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Privacy Policy

Effective Date: October 2023

Snappt (“Snappt,” “we,” “our,” or “us”) is committed to protecting your privacy and the security of your information. This Privacy Policy explains the types of personal information we collect from our website visitors, customers, and other individuals when they visit our website (www.snappt.com) and related sites and web-based services (our “Site”) as well as through the use of Snappt’s products and services (collectively, the “Services”). This Policy also describes how we use personal information, the purpose(s) for sharing and recipients of personal information, and your rights and choices as to that information.

Snappt obtains personal information about you from different sources to provide and manage our Site and Services. “You” may be a visitor to Site, an organization that uses our Services (“Customer”) or an applicant of a Customer (“User”).

Snappt provides antifraud and related services to its Customers, and in doing so, collects and handles personal information on behalf of each Customer and for that Customer’s exclusive benefit. In order to ensure that you are provided with the most detail regarding our collection, use, and sharing of personal information when acting for and on behalf of our Customers, this Privacy Policy includes disclosures about that activity as well. We have noted throughout this Policy where our data collection, use, and sharing is performed on behalf of our Customers, but please keep in mind that certain disclosures may be on our Customers’ behalf rather than Snappt’s own. In addition to the below disclosures, we encourage you to review the privacy policies of the Customers to which we are providing services information.

This Privacy Policy explains the following:

  • Collection of Personal Information
  • Use of Personal Information
  • Sharing of Personal Information
  • Your Rights and Choices
  • Links to Other Sites
  • Children’s Privacy
  • Data Security
  • Ownership
  • Keep Yourself Safe
  • Responsible Disclosure
  • International Data Transfers
  • Updates to This Privacy Policy
  • Contact Information

1. Collection of Personal Information

Personal information is any information that relates to an identified or identifiable individual. Personal information does not include publicly available information or information that has been anonymized, de-identified, or aggregated. Personal information we collect will be apparent by the context of the page or your interactions with us, and generally includes personal information you choose to provide us and personal information we collect as your interact with our Sites and Services.

a. Personal information you provide to us
Personal information we collect will be apparent by the context through which it is provided, and may include, but is not limited to, the following:

    • When you request a demo of our Services or otherwise contact us by providing your email address, name, company name, and telephone number
    • When you communicate with us via email, phone, fax, text, or by any other means, and provide your personal information over the course of those communications
    • When you otherwise provide us with your personal information in order to receive our Services or information relating to our Services, including as a User on behalf of and for the exclusive benefit of one of our Customers for fraud prevention and identity verification. This may include:
      • Contact information such as name, age, address, email address, phone number;
      • Personal information that may be contained in, or otherwise reflected by, records that are uploaded to our platform in connection with our Customer, including bank and payment card statements, investment account statements, government identification numbers (such as tax identification number, Social Security number, I-20 number, and any similar numbers you provide), tax statements, utility bills, paystubs and pay statements, Social Security statements and documents, and records evidencing employment, immigration, and/or veteran status
      • Personal information that you may provide for identity verification purposes in connection with our Customer, including your photograph and certain biometric data based on your photograph, as further detailed in Section 1(d) below.

b. Information that we automatically collect
Our Sites use cookies and other tracking technologies (such as web beacons, embedded scripts, tags) which collect information from you automatically, including:

  • Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Sites you are visiting; and
  • Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
  • Information automatically collected on behalf of and for the exclusive benefit of Snappt Customers through Customer access portals, including browsing data, session data, and other information about User activity.
  • We use third party analytics services on our Sites to help us analyze your use of our Sites and diagnose technical issues.

c. Information collected from third-party sources

  • Our service providers. We may receive personal information about you from our service providers, such as those that conduct payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. Please review the remainder of this Privacy Policy to learn more about how and why we use this information.
  • Our Customers. We may receive personal information about you from our third party Customers, who have engaged us as their service provider to render Services to them. Our collection and use of this personal information is subject to any notices and agreements between you and the Customer.
  • Other third parties. We may receive personal information about you from third party sources, including things that other third parties may post publicly about you or otherwise provide to us.

d. Biometric information disclosure
In some circumstances, we may require you to provide your government photo identification and to take a photo of yourself in connection with the identity verification services that we provide on behalf of our Customers. These photos may be received and processed by our third party service providers, with which we may subcontract to provide these services for the exclusive benefit of our Customers. In some cases, these providers may create data based upon your photograph and/or facial image in order to assist with identify verification through facial recognition technology or similar technology. We only process this information for the specific purposes listed under Sections 2 and 4(b)(iii) of this Privacy Policy, and we do not sell, share, or disclose or otherwise use this information for any other purposes. We retain this information for as long as required under applicable law. Where a third-party service provider assists with receiving and processing this information, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

Snappt allows you to submit customer support requests through automated chat messaging services available on the Services. Communications through automated chat messaging services are collected, recorded, and used by Snappt for its own business purposes via its third party vendor.

2. Use of Personal Information

We use the personal information we collect to provide, maintain and improve our Sites and Services, including:

  • To provide fraud prevention and identity verification services on behalf of and for the exclusive benefit of Snappt Customers;
  • To enter into a contract for the sale of goods or services, to bill you for products or services, and to process payment transactions;
  • To provide you with customer support, including to contact you in response to an inquiry that you sent and to send administrative messages, technical notices, updates, alerts and other information;
  • To provide you with better products and services and improve and grow our business, including to perform research and development, understand our customer base and purchasing trends, and understand the effectiveness of our marketing; and
  • To operate and maintain safe, secure and reliable Sites and Platform.

We may also use your personal information to send you promotional communications about our Services. You may opt out of receiving any, or all, of these communications from us via the unsubscribe link provided in such emails or by following further instructions provided in Your Rights and Choices.

Snappt allows you to submit customer support requests through automated chat messaging services available on the Services. Communications through automated chat messaging services are collected, recorded, and used by Snappt for its own business purposes via a third party vendor, which is contractually limited to use the submitted information exclusively to render such services to Snappt.

3. Sharing of Personal Information

Snappt may share your personal information with the following trusted entities:

  • Our service providers, as necessary to provide services on our behalf, such as website hosting, data analysis, marketing, email delivery, technical support, customer service, and analytics, including without limitation, those services providers listed at https://www.snappt.com/msa.
  • Our Customers as necessary to provide, maintain, and develop our Sites and Services.
    Pursuant to a business transaction, subject to applicable law, in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the personal information collected by us in the same manner that we are able to use it, and the purchaser will assume the rights and obligations regarding personal information as described in this Privacy Policy.
  • Compliance and harm prevention, including to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We also may provide information in order to investigate, prevent, or take action regarding illegal activities or wrongdoing; to protect the rights, property, or safety of Snappt, its users, and others; to enforce our agreements; or as otherwise required by law.

We may create anonymous or de-identified data from personal information by removing data components that make the data personally identifiable to you or through obfuscation or other means. We may analyze any data we aggregate or de-identify and share our analyses at our discretion. Our use of anonymized and de-identified data is not subject to this Privacy Policy.

4. Your Rights and Choices

You may have rights and choices regarding our use and disclosure of your personal information. Unless instructed otherwise, you can exercise these rights and choices by emailing us at [email protected] or mailing us a letter to 226 W Ojai Ave, Ste 101-419, Ojai, CA 93023.

a. Opting out of receiving electronic communications from us.

If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or by emailing us at [email protected]. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with our Services.

b. Your California privacy rights.

i. Right to request information regarding third-party direct marketing

California residents have the right to request information from Snappt regarding third parties to whom we have disclosed certain categories of personal information during the preceding year for those third parties’ direct marketing purposes under California’s “Shine the Light” law. We do not currently disclose this type of personal information to third parties for their own purposes. However, if you are a California resident and would like to inquire further, please email us at [email protected] with “California Privacy Rights” as the subject line or write to us at 226 W Ojai Ave, Ste 101-419, Ojai, CA 93023

You must include your full name, email address and postal address in your request so that we can verify your California residence and respond.

In addition, California residents are entitled to certain consumer privacy rights related to their personal information under the California Consumer Privacy Act (“CCPA”). As a platform and service provider that collects personal information in order to provide our Sites and Services to Customers, the CCPA may apply to the personal information we hold about you on behalf of our Customers. If you are a User and California resident, please direct any CCPA-related requests directly to the relevant Customer (e.g., your property manager).

ii. Personal information we collect
For the purposes of this section, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de identified or aggregated, or other information covered by certain sector-specific privacy laws. For purposes of this section, “publicly available information” includes: information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

We may have collected the following categories of personal information about you over the last twelve (12) months, including on behalf of our Customers as further described in Section 1 of this Privacy Policy:

  • Identifiers, such as name, email, address, company name, telephone number, IP address, I-20 number, tax identification number, Social Security number, and any other government identification numbers you provide, and any other identifiers you provide when you communicate with us.
  • Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing and consuming histories or tendencies as it relates to our Customers.
  • Information relating to Internet activity or other electronic network activity, including IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language preferences, plug-ins, add-ons, the language version of the Sites you are visiting, time spent on the Sites, pages visited, links clicked, the pages that led or referred you to our Sites, and information automatically collected on behalf of and for the exclusive benefit of Snappt Customers through Customer access portals, including browsing data, session data, and other information about User activity.
  • Geolocation data.
  • Visual information, including images from your government photo ID.
  • Biometric information, including faceprint.
  • Professional or employment-related information, including paystub information.
  • Information related to characteristics protected under California or federal law, including date of birth, gender, racial and/or ethnic origin, and veteran and/or military status.
  • Other personal information not listed above and described in California Civil Code § 1798.80(e), including identifiers, information about financial and investment accounts, information about credit and debit cards, and digital payment platform information.
  • Inferences about you, based on any of the above.

Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.

Sensitive personal information. Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” under California law, including personal information that we may collect on behalf of our Customers as described in Section 1(a) of this Privacy Policy. This may include:

  • Social security, driver’s license, and any other government identification numbers you may provide;
  • Racial and/or ethnic origin; and
  • Biometric information.

The specific types of personal information we collect are further detailed in Section 1 of this Privacy Policy. Personal information does not include information excluded from the scope of California privacy law.

iii. Use of Personal Information

We use the personal information we collect from you for the purposes outlined in Section 2 above.

We may use the categories of sensitive personal information identified in Section 4(b)(i) for fraud prevention and identity verification on behalf of our Customers.

We will not retain any personal information we collect about you for longer than is reasonably necessary for the disclosed purpose of using such personal information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

iv. Sources of personal information

We may collect personal information from the sources described in Section 1(a) – (c), including from you, through our Sites using cookies and other tracking technologies, from our service providers, our Customers, and other third parties.

v. Sharing of personal information

We may disclose your personal information to the categories of service providers and third parties as detailed in Section 3. This includes disclosure of your personal information to service providers and/or contractors for one or more business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract with us and/or with our Customers.
We “sell”/“share” your personal information with third parties as those terms are defined by California law, but only in the context of sharing your personal information with third party advertising platforms to facilitate targeted digital advertising. These third party partners may use technologies, such as cookies and pixels, to gather information about your activities on the Services to deliver such advertising to you when you visit their platforms. Please also review our disclosures in Sections 1 – 3 of this Privacy Policy.
California law also requires that we state that we have no actual knowledge that we have sold/shared personal information of minors under 16 years of age.
In the last twelve (12) months, we have disclosed (or “shared”) the following categories of personal information to advertising partners for cross-context behavioral advertising purposes:

  • Identifiers; and
  • Internet or other electronic network activity information

v. Your California privacy rights

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal information:

  • Right to Know and Access. You may have the right to request what personal information we collect, use, disclose, and/or sell, as applicable. You may request either a report disclosing the general categories of the personal information we collect, or a report disclosing the specific pieces of personal information we collect.
  • Right to Delete. You have the right to request the deletion of your personal information that is collected or maintained by us.
  • Right to Opt-Out of Sale/Sharing of my Personal Information. You have the right to request to be opted out from any sales/sharing of your personal information by us, as those terms are defined under California law. This opt-out will not change your preferences with respect to the receipt of marketing and other communications from the Company. Information about how to exercise these rights is set forth in Section 7(h) (“Notice of Right to Opt-Out”) below.
  • Right to Correct. You have the right to request the correction of your inaccurate personal information.
  • Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our products and services to you, or for certain other authorized purposes. As disclosed elsewhere in this Section, we currently only use your sensitive personal information for the necessary purposes described above.
  • Right to Non-Discrimination. You have the right not to be denied goods or services, charged different prices or rates for goods or services, or receive a differing level of quality of goods or services as a result of exercising the above rights.

vi. Exercising your rights

If you are a California resident and wish to seek to exercise any of the rights in Section (v) above (other than your right to request information regarding third party direct marketing which must follow the process set forth in the last bullet above), please reach us in one (1) of the following ways:

  • By submitting a request to the Customer you have submitted personal information to Snappt in connection with (for example, by visiting their website)
  • Our webform
  • Email us at [email protected]
    By mail at:
    Snappt:
    226 W Ojai Ave
    Ste 101-419
    Ojai, CA 93023

You may also authorize someone to exercise the above rights on your behalf. If you should use an authorized agent to exercise the above rights, we may require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us. We do not collect personal information about minors. We do not collect household-level data. If we receive a request submitted by all members of a household, we will individually respond to each request.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests, which requires to you provide, at a minimum, your first and last name and email address that is connected to your online account. After you make a request to exercise these rights, you may receive an email requesting that you verify your identify. We will respond to your request only after your identity has been verified. Note that these rights are also subject to various exclusions and exceptions under applicable laws.

vii. Notice of Right to Opt Out

We may “sell”/ “share” personal information, as those terms are defined under California law, with third parties for purposes of cross-context behavioral advertising, as that term is defined under California law.

If you wish to opt-out of this “selling”/ “sharing” of the limited personal information that is gathered when you visit the Services for purposes of cross-context behavioral advertising, please use the information Section 4(b)(vi) above.

c. Your Nevada privacy rights

Nevada residents have the right to request to opt out of any “sale” of their personal information under Nevada SB 220. We do not currently sell personal information under Nevada law. However, you may still request to opt out of the future sale of your personal information. If you are a Nevada resident and would like to make such a request, please email us at [email protected] with “Nevada Privacy Rights” as the subject line or write to us at 226 W Ojai Ave, Ste 101-419, Ojai, CA 93023. You must include your full name, email address and postal address in your request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.

5. Links to Other Sites

Our Sites may contain links or otherwise provide access to other third-party sites, which may include websites, mobile applications, or other web-based services. Please note that we have no control over and are not responsible for third-party sites, their content, or any products or services available through the third-party sites. Our Privacy Policy does not apply to third-party sites. We encourage you to read the privacy policies of any third-party sites with which you choose to interact.

6. Children’s Privacy

We do not knowingly collect personal information from individuals under the age of 13 years without parental consent. No personal information should be submitted to our Sites by individuals under the age of 13. If we learn we have collected or received personal information from a child under the age of 13 without parental consent, we will delete that personal information as permitted by law. If you believe we may have any collected personal information from a child under the age of 13 without parental consent, please submit a written request via email to [email protected].

7. Data Security

Snappt uses bank-level commercially reasonable security standards, procedures, and processes to help protect your information against unauthorized access, destruction, alteration, misuse, or loss. Snappt uses HTTPS to ensure that your data is transmitted securely.

To protect your privacy, we limit the amount of sensitive data we store on our servers. For example, we do not store the contents of credit reports or background checks, or credit card numbers. When we do store financial information, we encrypt and protect that data on secure servers.

We designed and built all our systems with multiple levels of security, and we manage them according to industry best practices. Our hosting provider maintains world-class facilities that are certified to the highest levels of physical and virtual security. Reputable third-party security firms perform regular internal and external security audits of our systems, something we consider an essential investment.

Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.

8. Ownership

When you use Snappt, you own and control your information. We limit access to your information whenever possible. Landlords must verify their identities before viewing credit reports and background checks, or receiving payments.

All Snappt employees receive thorough training before accessing customer data, and we comply with the Fair Credit Reporting Act (FCRA) and the Gramm–Leach–Bliley Act (GLBA). We share information securely with trusted third parties only when needed—to provide services, prevent fraud, and meet legal requirements.

9. Keep Yourself Safe

Even though we review every financial transaction for fraud, we recommend only sending payments to people you know. The same goes for sharing your information. If you have any questions or concerns about safety or security, please contact us at [email protected].

10. Responsible Disclosure

We take security seriously and we appreciate your help in notifying us of vulnerabilities in a responsible manner. If you are a security researcher and have found a potential security vulnerability in our systems, please send details to [email protected].

11. International Data Transfers

Our Site is operated in the U.S. and intended for users located in the U.S. We may transfer, store and use the information we collect and maintain about you, including personal information outside of your state, province, country or other governmental jurisdiction. The data protection laws in the jurisdiction in which we process personal information may differ from those of your jurisdiction, and in certain circumstances, your personal information may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions. By using the Site or providing us with any information, you consent to the transfer and processing of your information, including personal information, in the U.S. and elsewhere as set forth in this Privacy Policy.

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. The date this Privacy Policy was last updated is identified at the top of this page. Any changes are effective when we post the revised Privacy Policy on the Sites. If we make material changes to this Privacy Policy that expand our rights to collect new personal information or to use differently any personal data that we have previously collected about you, we will notify you and provide you with the disclosure by posting it on our Sites and/or via email. We encourage you to review this Privacy Policy often to stay informed of how we may process your personal data.

13. Contact Us

If you would like to submit a privacy rights request as detailed above, or if you have any questions or concerns about this Privacy Policy or our privacy practices, please email us at [email protected] or write to us or call us using the information below:

Snappt:
226 W Ojai Ave
Ste 101-419
Ojai, CA 93023

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