Privacy Policy

Privacy Policy

This Privacy Policy (“Policy”) outlines Snaptrude Inc’s (“Snaptrude”, “we” or “us”) practices in relation to the storage, use, processing, and disclosure of personal data that you have chosen to share with us when you access our website https://snaptrude.com/ and the software applications that we make available (collectively the “Platform”), or personal data that we may have access to in relation to your use of the Platform.

Snaptrude is the “data controller” in relation to such processing of personal data.  We have appointed representatives in the European Union (“EU”) and United Kingdom (“UK”), the details of which can be found under “Contact Us” below. 

At Snaptrude, we are committed to protecting your personal data and respecting your privacy. Please read the following terms of the Policy carefully to understand our practices regarding your personal data and how we will treat it. This Policy sets out the basis on which any personal data we collect from you, we collect about you, or that you provide to us, will be processed by us.

Capitalised words in the Policy that are not defined in the Policy shall have the meaning given to them in the Terms and Conditions (“Terms”), available at www.snaptrude.com/terms. Please read this Policy in conjunction with the Terms.

‍

1. THE DATA WE COLLECT ABOUT YOU

1. ‍For the purposes of this Policy, personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed – for example, anonymous data.
2. ‍We may collect, use, store and transfer different kinds of personal data about you to provide you with or in connection with the Platform. Such personal data includes:

1. identity and profile-related data, such as your first and last name, username or similar identifiers, gender, title, employer, role/position, passwords, purchases or orders, feedback, survey responses, etc.;
2. contact details, including email addresses, phone numbers, delivery addresses, business addresses, etc.;
3. transaction data, including details about payments to and from you and details of products and services you (or your employer) have purchased or sold;
4. technical data including IP addresses, browser types and versions, time zone settings and locations, operating systems, and other technology on the devices you use to access the Platform;
5. usage data including information about how you use the Platform; and
6. marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.

3. ‍We do not intend to collect or process any special categories of personal data or data that is deemed particularly sensitive (such as information relation to race or ethnicity, religious or philosophical beliefs, or health data).  However, to the extent you proactively provide us with such information (e.g., where such information is provided unsolicited in communications) then we will process such personal data on the basis that you have provided your express consent by sharing it with us. 
4. We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under applicable laws. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Platform.
5. ‍Where we need to collect personal data by law, or under the terms of the arrangement we have with you, and you fail to provide that data when requested, we may not be able to perform our obligations under the arrangement we have with you or are trying to enter into with you (for example, to provide you with features of the Platform). In this case, we may have to cancel or limit your access to the Platform, but we will notify you if this is the case at the time.
6. We may also collect personal data about individuals who are apply for roles with Snaptrude.  We may collect personal data such as identity and contact details, along with information about relevant qualifications and experience for the purpose of taking steps, at your request, prior to entering into a contract with you (such as a contract of employment).  This may involve the processing of some special category information (such as health related information where we may need to make reasonable adjustments, which we will process where it is necessary in connection with specific rights and obligations under employment law). 

‍

2. HOW DO WE COLLECT DATA ABOUT YOU?

1. ‍We use different methods to collect and process data about you.

1. Information you give us – This is the information (including identity, contact, and marketing and communications data) you provide to us when you create a profile on the Platform or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Platform, use an in-Platform feature, or share data through the Platform, through other activities commonly carried out in connection with the Platform, and when you report a problem with the Platform. If you contact us, we will keep a record of the information shared during the correspondence.
2. ‍Information we collect about you and your device – Each time you visit our Platform, we will automatically collect personal data including device and usage data. We collect this data using cookies and other similar technologies.
3. ‍Information we receive from other sources – including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

1. ‍Analytics providers such as Google and Facebook;
2. Advertising networks;
3. Search information providers;
4. Contact, financial and transaction data from providers of technical, payment, and delivery services;
5. Identity and contact data from data brokers or aggregators; and
6. Identity and contact data from publicly available sources.

‍

3. HOW DO WE USE AND DISCLOSE THE DATA WE COLLECT?

1. ‍We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following purposes (which will constitute the lawful bases where required under applicable data protection law): 

1. to operate the Platform and provide it to you (which is in our legitimate interests which are not outweighed by your fundamental rights and freedoms), 
2. to perform our obligations and exercise our rights under any contract with you (e.g., where you contact with us for the Platform directly and not via an employer), 
3. where we have your consent (e.g., to send marketing materials) – you may withdraw your consent at any time, or 
4. where we need to use your personal data to comply with a legal obligation.

2. ‍In general, we will use your personal data in accordance with the following purposes for the following activities:

1. Activity

Lawful basis for processingTo install the Platform and register you as a user.Legitimate interest (where our contract is with your employer) Contract (where you have contracted for the Platform directly) To deliver features of the Platform to you.Legitimate interest (where our contract is with your employer) Contract (where you have contracted for the Platform directly)To manage our relationship with you including notifying you of changes to the Platform.Legitimate interestTo administer and protect our business and the Platform including troubleshooting, data analysis, and system testing.Legitimate interest To deliver content and advertisements to you.Legitimate interest Consent (where required by applicable law) To make recommendations to you about goods or services which may interest you.Legitimate interest Consent (where required by applicable law)To measure and analyse the effectiveness of the advertising we serve you.Legitimate interestTo monitor trends so we can improve the Platform.Legitimate interest

1. To perform our obligations that arise out of the arrangement we are about to enter or have entered with you.

Legitimate interest (where our contract is with your employer) Contract (where you have contracted for the Platform directly)

2. To enforce our Terms, including collecting payment.

Legitimate interest (where our contract is with your employer) Contract (where you have contracted for the Platform directly)

2. To perform necessary “know your customer” and similar checks. 

Legal obligation.

3. To comply with a legal or regulatory obligation.

Legal obligation. 

‍

3. ‍We do not process your personal data to make decisions based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you. 
4. You are aware that any and all information pertaining to you, whether or not you directly provide it to us (via the Platform or otherwise), including but not limited to personal correspondence such as emails, instructions from you etc., may be shared by us with third parties in order to achieve the purposes or activities set out above. For example, we may share your personal data with storage providers, payments systems providers, marketing partners, data analytics providers, and consultants, lawyers, and auditors. We may also share this information with our parent company, subsidiaries, affiliates or any of their holding companies.
5. ‍We may also share your personal data (without your knowledge in some circumstances), when it is required by law or where we receive a request from a court or government agency or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for Snaptrude’s legitimate commercial interests (where the request is not legally binding), or in order to comply with applicable laws and regulations (where a request may be legally binding).
6. You are aware that by using our Platform or creating an account on the Platform, Snaptrude, our associate partners, and affiliates may contact you via email, phone, or otherwise to ensure that you are aware of all the features of the Platform.
7. You authorise us to send you electronic alerts and messages for details pertaining to registration on the Platform and requirements arising out of the provision of the Platform.
8. ‍Further, where you have provided your consent for direct marketing (where required by applicable law), you agree to receive advertising, promotions, and other emails and forms of communication from us. Through such communication you will receive information about the latest developments on the Platform. You may unsubscribe from our mailing list at any time, via the unsubscribe option we offer.

‍

4. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA 

1. Depending on the jurisdiction you are located in, you may have certain rights in relation to your personal data.  For example, if you are located in the European Union (“EU”) or United Kingdom (“UK”) you may have the following rights: 

1. request access to your personal data;
2. request that we correct any inaccurate personal data that we are processing;
3. request that we delete your personal data where there is no good reason for us to continue processing it (subject to exceptions); 
4. object to our processing of your personal data in certain circumstances; 
5. request that we restrict our processing of your personal data in certain circumstances; 
6. request that we transfer your personal data to you or a third party. 

2. You may also have the right to complain about our processing of your personal data to an appropriate supervisory authority such as the Information Commissioner’s Office in the UK. 

‍

5. INTERNATIONAL TRANSFER OF PERSONAL DATA

1. ‍As a part of your use of the Platform, the information and personal data you provide to us may be processed in countries other than the country in which you are located. When we collect your personal data, we generally do so from the United States of America (“USA”) (where Snaptrude is established).  
2. We may also transfer your personal data if any of our servers are from time to time located in a country other than the USA, or one of our service providers is located in a country other than the USA.  We may also process your personal data using Snaptrude affiliates located in other jurisdictions (such as India). These entities may be subject to data laws of their respective countries.  However, where personal data is transferred to a jurisdiction that has not been deemed to provide an adequate level of protection for personal data (in accordance with applicable law), we will take steps, where required, to ensure that such personal data is appropriately safeguarded, for example by using approved standard contractual clauses for that purpose.   
3. ‍By submitting your information and personal data to us, you acknowledge the transfer, storage, and/or processing of such information and personal data in the manner described above.

‍

6. THIRD PARTY LINKS AND USER EXPERIENCE IMPROVEMENT SERVICES

1. ‍The Platform may, from time to time, contain services provided by or links to and from the websites of our partner networks, advertisers and affiliates (“Third Party Services”). Please note that the Third Party Services that may be accessible through our Services have their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through the Third Party Services. Please check their policies before you submit any personal data to such websites or use their services.
2. ‍We use third-party user experience improvement services (including but not limited to those provided by Google Inc and/or its affiliates) and applications to better understand your behaviour on the Platform.  
3. ‍The information collected includes (but is not limited to):

1. ‍age;
2. gender;
3. preferences; and
4. interests.

4. ‍Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit or restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.
5. ‍The place of processing information depends on each third-party service provider and you may wish to check the privacy policy of each of the service providers to identify the data shared and its purpose. You will also be subject to a third party’s privacy policy if you opt in to receive communications from third parties. We will not be responsible for the privacy standards and practices of third parties.

‍

7. COOKIES  

1. We use cookies and other tracking technologies to distinguish you from other users of the Platform and to remember your preferences. This helps us to provide you with a good experience when you use our Platform and also allows us to improve the Platform.
2. Cookies are small data files which are sent to your browser from the Platform and are stored on your computer or device (hard drive). The cookies shall not provide access to data in your computer or device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to administer the Platform and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features of the Platform. 
3. ‍Additionally, you may encounter cookies or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities in relation to the Platform, we may collect such information into a file specific to you.
4. You can control what cookies are placed by the Platform via the “Cookie Banner” that you are presented with when you first visit the Platform.  You can also update your preferences at any time by clicking on the “Cookie Settings” icon in the bottom right corner of the Platform’s home page. Most web browsers and devices can also be set to notify when you receive a cookie or prevent cookies from being sent. If you do prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform or try to access the Platform.

‍

8. DATA SECURITY  

1. ‍We implement certain security measures including encryption, firewalls, and socket layer technology to protect your personal data from unauthorised access. However, you acknowledge that the above-mentioned measures do not guarantee absolute protection to the personal data and by accessing the Platform, you assume all risks associated with disclosure of personal data arising due to breach of firewalls and secure server software.
2. ‍Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

‍

9. DATA RETENTION  

‍You are aware that your personal data will continue to be stored and retained by us for a reasonable period after termination of your account on the Platform.  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

‍

10. BUSINESS TRANSITIONS

‍You are aware that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

‍

11. CHANGE IN PRIVACY POLICY

1. We keep our Policy under regular review and may amend this Policy from time to time, at our sole discretion.
2. ‍The terms of this Policy may change and if they do, these changes will be posted on this page and, where appropriate, may be notified to you by email. The new Policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform.

‍

12. CONTACT US

‍You may contact us at info@snaptrude.com with any enquiry relating to this Policy, including where you would like more information about any of the topics discussed in this Policy, or if you have an enquiry relating to your personal data (including where you wish to exercise any of your rights). 

You can also do so by writing to our Grievance Officer, at the address provided below:

‍Address: 881, Koramangala 6^th Block, Club Road, Bangalore - 560095

Email Address: support@snaptrude.com

Our EU and UK representatives details are: 

EU-GDPR representative:

‍Rickert Rechtsanwaltsgesellschaft mbH
- Snaptrude Inc -
Colmantstraße 15
53115 Bonn
Germany
‍art-27-rep-snaptrude@rickert.law

UK-GDPR representative service:

‍Rickert Services Ltd UK
- Snaptrude Inc -
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
‍art-27-rep-snaptrude@rickert-services.uk