Snap Club LLC Privacy Policy
Your privacy is important to us. It is Snap Club LLC's policy to respect your privacy and
comply with any applicable law and regulation regarding any personal information we may
collect about you, including across our website, https://www.snapclub.io, and other sites we
own and operate.
Personal information is any information about you which can be used to identify you. This
includes information about you as a person (such as name, address, and date of birth), your
devices, payment details, and even information about how you use a website or online
service.
In the event our site contains links to third-party sites and services, please be aware that
those sites and services have their own privacy policies. After following a link to any third-
party content, you should read their posted privacy policy information about how they collect
and use personal information. This Privacy Policy does not apply to any of your activities after
you leave our site.
This policy is effective as of 22 March 2023.
Last updated: 22 March 2023
Information We Collect
Information we collect falls into one of two categories: “voluntarily provided” information and
“automatically collected” information.
“Voluntarily provided” information refers to any information you knowingly and actively
provide us when using or participating in any of our services and promotions.
“Automatically collected” information refers to any information automatically sent by your
devices in the course of accessing our products and services.
Log Data
When you visit our website, our servers may automatically log the standard data provided by
your web browser. It may include your device’s Internet Protocol (IP) address, your browser
type and version, the pages you visit, the time and date of your visit, the time spent on each
page, and other details about your visit.
Additionally, if you encounter certain errors while using the site, we may automatically collect
data about the error and the circumstances surrounding its occurrence. This data may include
technical details about your device, what you were trying to do when the error happened, and
other technical information relating to the problem. You may or may not receive notice of
such errors, even in the moment they occur, that they have occurred, or what the nature of
the error is.
Please be aware that while this information may not be personally identifying by itself, it may
be possible to combine it with other data to personally identify individual persons.
Device Data
When you visit our website or interact with our services, we may automatically collect data
about your device, such as:
- Device Type
- Operating System
- Geo-location data
Data we collect can depend on the individual settings of your device and software. We
recommend checking the policies of your device manufacturer or software provider to learn
what information they make available to us.
Personal Information
We may ask for personal information — for example, when you register an account or when
you contact us — which may include one or more of the following:
- Name
- Email
- Social media profiles
- Phone/mobile number
- Home/mailing address
User-Generated Content
We consider “user-generated content” to be materials (text, image and/or video content)
voluntarily supplied to us by our users for the purpose of publication, processing, or usage on
our platform. All user-generated content is associated with the account or email address used
to submit the materials.
Please be aware that any content you submit for the purpose of publication will be public after
posting (and subsequent review or vetting process). Once published, it may be accessible to
third parties not covered under this privacy policy.
Transaction Data
Transaction data refers to data that accumulates over the normal course of operation on our
platform. This may include transaction records, stored files, user profiles, analytics data and
other metrics, as well as other types of information, created or generated, as users interact
with our services.
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for
doing so. In which instance, we only collect personal information that is reasonably necessary
to provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our
website:
- Register for an account
- Purchase a subscription
- Use a mobile device or web browser to access our content
- Contact us via email, social media, or on any similar technologies
- When you mention us on social media
We may collect, hold, use, and disclose information for the following purposes, and personal
information will not be further processed in a manner that is incompatible with these
purposes:
- to provide you with our platform's core features and services
- to enable you to customize or personalize your experience of our website
- to deliver products and/or services to you
- to contact and communicate with you
- for advertising and marketing, including to send you promotional information about our
products and services and information about third parties that we consider may be of
interest to you
- to enable you to access and use our website, associated applications, and associated social
media platforms
- for internal record keeping and administrative purposes
- for security and fraud prevention, and to ensure that our sites and apps are safe, secure,
and used in line with our terms of use
We may combine voluntarily provided and automatically collected personal information with
general information or research data we receive from other trusted sources. For example, If
you provide us with your location, we may combine this with general information about
currency and language to provide you with an enhanced experience of our site and service.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we
will protect it within commercially acceptable means to prevent loss and theft, as well as
unauthorized access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we advise
that no method of electronic transmission or storage is 100% secure, and no one can
guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the
security of your own information within the bounds of our services. For example, ensuring any
passwords associated with accessing your personal information and accounts are secure and
confidential
How Long We Keep Your Personal Information
We keep your personal information only for as long as we need to. This time period may
depend on what we are using your information for, in accordance with this privacy policy. For
example, if you have provided us with personal information as part of creating an account
with us, we may retain this information for the duration your account exists on our system. If
your personal information is no longer required for this purpose, we will delete it or make it
anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information for our compliance with a
legal, accounting, or reporting obligation or for archiving purposes in the public interest,
scientific, or historical research purposes or statistical purposes.
Children’s Privacy
We do not aim any of our products or services directly at children under the age of 13, and we
do not knowingly collect personal information about children under 13.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
- a parent, subsidiary, or affiliate of our company
- third-party service providers for the purpose of enabling them to provide their services,
including (without limitation) IT service providers, data storage, hosting and server
providers, analytics, error loggers, debt collectors, maintenance or problem-solving
providers, marketing providers, professional advisors, and payment systems operators
- our employees, contractors, and/or related entities
- our existing or potential agents or business partners
- credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail
to pay for goods or services we have provided to you
- courts, tribunals, regulatory authorities, and law enforcement officers, as required by law,
in connection with any actual or prospective legal proceedings, or in order to establish,
exercise, or defend our legal rights
- third parties, including agents or sub-contractors, who assist us in providing information,
products, services, or direct marketing to you
- third parties to collect and process data
- an entity that buys, or to which we transfer all or substantially all of our assets and
business
Third parties we currently use include:
- Google Analytics
- MailChimp
- TinyLetter
- Paypal
- Stripe
Your Rights and Controlling Your Personal Information
Your choice:
By providing personal information to us, you understand we will collect, hold,
use, and disclose your personal information in accordance with this privacy policy. You do not
have to provide personal information to us, however, if you do not, it may affect your use of
our website or the products and/or services offered on or through it.
Information from third parties:
If we receive personal information about you from a third
party, we will protect it as set out in this privacy policy. If you are a third party providing
personal information about somebody else, you represent and warrant that you have such
person’s consent to provide the personal information to us.
Marketing permission:
If you have previously agreed to us using your personal information
for direct marketing purposes, you may change your mind at any time by contacting us using
the details below.
Access:
You may request details of the personal information that we hold about you.
Correction:
If you believe that any information we hold about you is inaccurate, out of date,
incomplete, irrelevant, or misleading, please contact us using the details provided in this
privacy policy. We will take reasonable steps to correct any information found to be
inaccurate, incomplete, misleading, or out of date.
Non-discrimination:
We will not discriminate against you for exercising any of your rights
over your personal information. Unless your personal information is required to provide you
with a particular service or offer (for example processing transaction data), we will not deny
you goods or services and/or charge you different prices or rates for goods or services,
including through granting discounts or other benefits, or imposing penalties, or provide you
with a different level or quality of goods or services.
Downloading of Personal Information:
We provide a means for you to download the
personal information you have shared through our site. Please contact us for more
information.
Notification of data breaches:
We will comply with laws applicable to us in respect of any
data breach.
Complaints:
If you believe that we have breached a relevant data protection law and wish to
make a complaint, please contact us using the details below and provide us with full details of
the alleged breach. We will promptly investigate your complaint and respond to you, in
writing, setting out the outcome of our investigation and the steps we will take to deal with
your complaint. You also have the right to contact a regulatory body or data protection
authority in relation to your complaint.
Unsubscribe:
To unsubscribe from our email database or opt-out of communications
(including marketing communications), please contact us using the details provided in this
privacy policy, or opt-out using the opt-out facilities provided in the communication. We may
need to request specific information from you to help us confirm your identity.
Use of Cookies
We use “cookies” to collect information about you and your activity across our site. A cookie
is a small piece of data that our website stores on your computer, and accesses each time
you visit, so we can understand how you use our site. This helps us serve you content based
on preferences you have specified.
Please refer to our Cookie Policy for more information.
Business Transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or enter
bankruptcy, we would include data, including your personal information, among the assets
transferred to any parties who acquire us. You acknowledge that such transfers may occur,
and that any parties who acquire us may, to the extent permitted by applicable law, continue
to use your personal information according to this policy, which they will be required to
assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
Our website may link to external sites that are not operated by us. Please be aware that we
have no control over the content and policies of those sites, and cannot accept responsibility
or liability for their respective privacy practices.
Changes to This Policy
At our discretion, we may change our privacy policy to reflect updates to our business
processes, current acceptable practices, or legislative or regulatory changes. If we decide to
change this privacy policy, we will post the changes here at the same link by which you are
accessing this privacy policy.
If the changes are significant, or if required by applicable law, we will contact you (based on
your selected preferences for communications from us) and all our registered users with the
new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt
out of, as applicable, any new uses of your personal information.
Additional Disclosures for Australian Privacy Act Compliance (AU)
International Transfers of Personal Information
Where the disclosure of your personal information is solely subject to Australian privacy laws,
you acknowledge that some third parties may not be regulated by the Privacy Act and the
Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party
engages in any act or practice that contravenes the Australian Privacy Principles, it would not
be accountable under the Privacy Act, and you will not be able to seek redress under the
Privacy Act.
Additional Disclosures for General Data Protection Regulation (GDPR)
Compliance (EU)
Data Controller / Data Processor
The GDPR distinguishes between organisations that process personal information for their
own purposes (known as “data controllers”) and organizations that process personal
information on behalf of other organizations (known as “data processors”). We, Snap Club
LLC, located at the address provided in our Contact Us section, are a Data Controller with
respect to the personal information you provide to us.
Legal Bases for Processing Your Personal Information
We will only collect and use your personal information when we have a legal right to do so. In
which case, we will collect and use your personal information lawfully, fairly, and in a
transparent manner. If we seek your consent to process your personal information, and you
are under 16 years of age, we will seek your parent or legal guardian’s consent to process
your personal information for that specific purpose.
Our lawful bases depend on the services you use and how you use them. This means we only
collect and use your information on the following grounds:
Consent From You
Where you give us consent to collect and use your personal information for a specific
purpose. You may withdraw your consent at any time using the facilities we provide; however
this will not affect any use of your information that has already taken place. When you
contact us, you may consent to your name and email address being used so we can respond
to your enquiry. While you may request that we delete your contact details at any time, we
cannot recall any email we have already sent. If you have any further enquiries about how to
withdraw your consent, please feel free to enquire using the details provided in the Contact
Us section of this privacy policy.
Performance of a Contract or Transaction
Where you have entered into a contract or transaction with us, or in order to take preparatory
steps prior to our entering into a contract or transaction with you. For example, if you
purchase a product, service, or subscription from us, we may need to use your personal and
payment information in order to process and deliver your order.
Our Legitimate Interests
Where we assess it is necessary for our legitimate interests, such as for us to provide,
operate, improve and communicate our services. We consider our legitimate interests to
include research and development, understanding our audience, marketing and promoting
our services, measures taken to operate our services efficiently, marketing analysis, and
measures taken to protect our legal rights and interests.
Compliance with Law
In some cases, we may have a legal obligation to use or keep your personal information. Such
cases may include (but are not limited to) court orders, criminal investigations, government
requests, and regulatory obligations. If you have any further enquiries about how we retain
personal information in order to comply with the law, please feel free to enquire using the
details provided in the Contact Us section of this privacy policy.
International Transfers Outside of the European Economic Area (EEA)
We will ensure that any transfer of personal information from countries in the European
Economic Area (EEA) to countries outside the EEA will be protected by appropriate
safeguards, for example by using standard data protection clauses approved by the European
Commission, or the use of binding corporate rules or other legally accepted means.
Your Rights and Controlling Your Personal Information
Restrict:
You have the right to request that we restrict the processing of your personal
information if (i) you are concerned about the accuracy of your personal information; (ii) you
believe your personal information has been unlawfully processed; (iii) you need us to maintain
the personal information solely for the purpose of a legal claim; or (iv) we are in the process
of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing:
You have the right to object to processing of your personal
information that is based on our legitimate interests or public interest. If this is done, we must
provide compelling legitimate grounds for the processing which overrides your interests,
rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability:
You may have the right to request a copy of the personal information we
hold about you. Where possible, we will provide this information in CSV format or other easily
readable machine format. You may also have the right to request that we transfer this
personal information to a third party.
Deletion:
You may have a right to request that we delete the personal information we hold
about you at any time, and we will take reasonable steps to delete your personal information
from our current records. If you ask us to delete your personal information, we will let you
know how the deletion affects your use of our website or products and services. There may be
exceptions to this right for specific legal reasons which, if applicable, we will set out for you in
response to your request. Please be aware that search engines and similar third parties may
still retain copies of your personal information that has been made public at least once, like
certain profile information and public comments, even after you have deleted the information
from our services or deactivated your account.
Additional Disclosures for California Compliance (US)
Under California Civil Code Section 1798.83, if you live in California and your business
relationship with us is mainly for personal, family, or household purposes, you may ask us
about the information we release to other organizations for their marketing purposes.
To make such a request, please contact us using the details provided in this privacy policy
with “Request for California privacy information” in the subject line. You may make this type
of request once every calendar year. We will email you a list of categories of personal
information we revealed to other organisations for their marketing purposes in the last
calendar year, along with their names and addresses. Not all personal information shared in
this way is covered by Section 1798.83 of the California Civil Code.
Do Not Track
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want
to have your online activities tracked. At this time, we do not respond to browser “Do Not
Track” signals.
We adhere to the standards outlined in this privacy policy, ensuring we collect and process
personal information lawfully, fairly, transparently, and with legitimate, legal reasons for
doing so.
Cookies and Pixels
At all times, you may decline cookies from our site if your browser permits. Most browsers
allow you to activate settings on your browser to refuse the setting of all or some cookies.
Accordingly, your ability to limit cookies is based only on your browser’s capabilities. Please
refer to the Cookies section of this privacy policy for more information.
CCPA-permitted financial incentives
In accordance with your right to non-discrimination, we may offer you certain financial
incentives permitted by the CCPA that can result in different prices, rates, or quality levels for
the goods or services we provide.
Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your
personal information, and we will provide written terms that describe clearly the nature of
such an offer. Participation in a financial incentive program requires your prior opt-in consent,
which you may revoke at any time.
California Notice of Collection
In the past 12 months, we have collected the following categories of personal information
enumerated in the California Consumer Privacy Act:
- Identifiers, such as name, email address, phone number account name, IP address, and an
ID or number assigned to your account.
- Customer records, such as billing and shipping address, and credit or debit card data.
- Commercial information, such as products or services history and purchases.
- Audio or visual data, such as photos or videos you share with us or post on the service.
- Geolocation data.
For more information on information we collect, including the sources we receive information
from, review the “Information We Collect” section. We collect and use these categories of
personal information for the business purposes described in the “Collection and Use of
Information” section, including to provide and manage our Service.
Right to Know and Delete
If you are a California resident, you have rights to delete your personal information we
collected and know certain information about our data practices in the preceding 12 months.
In particular, you have the right to request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or
sold;
- The categories of third parties to whom the personal information was disclosed for a
business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
To exercise any of these rights, please contact us using the details provided in this privacy
policy.
Shine the Light
If you are a California resident, in addition to the rights discussed above, you have the right to
request information from us regarding the manner in which we share certain personal
information as defined by California’s “Shine the Light” with third parties and affiliates for
their own direct marketing purposes.
To receive this information, send us a request using the contact details provided in this
privacy policy. Requests must include “California Privacy Rights Request” in the first line of
the description and include your name, street address, city, state, and ZIP code.
Contact Us
For any questions or concerns regarding your privacy, you may contact us using the following
details:
Manjil Shrestha
info@snapclub.io
Snap Club LLC Acceptable Use Policy
This acceptable use policy covers the products, services, and technologies (collectively
referred to as the “Products”) provided by Snap Club LLC under any ongoing agreement. It’s
designed to protect us, our customers, and the general Internet community from unethical,
irresponsible, and illegal activity.
Snap Club LLC customers found engaging in activities prohibited by this acceptable use policy
can be liable for service suspension and account termination. In extreme cases, we may be
legally obliged to report such customers to the relevant authorities.
This policy was last reviewed on 22 March 2023.
Fair use
We provide our facilities with the assumption your use will be “business as usual”, as per our
offer schedule. If your use is considered to be excessive, then additional fees may be
charged, or capacity may be restricted.
We are opposed to all forms of abuse, discrimination, rights infringement, and/or any action
that harms or disadvantages any group, individual, or resource. We expect our customers
and, where applicable, their users (“end-users”) to likewise engage our Products with similar
intent.
Customer accountability
We regard our customers as being responsible for their own actions as well as for the actions
of anyone using our Products with the customer’s permission. This responsibility also applies
to anyone using our Products on an unauthorized basis as a result of the customer’s failure to
put in place reasonable security measures.
By accepting Products from us, our customers agree to ensure adherence to this policy on
behalf of anyone using the Products as their end users. Complaints regarding the actions of
customers or their end-users will be forwarded to the nominated contact for the account in
question.
If a customer — or their end-user or anyone using our Products as a result of the customer —
violates our acceptable use policy, we reserve the right to terminate any Products associated
with the offending account or the account itself or take any remedial or preventative action
we deem appropriate, without notice. To the extent permitted by law, no credit will be
available for interruptions of service resulting from any violation of our acceptable use policy.
Prohibited activity
Copyright infringement and access to unauthorized material
Our Products must not be used to transmit, distribute or store any material in violation of any
applicable law. This includes but isn’t limited to:
- any material protected by copyright, trademark, trade secret, or other intellectual property
right used without proper authorization, and
- any material that is obscene, defamatory, constitutes an illegal threat or violates export
control laws.
The customer is solely responsible for all material they input, upload, disseminate, transmit,
create or publish through or on our Products, and for obtaining legal permission to use any
works included in such material.
SPAM and unauthorized message activity
Our Products must not be used for the purpose of sending unsolicited bulk or commercial
messages in violation of the laws and regulations applicable to your jurisdiction (“spam”). This
includes but isn’t limited to sending spam, soliciting customers from spam sent from other
service providers, and collecting replies to spam sent from other service providers.
Our Products must not be used for the purpose of running unconfirmed mailing lists or
telephone number lists (“messaging lists”). This includes but isn’t limited to subscribing email
addresses or telephone numbers to any messaging list without the permission of the email
address or telephone number owner, and storing any email addresses or telephone numbers
subscribed in this way. All messaging lists run on or hosted by our Products must be
“confirmed opt-in”. Verification of the address or telephone number owner’s express
permission must be available for the lifespan of the messaging list.
We prohibit the use of email lists, telephone number lists or databases purchased from third
parties intended for spam or unconfirmed messaging list purposes on our Products.
This spam and unauthorized message activity policy applies to messages sent using our
Products, or to messages sent from any network by the customer or any person on the
customer’s behalf, that directly or indirectly refer the recipient to a site hosted via our
Products
Unethical, exploitative, and malicious activity
Our Products must not be used for the purpose of advertising, transmitting, or otherwise
making available any software, program, product, or service designed to violate this
acceptable use policy, or the acceptable use policy of other service providers. This includes
but isn’t limited to facilitating the means to send spam and the initiation of network sniffing,
pinging, packet spoofing, flooding, mail-bombing, and denial-of-service attacks.
Our Products must not be used to access any account or electronic resource where the group
or individual attempting to gain access does not own or is not authorized to access the
resource (e.g. “hacking”, “cracking”, “phreaking”, etc.).
Our Products must not be used for the purpose of intentionally or recklessly introducing
viruses or malicious code into our Products and systems.
Our Products must not be used for purposely engaging in activities designed to harass
another group or individual. Our definition of harassment includes but is not limited to denial-
of-service attacks, hate-speech, advocacy of racial or ethnic intolerance, and any activity
intended to threaten, abuse, infringe upon the rights of, or discriminate against any group or
individual.
Other activities considered unethical, exploitative, and malicious include:
- Obtaining (or attempting to obtain) services from us with the intent to avoid payment;
- Using our facilities to obtain (or attempt to obtain) services from another provider with the
intent to avoid payment;
- The unauthorized access, alteration, or destruction (or any attempt thereof) of any
information about our customers or end-users, by any means or device;g our facilities to obtain (or attempt to obtain) services from another provider with the
intent to avoid payment;
- Using our facilities to interfere with the use of our facilities and network by other customers
or authorized individuals;
- Publishing or transmitting any content of links that incite violence, depict a violent act,
depict child pornography, or threaten anyone’s health and safety;
- Any act or omission in violation of consumer protection laws and regulations;
- Any violation of a person’s privacy.
Our Products may not be used by any person or entity, which is involved with or suspected of
involvement in activities or causes relating to illegal gambling; terrorism; narcotics trafficking;
arms trafficking or the proliferation, development, design, manufacture, production,
stockpiling, or use of nuclear, chemical or biological weapons, weapons of mass destruction,
or missiles; in each case including any affiliation with others whatsoever who support the
above such activities or causes.
Unauthorized use of Snap Club LLC property
We prohibit the impersonation of Snap Club LLC, the representation of a significant business
relationship with Snap Club LLC, or ownership of any Snap Club LLC property (including our
Products and brand) for the purpose of fraudulently gaining service, custom, patronage, or
user trust.
About this policy
This policy outlines a non-exclusive list of activities and intent we deem unacceptable and
incompatible with our brand.
We reserve the right to modify this policy at any time by publishing the revised version on our
website. The revised version will be effective from the earlier of:
- the date the customer uses our Products after we publish the revised version on our
website; or
- 30 days after we publish the revised version on our website.
USE of Your Google User Data
Subject to all other provisions in this Privacy Policy, if you grant us access to certain types of your Google data, the usage of that data will adhere to
Google API Services User Data Policy, including the Limited Use requirements.It will also be governed by the following additional restrictions:
We will solely utilize access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to facilitate a web email client. This client enables users to compose, send, read, and manage emails. We will not disclose this Gmail data to any third parties, except when necessary to furnish and enhance these features, comply with applicable laws, or as part of a merger, acquisition, or asset sale.
Under no circumstances will we employ this Gmail data for serving advertisements.
We will not permit any human access to read this data unless we have received your explicit consent for specific messages. Such access may be necessary for security reasons, such as investigating abuse, complying with applicable laws, or for our internal operations. Even in these cases, access will only be granted when the data have been aggregated and anonymized.