SeeSnap Third Party Privacy Notice

1. Introduction

This privacy notice is provided in accordance with the General Data Protection Regulation 2016/679 (“GDPR”), including any EU national laws implementing or supplementing the same, and any other applicable data protection laws (the “Data Privacy Laws”).

SeeSnapInc, LLC is a wholly owned affiliate of SeeSnapInc LLC a global firm with operations across the internet. SeeSnapInc, LLC (and all affiliates and subsidiaries, collectively "SeeSnap"), is committed to complying with the applicable data privacy and security requirements in the jurisdictions in which it operates. SeeSnap complies with internationally recognized standards of privacy protection, and with various privacy laws globally including, but not limited to, the GDPR.

SeeSnap provides workflow optimization, photo management and other productivity services to clients (collectively, “services”). In this respect, the relevant SeeSnap affiliate providing these services may act as data processor or as a separate data controller depending on the service being provided and the amount of control SeeSnap has over the purpose(s) and means of the data processing.

To the extent that SeeSnap is deemed to be a data controller under Data Privacy Laws, this notice fulfils our obligation to provide certain information to third parties whose personal data we process in this capacity as required by Article 14 of the GDPR and the notice requirements set out in any other Data Privacy Laws for processing personal data which has been obtained indirectly.

If you are a California resident, please see our CCPA Privacy Policy to learn about your rights under the California Consumer Privacy Act.

2. Who is Collecting Data?

Data will be collected by SeeSnap.

3. Data We Collect

SeeSnap collects the following categories of personal data:

Contact data: We may collect information about data subjects such as name and contact details (email, phone number, etc.) in order to communicate and facilitate the provision of our services with our clients or potential clients. For example, contact details of individuals who work for or on behalf of the clients, in order to carry out the client’s engagement with SeeSnap.

Services data: Personal data may be provided to us by clients to the extent required to perform the services. SeeSnap may also acquire personal data from a third party as required to perform services requested by our client(s).

Marketing information: We may collect information to respond to inquiries regarding our products and services or to provide you with information, reports, or updates.
Website visitor information: when you visit our website, we may collect information about your visit such as your IP address and the pages you visited and when you use our services we may collect information on how you use those services. Please see our Website Privacy Policy, Website Terms of Use and Cookies Policy for additional information.

Website visitor information: when you visit our website, we may collect information about your visit such as your IP address and the pages you visited and when you use our services we may collect information on how you use those services. Please see our Website Privacy Policy, Website Terms of Use and Cookies Policy for additional information.

Clients and other third parties who provide personal information to SeeSnap must do so in compliance with applicable data privacy regulations.

4. Detailed information on the processing of Personal Data

Personal data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out.

Category of personal information collected according to CCPA: internet information.

Backup saving and management

This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.

Backup on Google Drive (Google LLC)
Google Drive is a service to save and manage backups provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Maps widget (Google LLC)
Google Maps is a maps visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Handling activity data

This type of service allows the Owner to use the activity data collected by your device in order for this Application to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.
Depending on what is described below, third parties may be involved in the activity tracking.
Most devices allow for the User to control which Data is accessed or stored.

Activity data tracked by your device (this Application)
This Application uses some activity data tracked by your device to operate or to provide specific features.
Personal Data processed: movement activity.

Category of personal information collected according to CCPA: biometric information.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Interaction with data collection platforms and other third parties

This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Mailchimp widget (The Rocket Science Group LLC)
The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data processed: first name; last name; phone number; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; internet information.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.T
hese services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailchimp (The Rocket Science Group LLC)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data processed: company name; Cookies; email address; first name; phone number.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

Platform services and hosting

These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Webflow (Webflow, Inc.)
Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host this Application. Webflow is highly customizable and can host websites from simple blogs to complex e-commerce platforms.
Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy PolicyOpt out.

Category of personal information collected according to CCPA: internet information.

Remarketing and behavioral targeting

This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.
Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy PolicyOpt Out.

Category of personal information collected according to CCPA: internet information.

Social features

Inviting and suggesting friends (this Application)
This Application may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data processed: various types of Data.

Category of personal information collected according to CCPA: internet information.

Tag management

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

5. Processing of Personal Data

We collect personal data to offer and administer our services.

The data you provide to us will be processed in accordance with the purposes specified in this notice, namely:

a.
To provide the products or perform the services requested by clients and individuals pursuant to a letter of engagement, statement of work, or similar (where the processing is necessary for our legitimate business interests in conducting and managing our business).
b.
To provide the products or perform the services requested by clients and individuals using our website or web applications (where the processing is necessary for our legitimate business interests in conducting and managing our business).
c.
For complying with obligations provided by laws, current regulations and European legislation (e.g. tax regulations) (where processing is based on a legal obligation) or legislation in other jurisdictions that may be applicable.
d.
For legitimate business purposes to advise you through e-mail, phone call, or post, in the framework of our ordinary commercial relationship, about other products or services similar to the products or services we have provided to you and that we think will be of interest to you (where the processing is necessary for our legitimate business interests).
e.
For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding SeeSnap and its group companies such as information about promotions, events, products or services. You can withdraw your consent or opt out of receiving our marketing communications at any time. If you are not located in the EU, you may opt-out of receiving marketing communications and updates at any time. You can manage your receipt of marketing and non-transactional communications by clicking on the «unsubscribe» link located on the bottom of SeeSnap’s marketing emails. Additionally, you may send a request to legal@seesnap.com.
f.
For improving SeeSnap’s communications with you. Emails sent to you by SeeSnap may include standard tracking, including open and click activities. SeeSnap may collect information about your activity as you interact with our email messages and related content.
g.
For operating and improving SeeSnap’s website and your customer experience. For example, we may collect and analyse data on your use of our website and process it for the purpose of improving our online experience. Please see our Privacy Policy, Terms of Use and Cookies Policy for additional information
h.
For security purposes. For example, we may use your data to protect SeeSnap and its third parties against security breaches and to prevent fraud and violation of SeeSnap’s applicable agreements (where the processing is necessary for our legitimate business interests).

Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing if you wish.

6. Personal data and the performance of client services

Our clients engage us on a wide range of matters to help them better perform workflow related tasks, for example to conduct due diligence on a potential partner, supplier or acquisition target. In many cases, the client’s engagement of SeeSnap is to fulfil a requirement of EU or member state law or regulation, e.g. the EU Anti-Money Laundering Regulations and the UK Bribery Act 2010. We believe that SeeSnap has a legitimate interest in processing data to support its clients in these objectives provided that the privacy rights of any affected individuals are not unduly affected.

The personal data we process in the performance of services for and on behalf of our clients includes but is not limited to any information relating to a living individual in which the individual is identified or identifiable, for example, the individual’s name, contact information, education information, work history, directorships, financial information, as well as, where necessary, data concerning criminal convictions and offences and some special categories of information as defined by article 9 of the GDPR or sensitive personal data, as defined by laws of other jurisdictions, for example the Dubai International Financial Centre's Data Protection Law.

In connection with our services we collect various types of personal data from a variety of different sources, including from:

our clients
public sources such as public records and registers, social media sites and the internet
other third party sources such as industry or country experts

7. How data is processed

Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorized SeeSnap employees and third-party providers to have access to your information. Such employees and third-party providers are appropriately designated and trained to process data only according to the instructions we provide them.

8. Storage of Personal Data

SeeSnap will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements, and in accordance with SeeSnap’s Records Retention Policy.

9. Disclosure/Sharing of Personal Data

We only share your personal data with your consent or in accordance with this notice. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this notice.

We share personal data among SeeSnap-controlled affiliates and subsidiaries who act for SeeSnap for the purposes set out in this notice.

SeeSnap may share your information with external third parties, such as vendors, consultants, legal advisors, auditors and other service providers who are performing, advising or assisting with certain services on behalf of SeeSnap. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable contract, and not for any other purpose. SeeSnap requires these third parties to undertake security measures consistent with the protections specified in this notice.

SeeSnap may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

If SeeSnap’s business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.

10. Cross – Border Transfers of Personal Data

SeeSnap is a global firm with operations in the USA, but we operate across the internet.  Personal information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this notice, and in compliance with local law and regulations.

Personal Data may be transferred to or processed in locations outside of the European Economic Area (EEA), some of which have not been determined by the European Commission to have an adequate level of data protection. In that case, for personal data subject to European data protection laws, we take measures designed to provide the level of data protection required in the EU, including ensuring transfers are governed by the requirements of the Standard Contractual Clauses adopted by the European Commission, or another adequate transfer mechanism. SeeSnap entities have entered into intragroup transfer agreements based on the Standard Contractual Clauses which allows for the processing and transfer of personal data.

Where we receive requests to disclose personal data from law enforcement or regulators, we carefully validate these requests, including reviewing the legality of any order and challenging the order if there are grounds under the law to do so, before any personal data is disclosed.

11. Your Rights

Depending on the laws of the jurisdiction governing the processing of your personal data, you may have certain rights under applicable data protection laws concerning your data processed by SeeSnap including:

Access: You have the right to access personal information that SeeSnap holds about you.

Rectification: You have the right to ask us to rectify information SeeSnap holds about you if it is inaccurate or not complete.

Erasure: You can request that SeeSnap erase your personal data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing. You can make a request to have your data removed. SeeSnap will have 45 days to comply. Please fill out this form.

Restrict Processing: You have the right to ask SeeSnap to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.

Object to processing: Where processing is based on legitimate interests, you have the right to object to SeeSnap processing your data. SeeSnap will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Portability: Where processing is based on consent or performance of a contract, you have the right to data portability. SeeSnap must allow you to obtain and reuse your personal data for your own purposes in a safe and secure way without this affecting the usability of your data. This right only applies to personal data that you have provided to SeeSnap as the Data Controller.

Please contact legal@seesnap.com to request access, rectification, or erasure, or to restrict processing, to object to processing, to request data portability.

Subject to legal considerations or certain exemptions, we may not always be able to address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Requests received via post may be delayed due to limited office access during the Covid-19 pandemic. Please contact us by email to ensure your request is received in a timely manner.

12. Automated Decision Making

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

SeeSnap does not make automated decisions using personal data. If automated decisions are to be made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.

13. Providing Information to SeeSnap

If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services, and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our website(s).

14. Third Party Websites or Other Services

We are not responsible for the privacy practices of any non-SeeSnap operated websites, mobile apps or other digital services, including those that may be linked through SeeSnap websites or services, and we encourage you to review the privacy policies or notices published thereon.

15. Contact Us

Requests received via post may be delayed due to limited office access during the Covid-19 pandemic.  Please contact us by email to ensure your request is received in a timely manner.

Please contact us at SeeSnap with questions, concerns, or complaints:

SeeSnap Corporate Headquarters
3174 Vera Valley Road
Franklin, TN 37064
legal@seesnap.com

If you are in the EU:
For data subjects located in the EU: if we are not able to satisfactorily resolve your questions, concerns, or complaints, or if you believe that the processing of your personal data infringes on your rights under applicable data protection laws, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. Contact information for the supervisory authorities may be found here:

EU Data Protection Authorities

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm