1.            Introduction

This Privacy Policy describes how Snap Software collects and uses Personal Data about you through the use of our Websites, our products, and through email, text, and other electronic communications between you and Snap Software.

Snap Software Inc. (“Snap Software” or “we”) respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website https://www.snapsoftware.com or use our software products and our practices for collecting,  maintaining, using, protecting, and disclosing that information.


This policy applies to information we collect:

•             on our Websites and through the use of our products;

•             in email, text, and other electronic messages between you and our Websites (including our technical support services);


It does not apply to information collected by:

•             us offline or through any other means, including on any other website operated by Snap Software or any third-party; or

•             any third party, including through any application or content that may link to or be accessible from or on the Website or with our products.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites and/or not to use our products. By accessing or using these Websites and using our products, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of these Websites and continued use of our products after we make changes is considered to be acceptance of those changes, so please check this Privacy Policy regularly for updates.

 

2. Data Controller, Data Protection Officer, and Representative

Snap Software is the data controller of the Personal Data you provide on the Website. Snap Software, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Policy.

 

3. Children Under the Age of 18

Our Websites are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Website. We will remove any information about a child under the age of 18 if we become aware of it.

Our Websites are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not register on the Website or make any communications through the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us in any manner set forth below in the “Contact Information” Section of this Privacy Policy.

 

4. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally


We collect several types of information from and about users of our products and Websites, specifically information:

•             by which you may be personally identified, such as name, postal address, e-mail address, telephone number, credit card information (for payment processing) and any other identifier by which you may be contacted online or offline (“Personal Data”);

•             that is about you but individually does not identify you, such as Website traffic data, location data (through IP address), logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream data, and other communication data and the resources that you access and use on the Websites;

•             if you use our software, information related to your usage of the software; and/or

•             about your internet connection, the equipment you use to access our Websites and usage details.


We collect this information:

•             directly from you when you provide it to us;

•             automatically as you navigate through the site. Information collected automatically may include usage details (including the number of installations for products you have purchased), IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and

•             From third parties, for example, our resellers.

Information You Provide to Us

The information we collect on or through our Websites are:

•             information that you provide by filling in forms on our Websites. This includes information provided at the time of posting material, or requesting further services (such as technical support). We may also ask you for information when you report a problem with our Website;

•             records and copies of your correspondence (including email addresses), if you contact us;

•             your responses to quizzes and surveys that we might ask you to complete for research purposes;

•             details of records you create when using our products;

•             details of transactions you carry out through our Websites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites; and

•             your search queries on the Websites.

The Personal Data we collect from you is required for Snap Software to provide you with our products and services, and to provide you with license keys to our products. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to provide services and products to you.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). If you consent, your User Contributions may include technical support tickets that you make publicly available to our user community. Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies


As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

•             details of your visits to our Website, specifically traffic data, location data (through IP addresses), logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Websites;

•             the number of installations for the products you have purchased; and

•             Information about your computer and internet connection, specifically your IP address, operating system, and browser type.


The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:

•             estimate our audience size and usage patterns;

•             store information about your preferences, allowing us to customize our Websites according to your individual interests;

•             prevent or deter software piracy and protect our intellectual property; and

•             recognize you when you use and return to our Websites.

Information We Collect Through Using Our Products

When you use our software products, your computer or device may transmit information to us about the usage of our products and software technologies. We may collect information about your software use, error logs, and any records created with our software products. This information is used by us to address issues within our products and improve our products.

 

5. Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you, and required by law, and with your consent.

 

6. Special Categories of Information

We generally do not request you provide and do not process any special categories of Personal Data.

Snap Software does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you, such as Personal Data that reveals your racial or ethnic origin, political opinions, religious, philosophical beliefs, or trade unions membership, or the processing of data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions.

 

7. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

•             provide our Websites to you;

•             provide you with information you request from us;

•             enforce our rights arising from contracts or software license agreements ;

•             notify you about changes; and

•             provide you with notices about your account


We use information that we collect about you or that you provide to us, including any Personal Data:

•             to present our Websites and their contents to you;

•             to provide you with information, products (including license keys), or services that you request from us;

•             to fulfill any other purpose for which you provide it;

•             to provide you with notices about your account, including expiration and renewal notices, invoices, and receipts;

•             to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

•             to notify you about changes or updates to our Websites or any products or services you have purchased or that we offer or provide though our Websites;

•             to allow you to participate in interactive features on our Websites;

•             when necessary to contact you about processing an order or transaction, to contact you through phone or SMS messages;

•             in any other way we may describe when you provide the information; and

•             for any other purpose with your consent.

With your consent, we may also use your information to send you newsletters and contact you about our own goods and services that may be of interest to you, including events and other activities that may be in your area or may be of interest to you.

 

8. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

•             our third-party service providers that we use to support our business, such as our payment processors and hosting providers;

•             to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;

•             to comply with our legal obligations;

•             to enforce our rights; and

•             with your consent.


We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.


We may disclose Personal Data that we collect or you provide as described in this privacy policy:

•             to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them;

•             to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Snap Software Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Snap Software Inc. about our Website users is among the assets transferred;

•             to fulfill the purpose for which you provide it. For example, if you give us a name and/or email address and post in public comments to a page, we will transmit your name and/or email address to anybody who views that comment page;

•             for any other purpose disclosed by us when you provide the information; and

•             with your consent.

We may also disclose your Personal Data:

•             to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

•             to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and

•             if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Snap Software Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

9. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.


Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

•             Access and Update. You can review and change your Personal Data by logging into the Websites and visiting the “Manage Profile” section of your “My Account” page. You may also notify us through the contact information below or through our Websites’ live chat features of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

•             Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing, but we have retained it as permitted by law.

•             Portability. To the extent the Personal Data you provide Snap Software is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.

•             Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.

•             Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account and revoking your licenses, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.

•             Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

•             How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods below and through the live chat feature of our Website. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.

 

10. Do Not Track Signals

We do not track you over time and across other third-party websites or services and therefore We currently do not honor do-not-track signals that may be sent by some browsers.

We do not track you over time and across third-party websites or other online services for any purpose. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received.

 

11. Data Security

Information transmitted over the Internet is not completely secure, but We do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your passwords to our Websites and data services confidential.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites or data services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Websites like message boards. The information you share in public areas may be viewed by any user of the Websites.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

 

12. Data Retention Periods

We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:

•             on our backup and disaster recovery systems;

•             for as long as necessary to protect our legal interests; and

•             and to comply with other legal requirements.


Snap Software will retain your personal data for the entire time that you keep your account open. After you close your account and request your information to be deleted, we may retain your Personal Data:

•             for as long as necessary to comply with any legal requirement;

•             on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;

•             for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and

•             for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

 

13. Changes to Our Privacy Policy 

We will post any changes to our Privacy Policy on our Websites. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes. We may change this Privacy Policy at any time.

 

14. Contact Information

You may contact us through the contact information through the “Contact Us” page on our Website.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact us at the contact information through the “Contact” page on our Website.