Last updated: 27.09.2023
The App is managed by SNAQ AG, a joint-stock company incorporated under Swiss law, having its registered office at Ruchackerweg 10, 8405 Winterthur, Switzerland.
- "App" means the Snaq mobile application, published by Us and available on the Store;
- “Applicable Law” means the substantive laws of Switzerland, including the Federal Act on Data Protection, and, whenever applicable, the EU General Data Protection Regulation (GDPR);
- "EULA" means Our End User License Agreement, accessible at the following link https://www.snaq.io/eula;
- "Google" has the meaning set forth at Section 7.3.
- "Personal Data" means any Personal Data relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- "Services" refers to the App, the Website and/or the services offered by Us through the App and/or the Website;
- "We", "Us", "Our(s)" and "Snaq" refer to SNAQ AG;
- "Website" means Our website accessible at the following link: https://www.snaq.io/; and
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1.1 As part of accessing and using Our Services or interacting with Us, We may collect and process some Personal Data about You. When We do so, We will collect, process and share Your Personal Data with Your consent for the purposes We have informed You of, or as may be otherwise permitted or required by Applicable Law.
1.2 You can withhold or withdraw Your consent for Us to collect, use or share Your Personal Data, as long as there are no legal or contractual requirements for Us to process such Personal Data (see Section 8 below). Depending on the circumstances, however, withdrawal of Your consent may impact Our ability to provide You Our Services.
2. WHICH DATA DO WE COLLECT AND HOW?
The following Section describes the information that We collect and how We collect it. There are multiple ways in which We collect information, which can be broadly categorized into:
a) Information that You freely choose to share with Us
We collect the information that You directly provide to Us, such as when You set up an account on the Website or when You send Us an e-mail. This type of collection often occurs through Our business support processes, such as:
Notwithstanding the above, please note that You may also choose to submit information to Us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with Us or (v) by giving Us Your business card or contact details at trade shows or other events.
b) Information that is automatically collected when using Our Services
Besides the information that You freely choose to share with Us, We may automatically or passively collect and process various information regarding Your use of – and Your behavior through – the Services. While information collected in this manner is not typically Personal Data, We may combine it in ways that make it personally identifiable. When We do so, We will treat the combined data as Personal Data.
Information collected in this manner may include:
c) Information that is collected via third parties
As far as it is not unlawful, We also collect information from public sources (for example, the media, or the internet including social media) or receive data from public authorities and from other third parties (such as Our contractual or business partners, Our internet analytics services, etc.).
We may receive the following categories of information from third parties:
3. HOW DO WE USE THE COLLECTED DATA?
We use non-personally identifying information without restrictions. On the contrary, Personal Data are only used for the purposes indicated at Section 4 below. Please note that We strive to minimize Our use of Personal Data, and, to the maximum extent possible, anonymize or aggregate it before use.
4. FOR WHAT PURPOSES DO WE COLLECT PERSONAL DATA?
4.1 We will mainly process Personal Data for the conclusion, administration and performance of Our contractual and business relationships and the provision of the Services as well as for otherwise interacting and communicating with You.
4.2 We further process Personal Data for the following purposes:
4.3 Snaq's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.
5. LEGAL GROUNDS FOR DATA PROCESSING
5.1 Where We ask for Your consent for certain processing activities (i.e. for marketing mailings, for advertising management and behavior analysis on the Website), We will inform You separately about the relevant processing purposes. You may withdraw Your consent at any time with effect for the future by sending an e-mail to Us (see Our contact details in Section 11 below). For withdrawing consent for online tracking, see Section 7. Once We have received notification of withdrawal of consent, We will no longer process Your information for the purpose(s) You consented to, unless We have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.
5.2 Where We do not ask for consent for processing, the processing of Your Personal Data relies on the requirement of the processing for initiating or performing a contract with You or on Our or a third-party legitimate interest in a specific processing, in particular in pursuing the purposes set out in Section 4.
5.3 Where We receive sensitive Personal Data, We may process Your Personal Data on other legal basis, for example, in the event of a dispute, as required in relation with a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which We will communicate to You separately as necessary.
6. TO WHOM DO WE COMMUNICATE PERSONAL DATA?
We do not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted entities, as outlined below:
7. WHAT KIND OF TRACKING TECHNOLOGIES DO WE USE?
7.2 We distinguish the following categories of cookies (including other technologies):
7.3 We currently use offers from the following service providers and advertising partners (where they use data from You or cookies set on Your computer for advertising purposes):
8. YOUR PERSONAL DATA, YOUR RIGHTS
Applicable data protection laws grant You the right to object to the processing of Your data in some circumstances, in particular for direct marketing purposes, to profiling carried out for direct marketing purposes and to other legitimate interests in processing.
To help You control the processing of Your Personal Data, You have the following rights in relation with Our data processing, depending on the applicable data protection law:
If You wish to exercise the above-mentioned rights in relation with Us, please contact Us in writing, at Our premises or, unless otherwise specified or agreed, by e-mail (see Our contact details in Section 11).
You also have these rights in relation with other parties that cooperate with Us as separate controllers – please contact them directly if You wish to exercise Your rights in relation with their processing.
If You do not agree with the way We handle Your rights or with Our data protection practices, please let Us or Our Data Protection Officers (see Section 11) know. If You are located in the EEA, the United Kingdom or in Switzerland, You also have the right to lodge a complaint with the competent data protection supervisory authority in Your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-Us/.
9. SECURITY AND RETENTION OF PERSONAL DATA
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within Our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of employees who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with Us is no longer secure, please contact firstname.lastname@example.org immediately.
We process Your data for as long as Our processing purposes, the legal retention periods and Our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 2, and for cookies in Section 7. If there are no contrary legal or contractual obligations, We will delete or anonymize Your data once the storage or processing period has expired as part of Our usual processes.
10. INTERNATIONAL PERSONAL DATA TRANSFER
As explained in Section 6, We disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and in the USA; in exceptional cases, in any country in the world.
If a recipient is located in a country without adequate statutory data protection, We require the recipient to undertake to comply with data protection (for this purpose, We use the European Commission’s standard contractual clauses), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless We cannot rely on an exemption. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if You have consented or if data has been made available generally by You and You have not objected against the processing.
11. CONTACT US