We are committed to protecting and respecting your privacy. This policy describes what personal information we collect from you (and how we use it) via the Snap Fashion website located at www.snapfashion.co.uk and Snap Tech website located at https://www.snaptechnology.co.uk (referred to as “the Website”), the Snap Fashion Android and iOS Apps, Snap ColourPop Android and iOS Apps, (referred to as “the Apps”) (the Website and the Apps are together referred to as “the Services”).
Please read this policy carefully before you start to use any of the Services. By using any of the Services, you are indicating that you agree to this policy. If you do not agree to this policy, please do not use any the Services.
We hope this policy helps you to understand our privacy commitments to you. If you ever have any questions or concerns, then please contact us at [email protected]. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use Snap Fashion.
2. WHO ARE WE?
The Services are operated by Snap Tech Ltd (previously known as Snap Fashion Ltd) (referred to as "we" or “us”). We are a limited company registered in England and Wales under company number 07701980 and have our registered office at 4th Floor, Greenworks, Dog and Duck Yard, Princeton Street, London, WC1R 4BH.
For the purposes of data protection law, Snap Tech Ltd may be referred to as the “data controller”.
3. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
We may collect and use the following personal information from you:
- Information you provide by filling in forms on the Services. This includes information provided at the time of registration or subscription, uploading any content or material or requesting further services. Such information includes a) name, b) contact information including email address, c) demographic information d) Facebook and Google user id if you created a Snap Fashion account using Facebook or Google
- We may also ask you for information when you enter a competition or promotion administered by us or when you report a problem with the Services.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of any transactions you carry out through the Services.
- Details of your visits and use of the Services including, but not limited to, traffic data, location data, weblogs and other communication data.
4. IP ADDRESSES AND OTHER INFORMATION IDENTIFYING YOUR DEVICE
We may collect information about your device, including where available your IP address and/or your iPhone’s “UDID”, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
A cookie is a small file of letters and numbers that we store on you device if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into secure areas of our Services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Services when they are using them. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our Services. This enables us to personalise our content for you, greet you by name and remember your preferences.
- Targeting cookies. These cookies record your visit to our Services, the pages you have visited and the links you have followed. We will use this information to make our Services and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.
You block cookies by activating the setting on your device that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Service.
6. WHERE WE STORE YOUR PERSONAL INFORMATION AND SECURITY
The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (referred to as the "EEA"). It may also be used by staff operating outside the EEA who work for us or for one of our suppliers (e.g. in order to provide support services). By submitting your personal information, you agree to this transfer, storing and use. In all cases, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this policy.
Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Snap Fashion Service.
7. USES MADE OF YOUR PERSONAL INFORMATION
We may use the personal information held about you in the following ways:
- To ensure that content from our Services are presented in the most effective manner for you and for your device.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our Services, when you choose to do so.
- To notify you about changes to our Services.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail.
Where we have your consent, we may also permit selected third parties to use your personal information to provide you with information about products and/or services which may be of interest to you.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate anonymous information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
We have a legitimate interest in obtaining and using the information as set out above in being able to provide and improve the service and marketing that you receive from us. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Account.
8. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to third parties as follows:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets.
- If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions; or to protect our or our users’ rights, property, or safety. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
9. YOUR RIGHTS
You have the right to ask us not to use your personal information for marketing purposes. We will request your permission (before collecting your personal information) if we intend to use it for such purposes or if we intend to disclose it to any third party for such purposes.
You can exercise your right to prevent such use either by checking certain boxes on any forms or profile pages made available on our Services or by contacting us at [email protected], or at 4th Floor, Greenworks, Dog and Duck Yard, Princeton Street, London, WC1R 4BH. More information on controlling your personal information is included included in the following section.
Our Services may, from time to time, contain links to and from other third party websites and services not controlled by us (such as social media platforms like Facebook or Twitter). Please note that these websites and services may have their own privacy policies. We do not accept any responsibility or liability for these third party websites and/or services. Please check their privacy policies before you submit any personal information to them.
You also have the right to access personal information held about you. You can exercise this right of access as outlined in more detail in the following section, or by contacting us at: 4th Floor, Greenworks, Dog and Duck Yard, Princeton Street, London, WC1R 4BH.
10. CONTROLLING YOUR PERSONAL INFORMATION
You may exercise any of the rights described in this section by sending an email to [email protected]. Please note that we will ask you to verify your identity before taking further action on your request. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Managing Your Information
You may access and update some of your information through your Account settings.
Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Account).
Data Access and Portability
You have the right to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data Retention and Erasure
We generally retain your personal information for as long as necessary to provide you with the Snap Fashion service. If you no longer want us to keep your information, you can request that we erase your personal information and close your Snap Fashion Account. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Snap Fashion Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user from opening a new Snap Fashion Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
- Additionally, some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
Withdrawing Consent and Restriction of Processing
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. Where you have provided your consent to the processing of your personal information by Snap Tech you may withdraw your consent at any time by sending a communication to Snap Tech specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, you have the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to the following paragraph and pending the verification whether the legitimate grounds of Snap Tech override your own.
Objection to Processing and Profiling
You are entitled to require Snap Tech not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Snap Tech will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
The security of your data is very important to us. With this in mind we will take all appropriate steps to protect your data and will treat it with the utmost care and attention. We use SSL technology to secure access to all areas of our websites and apps. Access to your personal data is password-protected. We ensure that our systems are regularly monitored for possible vulnerabilities and attacks.
You have the right to lodge complaints about the data processing activities carried out by Snap Tech before the Information Commissioner's Office. In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email protected]
We will not sell, distribute or lease your personal information to third parties unless we have your permission, are required by law to do so or it is required for the provision of our services as detailed above. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
11. CHANGES TO THIS POLICY
We may revise this policy at any time. You are expected to check this page from time to time to take notice of any changes we may have made. Your continued use of the Services after any such changes have been made will constitute your acceptance of the updated policy.
12. YOUR CONCERNS
If you have any concerns or contact us about this policy, please contact [email protected]
This policy was last updated on 24 May 2018.