Privacy Policy Statement

Privacy Policy Statement
Photo by Dan Nelson / Unsplash

Snapano.com is operated by SNAPANO LLC (hereinafter referred to as "Snapano" or "we") and provides services or products to you, we understand the importance of privacy to you and fully respect your privacy. Before submitting your personal information to us, please read this Privacy Policy Statement (hereinafter referred to as "this Statement") carefully. Unless otherwise specified, this Statement applies to your login and access to the website https://www.snapano.com and the purchase and use of services and products provided by us (hereinafter referred to as "Services"). This Statement does not apply to the content that we process, store or host in Snapano as trustees.

"Your Content" means all information (including personal information), software, equipment, text, images, video, audio, photographs, Third Party Applications, and Materials. Our materials, data, and information are not yours.

This Statement describes how we collect, use, share and disclose your personal information, your rights and the legal basis for personal processing information, and the security measures we take to protect your personal information. Additional relevant details to know before providing personal information. We may inform you of information collection for specific services or products that are not reflected in this Statement by means of a service statement or privacy notice before the relevant personal information is collected. When using a specific service or product, in addition to this Statement, you are also advised to read the relevant service statement or privacy notice.

We have made this Statement to help you understand:

1. How Snapano collects your personal information

2. How Snapano uses your personal information

3. How Snapano uses cookies and similar technologies

4. How Snapano shares and discloses your personal information

5. How Snapano protects your personal information

6. Retention period of personal information

7. How to access or control your personal information

8. How Snapano handles personal information of minors

9. How your personal information is transferred

10. How is this Statement updated

11. How to contact Snapano

1. How Snapano collects your personal information

Personal information refers to various information related to identified or identifiable natural persons recorded electronically or in other ways, excluding anonymized information. Sensitive personal information is personal information that, once leaked or illegally used, may easily lead to the infringement of the personal dignity of a natural person or endanger personal and property safety. A personal information processor refers to an organization or individual who independently decides the purpose and method of processing in personal information processing activities.

We collect your personal information for necessary purposes during your interaction with us; for example, to provide you with services, we will collect the following personal information in the following scenarios:

A) Account management: When you use a user account, you need to collect your user name, mobile phone number, email address and account information (account name, account ID and password, key). In order to protect the security of your Snapano account information, you need to Collect your email, mobile phone number.

b) Address management: When you use the address management service, you need to collect your recipient's name, detailed address, zip code, and mobile phone number.

c) Message center: When you use the message center service, including when you use the new administrator service, you need to collect your name, email, and mobile phone number.

d) Support and Services: Personal information provided when you request support or assistance from us. For example, when you create a new work order and obtain professional services, you need to collect your user name, email address, mobile phone number, and the consultation records and call recordings you left when you contact us for corresponding support.

e) Shopping: When you purchase services or products, you need to collect your order information and transaction information.

f) Personal information provided when you contact us, use the Services or request assistance. Such as contact information (account identifiers such as account name and account ID address) and business information (company name, industry, position).

g) Personal information that we need to obtain and automatically record when you access or use the Services. For example, your browsing history, access date and time, browser information (including but not limited to fonts and types) and network link information (including but not limited to IP address, port, network protocol).

The above scenarios may involve the collection of your sensitive personal information, including your identity document, biometrics (static or dynamic facial features) and detailed address, payment information (bank card number, bank statement) and invoice information. The purpose of the information includes fulfilling the requirements of relevant laws and regulations for online real-name authentication, verifying your user identity, providing you with consultation or technical support, issuing bills, sending goods, and registering for competitions and events.

2. How Snapano uses your personal information

We use your personal information for the following purposes:

a) Use, login and verification: When you use Snapano services and products, provide you with identity authentication, authority management to protect the security of services and products, contact you, send you important notices, etc.

b) To perform our contractual obligations with you. For fulfilling your transaction or service request, including ordering, requesting changes or providing information you request (such as materials about the service), delivering, activating or verifying the service; providing technical support, and enhancing the security of the service.

c) Respond to your interaction requests. When you visit our website, participate in online or offline events, request changes, or request information you request (such as marketing materials for services or products, white papers, e-magazine subscriptions), and contact us with any questions or product information When contacting (such as providing technical support, providing us with comments, suggestions, inquiries, etc.), we reply to your inquiries, comments or suggestions to us, or send you event gifts, etc.

d) Recommend relevant content, services or products for you. With your consent, to send you information about services and products that may be of interest to you; to invite you to participate in Snapano events (including promotions), market surveys or satisfaction surveys; or when you visit online platforms such as the website You provide personalized content and services. With your consent, we will track and analyze various types of data, including your personal information, through automated or semi-automated processes, and on this basis, provide you with a personalized user experience and recommend personalized content. You provide a convenient way to decline. You may submit your refusal request to us directly through the following personal information rights subject request page: https://www.snapano.com/personal-data-request.html.

e) In order to fulfill legal obligations, ensure the reliable, safe and stable operation of services or products, optimize services and products, etc., we will also use your personal information for the following purposes:

1) Troubleshoot errors if you choose to send us error details.

2) To protect the safety of our services, products and customers or users, and to implement and improve our loss prevention and anti-fraud programs.

3) To carry out internal audit and data analysis and research to improve our services.

4) Comply with and enforce applicable legal requirements, relevant industry standards or our policies.

3. How Snapano uses cookies and similar technologies

We sometimes store cookies on computers or mobile devices in order to ensure the website or the proper functioning of the site. For details on our use of cookies and similar technologies and how they process your personal information, please see our Cookie Policy.

4. How Snapano shares and discloses your personal information

4.1 Sharing

We will not share your personal information with third parties, except in the following cases:

a) Sharing with your express consent. After informing you of the third party's name or name, contact information, processing purpose, processing method and type of personal information, and after obtaining your explicit consent, Snapano will share the information within the scope of your authorization with the third party you have agreed to;

b) Sharing under statutory circumstances. Your personal information needs to be shared in accordance with applicable laws and regulations, legal procedures, litigation/arbitration, government mandatory orders, and regulatory requirements; for example, in order to meet the online real-name authentication requirements of relevant laws and regulations, you may request the relevant government agencies or their designation, approval share your personal information with third parties;

c) To the extent required or permitted by law, it is necessary to provide your personal information to a third party in order to protect the interests, property or safety of you or the public from harm;

d) In order to protect national security, public safety and the significant legitimate rights and interests of you and other individuals, it is necessary to share your personal information;

e) Your personal information disclosed by you or we can obtain your personal information from other legitimate public channels;

f) Sharing with business partners as necessary to provide services. We may share your order information, account information, and device information with partners and other third parties to ensure the smooth completion of the services provided to you. However, we will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide services. Our partners include:

1) The trustee of the product or service. We may provide your personal information to trustees who support the functions of this platform as necessary to provide services. These supports include: providing warehousing, logistics, customer service and other services. When you use Snapano services, we may provide your personal information to these trustees, who will provide you with logistics and delivery, order inquiry, order payment, after-sales service, customer support (such as installation services), billing, and Partner reconciliation, payment institution survey response, prize distribution, service or product content recommendation and other services. If you have activated or linked our services or products to third-party platforms or social media (such as direct login, virtual login, or linked login through a third-party website), we may associate your personal information is disclosed. We do not control the use of your personal information by third parties.

2) Third-party partners. For the purpose of providing services, we may share your account information, contact information, order information, necessary transaction information and transaction dispute information with cloud service providers and partners to fulfill your needs for purchasing goods or services from them. And enable merchants to complete commodity sales, after-sales service and service delivery.

4.2 Disclosure

We may disclose personal information to third parties in the following circumstances:

a) Disclosure is required in accordance with applicable laws and regulations.

b) Disclosure is necessary to protect the rights or property of Snapano users and/or the public. For example, when we believe disclosure is necessary or appropriate to prevent or protect against cyber threats, fraud, personal injury or financial loss, or when it is related to an investigation of suspected or actual illegal activity.

We only disclose your personal information to the extent permitted by applicable laws and regulations and in accordance with this Statement.

4.3 Third-party SDK

During your use of Snapano, some services need to be jointly provided by Snapano and third-party partners, such as social sharing, etc. For this purpose, we have integrated the software tool development kits ("SDK") of third-party partners or other similar applications.

We have no control over the privacy and data protection policies of third parties and such third parties are not bound by this Statement. Before submitting personal information to a third party, please refer to the third party's privacy policy.

5. How Snapano protects your personal information

We value the security of your personal information. We employ appropriate physical, administrative and technical safeguards to protect your personal information. For example, we will use encryption technology to ensure the confidentiality of information; we will use protection mechanisms to prevent malicious attacks on information; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will conduct security and privacy protection Training to enhance employees' awareness of the importance of protecting personal information. We do our best to protect your personal information, but please be aware that no security measure can be perfect. In particular, to protect your personal information, we have taken the following measures:

a) We take reasonable and practicable measures to ensure that the collection of personal information is minimised and that personal information not related to the purpose of processing will not be collected;

b) We will use encryption technology to ensure the confidentiality of information transmission and storage. We will use trusted protection mechanisms to prevent malicious attacks on the servers that store information;

c) We will deploy an access control mechanism to ensure that only authorized personnel can access personal information; and according to business needs and personnel levels, we will control the number of authorized personnel and implement hierarchical authority management for authorized personnel;

d) We will select business partners and service providers, and implement personal information protection requirements into contracts or audit, assessment and other activities of both parties;

e) We will hold security and privacy protection training courses, testing and publicity activities to enhance employees' awareness of the importance of protecting personal information.

Although we are responsible for protecting your personal information, you are also responsible for keeping your login information, including account ID and password, in a safe place. If you discover that someone else is using Snapano with your account ID without your permission, please notify us immediately. You have the right to request that we suspend unauthorized use of your account.

We will try our best to protect your personal information, but no measures can be perfect, and no service or product, website, information transmission, computer system or network connection is completely secure.

In order to cope with the possible risks of personal information leakage, damage and loss, Snapano has formulated a number of systems and control measures, and clarified the classification and grading standards of security incidents and security vulnerabilities and the corresponding processing procedures. Snapano has also established a special emergency response team for security incidents. In accordance with the requirements of security incident handling specifications, Snapano starts security plans for different security incidents, and performs stop loss, analysis, positioning, and formulation of remedial measures.

6. Retention period of personal information

We will retain your personal information for the period necessary for the purposes described in this Statement, unless an extension of the retention period is required by law. Retention periods may vary based on different processing purposes and services.

Generally speaking, after you cancel your authorization or cancel your account, we will store or retain your personal information within the retention period according to the requirements of applicable laws or the agreement of the service agreement. After your personal information exceeds the retention period and there is no legal requirement for us to continue processing your specific personal information, we will delete your personal information or anonymize it as required by applicable law. For example, we will save your registration information for the period specified in the Cybersecurity Law and other relevant laws and regulations. The storage period is six (6) months after you cancel your account. Your registration information includes user name, mobile phone number, email address Address and account information (account name, account ID and password, key).

7. How to access or control your personal information

You should ensure that all personal information submitted is accurate. We will do our best to maintain the accuracy and completeness of your personal information and to update your personal information in a timely manner based on the information you provide to us

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Among the many countries/regions where Snapano provides services and products, the legislation of some countries/regions stipulates that personal information subjects have the right to request access, correction, deletion, etc. to the relevant personal information retained by Snapano (hereinafter collectively referred to as "requests") .

You can easily modify the personal information we hold about you in the following ways:

a) Account information: If you use Snapano, when you want to add or update personal information related to your account, please visit the website and log in to your account: "Login" > "Account Center".

b) Cookies: For the management of cookies, please refer to our Cookie Policy.

c) Messages: If you use the Snapano website, please visit the website and log in to your account: Login > Account icon in the upper right corner > Unread messages, after entering, you can set your preferences at the mailbox icon in the upper right corner of your account > Message reception manage. In accordance with applicable laws and regulations, with respect to your personal information, you may have the following rights:

a) the right to access and obtain a copy of your personal information held by us;

b) the right to request that we update or correct your personal information;

c) the right to ask us to delete your personal information;

d) the right to object to our processing of your personal information;

e) the right to restrict our processing of your personal information; and

f) The right to file complaints and reports to relevant government management agencies.

Please note that these rights are not absolute and may be limited under applicable law. If you need our assistance in exercising the above request or rights, please contact us via "How to Contact Snapano" below.

Unless otherwise required by applicable laws and regulations, we will generally respond to your request within one month. Also, depending on the complexity of your request, we may be delayed by an additional two months. If this happens, we will notify you of the delay and the reasons for it within one month of receiving the request.

Please note that your request will be denied in certain circumstances, such as when we cannot verify your identity, or if your request exceeds your rights under the law. We will inform you in writing of the circumstances in which your request was denied and the reasons for the denial.

You can change the scope of your authorization to continue to collect personal information or withdraw your authorization, but your decision to withdraw your consent or authorization will not affect the previous personal information processing based on your authorization. You can contact us for assistance through "How to Contact Snapano" below, or do it yourself through the methods provided in the Statement. If using Snapano, you can visit the website and log in to your account: Login > Message Center > Message Receiving Management to turn off emails, text messages and system notifications.

In the Snapano account-related business, you can also withdraw all authorizations for us to continue to collect your personal information through the Snapano account-related business by canceling your account.

You can apply for account cancellation in Snapano account-related services and products. After you cancel your account, we will stop providing you with services and products, and we will delete your personal information unless otherwise provided by laws and regulations. After the account is cancelled, the account cannot be recovered. If you want to enjoy the related services and products again, you need to re-register the account.

8. How Snapano handles personal information of minors

Our services and products are primarily aimed at adults. Minors under the age of 14 may not create their own user accounts without the consent of their parents or guardians.

For the personal information of minors under the age of 14 collected with parental consent, we will only use or use it when permitted by law, expressly consented by parents or guardians, or necessary to protect minors under the age of 14. Disclose this personal information.

If Snapano discovers that it has collected personal information from minors under the age of 14 without first obtaining verifiable parental consent, it will seek to delete the relevant personal information as soon as possible.

9. How your personal information is transferred

We provide you with services and products through resources and servers located all over the world. This means that your personal information may be transferred to, or accessed from, other jurisdictions outside the country in which you use the Services or Products. Such jurisdictions may apply different personal information protection laws without even enacting relevant laws and regulations. In such cases, Snapano will ensure that your personal information is adequately and equally protected as required by applicable laws and regulations. For example, Snapano may request your consent to transfer personal information across borders or implement security measures such as anonymity prior to cross-border transfers. For users in mainland China, your personal information will be stored on servers in mainland China.

10. How this Statement is updated

We may update or revise this Statement from time to time in response to changes in our services or processing of personal information. If we update this Statement, we will show you the changed Statement in the form of announcements, pop-ups, etc. If we make any material changes to this Statement in accordance with applicable laws and regulations, we will notify you through appropriate channels and re-obtain your consent.

11. How to contact Snapano

We have set up a dedicated department for the protection of personal information, you can get in touch with it by visiting the Privacy Questions page (https://www.snapano.com/personal-data-request.html), and we will reply as soon as possible.

If you are not satisfied with our reply, especially when our personal information processing behavior damages your legitimate rights and interests, you can also file a lawsuit with the competent people's court, file a complaint with the industry self-discipline association or relevant government management agencies wait for an external solution. You can also ask us for information about the relevant complaint avenues that may apply.

Last update: October 2022