Thank you for your interest in SNAPP! We are committed to protecting and respecting your privacy when you use our website at www.snapp-media.com and our Services. 

In principle, we will only use your personal data in accordance with applicable data protection laws, in particular Israel`s Protection of Privacy Law, 5741-1981 (“the Privacy Law”), the General Data Protection Regulation (“GDPR”) and of course only as described in this privacy policy.

What is Personal Data?

Personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.

Responsible for data processing

Responsible for data processing is GO GROUP HOLDINGS 21 LTD, a company in Israel, doing business as SNAPP Media. 

General Information on Data Processing 

1. The legal bases of processing

All personal data that we obtain from you via the website will be processed for the purposes described in more detail below. This is done within the framework of the DPA and the GDPR or with your consent. In particular, we process personal data only when processing is permitted and if:

• you have given your consent,
• the data is necessary for the fulfillment of a contract / pre-contractual measures,
• the data is necessary for the fulfillment of a legal obligation or
• the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.

1. Your data subject rights

The following rights are available to you as a data subject:

• the right to information,
• the right to rectification,
• the right to erasure,
• the right to restriction of data processing,
• the right to data portability,
• the right to object to data processing,
• the right to revoke any consent you have given, and
• the right to lodge a complaint with the competent supervisory authority.

Please contact us at any time with questions and suggestions regarding data protection and/or to enforce your rights.

1. Exercising your rights

If you wish to access your personal data or exercise any of the rights listed above, you should apply in writing, providing evidence of your identity. Any communication from us in relation to your rights as detailed above will be provided free of charge. However, in case of requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request.

1. Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us.

1. International data transfer

In the course of our business and website operations, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside Israel. Where we transfer data outside Israel, we make sure to use the necessary and appropriate safeguards to ensure that the security of your personal data is maintained and guaranteed. In particular those include standard contractual clauses, binding corporate rules and data processing agreements. If you have any questions relating to our third-party providers, please refer to their relevant Privacy Policies or contact us for further details.

1. Storage and retention of your data

We process and store your personal data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

1. Security

We have implemented technical and administrative security measures to protect your personal data against loss, destruction, manipulation, and unauthorized access. All our employees and service providers working for us are bound by the applicable data protection laws.

Whenever we collect and process personal data, it is encrypted before it is transmitted. This means that your data cannot be misused by third parties. Our security measures are subject to a continuous improvement process and our privacy policy is constantly being revised.

Nonetheless, databases or data sets that include personal data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose personal data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after the breach was discovered. 

Processing of Automatically Collected Data

1. a) Collection of access data and log files

We collect data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.

1. b) Use of cookies

We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

1. c) Content Management System (CMS)

We use the Content Management System (CMS) of WordPress a service provided by Automattic Inc, to publish and maintain the created and edited Content and texts on our website. This means that all content and texts submitted to us by users for publication is transferred to WordPress. In addition to texts, this also includes, for example your data in our forms. The legal basis for this processing is our legitimate interest.

1. d) Hosting

To provide our website, we use the services of Namecheap, who process the below-mentioned data and all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website. 

Data processing when you submit it to us 

When you contact us through our website or use our services, some data is collected and processed by us or on our behalf by our selected third-party providers. 

1. a) Contacting us

If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our overriding legitimate interest in processing your request.

For the Chat, we use Crisp Chat provided by  Crisp IM. We have no influence on the processing of data by Crisp IM and no possibility to influence it. The legal basis of the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our legitimate interest in processing your enquiry.

1. b) Booking a Meeting

For booking a Booking a Meeting in an easy and convenient way, we use Calendly. Your data from the form will be transferred to our appointment account at Calendly after you press the “Book appointment” button. You will then receive a confirmation email with a link to the event. Your data will be kept at Calendly until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. Calendly undertakes not to pass on your data to third parties. The legal basis is your consent as well as our legitimate interest.

1. c) Data management and customer support

For optimal customer support, we use first name, last name, e-mail address, and the data related to your contract with us. Your data may be stored on our website and or our customer relationship management system (“CRM system”) by monday.com. This data processing is based on our legitimate interest in providing our customer service.

1. d) Contract processing

We process your company details, first name, last name, e-mail address, and the data related to your contract with us data to handle the contractual relationship between you and us. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations.

1. e) Video Call

We use Zoom to conduct our video calls and various types of data are processed when using Zoom. The scope of the data depends on the information you provide before or during participation in the video call. The legal bases for processing are your consent, our legitimate interest and, insofar as it concerns an enquiry to enter into or fulfill a contract, also contract.

1. f) Onboarding Questionnaire

We use the services of Typeform, S.L. to make the onboarding process as convenient as possible for you. The data processing is based on our legitimate interest lies in the technically error-free and optimized provision of our services. Typeform receives secure user IDs for this purpose. The processing of the data collected from you when requesting a demo (Name, and e-mail address) is based on contract as the processing of personal data is necessary for the initiation of our services.

Transfer of personal data 

We will not disclose or otherwise distribute your personal data to third parties unless this:

• is necessary for the performance of our services,
• you have consented to the disclosure,
• or the disclosure of data is permitted by relevant legal provisions.

However, we are entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors within the framework of the Privacy Law and GDPR. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfillment of reporting obligations.

The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with the Privacy Law and GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organizational measures, and additional controls by us.

We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfill our legitimate interests.

Advertising and Marketing 

Insofar as you have also given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. 

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out. 

Miscellaneous  

1. a) Automated decision-making

Automated decision-making including profiling pursuant does not take place on the part of SNAPP.

1. b) Links to other providers

Our website also contains – clearly recognizable – links to the websites of other companies. Insofar as there are links to websites of other providers, we have no influence on their contents. Therefore, no guarantee or liability can be assumed for these contents. The respective provider or operator of the pages is always responsible for the content of these pages.

The linked pages were checked for possible legal violations and recognizable infringements at the time of linking. Illegal contents were not recognizable at the time of linking. However, permanent monitoring of the content of the linked pages is not reasonable without concrete indications of a legal violation. Such links will be removed immediately if infringements of the law become known.

1. c) Personal information and children

Most of the services available on this website are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal information from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact. The parent or guardian will be provided with (i) information about the specific type of personal information being collected from the minor, (ii) the purpose for which it will be used, and (iii) the opportunity to object to any further collection, use or storage of such information. We comply with youth protection laws.

1. d) Online presences in social media

We maintain online presences within social networks and platforms  in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply. Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g., write posts on our online presences or send us messages. 

1. e) Am I Obliged to Provide Data?

The processing of your data is necessary for the conclusion or fulfillment of the contract you have entered into with us. If you do not provide us with this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and consequently have to terminate it. However, you are not obliged to give your consent to data processing with regard to data that is not relevant for the fulfillment of the contract or that is not required by law.

Closing 

Can we make changes to this Privacy Policy?

We reserve the right to update and amend all or parts of this Privacy Policy, at any time, to the fullest extent permitted under applicable law. The version published on the Site is the version actually in force.

As an individual whose personal information is processed as described in this Privacy Policy, you have a number of rights which are summarized above. Please note that exercising these rights is subject to certain requirements and conditions as set forth in applicable law. 

Questions, suggestions, or comments

If you have any questions, suggestions, or comments on the subject of data protection, please do not hesitate to contact us. This Privacy Policy was last updated on Monday, 07 November 2022