joinsnag.com.
15.5 Colorado Residents. This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
15.5.1 You have the right to be informed whether or not we are processing your personal data;
15.5.2 You have the right to access your personal data;
15.5.3 You have the right to correct inaccuracies in your personal data;
15.5.4 You have the right to request deletion of your personal data;
15.5.5 You have the right to obtain a copy of the personal data you previously shared with us;
15.5.6 You have the right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
15.5.7 Exercise of Rights. To exercise these rights, please contact us at hi@joinsnag.com. If we decline to take action regarding your request and you wish to appeal our decision, please contact us at hi@joinsnag.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
15.6 Connecticut Residents. This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. These rights are not absolute, and in certain cases, we may decline your request as permitted by law.
15.6.1 You have the right to be informed whether or not we are processing your personal data;
15.6.2 You have the right to access your personal data;
15.6.3 You have the right to correct inaccuracies in your personal data;
15.6.4 You have the right to request deletion of your personal data;
15.6.5 You have the right to obtain a copy of the personal data you previously shared with us;
15.6.6 You have the right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
15.6.7 Exercise of Rights. To exercise these rights, please contact us at hi@joinsnag.com. If we decline to take action regarding your request and you wish to appeal our decision, please contact us at hi@joinsnag.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
15.7 Utah Residents. This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
15.7.1 You have the right to be informed whether or not we are processing your personal data;
15.7.2 You have the right to access your personal data;
15.7.3 You have the right to correct inaccuracies in your personal data;
15.7.4 You have the right to request deletion of your personal data;
15.7.5 You have the right to obtain a copy of the personal data you previously shared with us;
15.7.6 You have the right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
15.7.7 Exercise of Rights. To exercise these rights, please contact us at hi@joinsnag.com.
15.8 Virginia Residents. Under the Virginia Consumer Data Protection Act (VCDPA):
15.8.1 Definitions.
15.8.1.1 “Consumer” means a natural person who is a resident of the Commonwealth of Virginia acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context. If this definition of “Consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.
15.8.1.2 “Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable natural person but does not include de-identified data or publicly available information.
15.8.1.3 “Sale of Personal Data” means the exchange of personal data for monetary consideration.
15.8.2 Your Rights with Respect to Your Personal Data.
15.8.2.1 You have the right to be informed whether or not we are processing your personal data;
15.8.2.2 You have the right to access your personal data;
15.8.2.3 You have the right to correct inaccuracies in your personal data;
15.8.2.4 You have the right to request deletion of your personal data;
15.8.2.5 You have the right to obtain a copy of the personal data you previously shared with us;
15.8.2.6 You have the right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
15.8.3 Exercise of Rights. To exercise these rights, please contact us at hi@joinsnag.com. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
15.8.4 Verification Process. We may request that you provide additional information reasonably necessary to verify your / your Consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request. Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
15.8.5 Right to Appeal. If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If we decline to take action regarding your request and you wish to appeal our decision, please contact us at hi@joinsnag.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
16.1 Analytics Companies. We may partner with third-parties, including analytics companies. Analytics companies may use cookies (described above) or other tracking technologies to analyze visitors’ use of parts of the Services for various reasons, including, without limitation, to determine the popularity of content and to better understand online activity. To access our Services, you may be requested to consent to the collection and use of your information by certain third-party analytic companies. If you choose not to consent, you may not be able to access parts of the Services. We may not transfer your personal information to analytics companies but reserve the right to allow them use of, or access to, same as may be necessary or appropriate as contemplated under this Section. In such case, you should review any such analytics company’s Privacy Policy and contact them directly if you have questions about how your data may be used for analytics purposes as contemplated hereunder. If you do not want any information to be collected and used by tracking technologies, we encourage you to visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.
16.1.1 Google Analytics: You can opt-out of having your activity on Our Site or Application made available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents Google Analytics from retrieving information about your visits to our Site or Application. For more information about Google’s Privacy Policy, please visit: https://policies.google.com/privacy.
16.1.2 Facebook. You can opt-out of Facebook’s interest-based ads by visiting: https://www.facebook.com/help/568137493302217
You can learn more about Facebook’s Privacy Policy at:
https://www.facebook.com/full_data_use_policy
17.1 Updates. We will periodically update this Privacy Policy as necessary or appropriate or to stay compliant with relevant laws.
17.2 Notification of Changes. We may update this Privacy Policy from time to time. The updated version will be indicated by changes to the version number and date at the top of this Privacy Policy. The updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes through the Services or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting and processing your information.
If you have questions or comments about this privacy policy and our privacy practices, or would like to register a complaint or concern, you may contact us at hi@joinsnag.com.
If you wish to request access to the personal information we collect from you, to update that information, or to delete it, please contact us at hi@joinsnag.com.
