PRIVACY POLICY

1. GENERAL PROVISIONS

1.1 Purpose. This privacy policy (“Privacy Policy”) for Snag Sublets, Co. (referred to herein as “Snag”, “Company”, “we”, “us”, “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our Platform or Services.

1.2 Scope. This policy applies when you:

1.2.1 Visit or access Snag’s website (https://snagsublets.com/) or any site, application, product, or service of ours that links to this Privacy Policy;

1.2.2 Use or access our Platform or Services; or

1.2.3 Engage with us in other related ways, including through sales, marketing, events, or social media.

1.3 Concerns. Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, you should not use our Platform or Services.

2. USE OF INFORMATION

2.1 Personal Information. When you visit, use, access, or navigate our Platform or Services, we may process personal information depending on how you interact, the choices you make, and the products and features you use. We may process your data or personal information to serve our legitimate business interests, including, without limitation, to allow Users to interact with our Services. By way of example, but not limitation, we may use User information and data for:

2.1.1 Creation and administration of your account;

2.1.2 Corresponding or communicating with you;

2.1.3 Identifying Users;

2.1.4 Allowing Users to Identify One Another;

2.1.5 Displaying your usage information to other Users or third parties;

2.1.6 Enabling you to access parts of the Services;

2.1.7 Enabling you to connect with or communicate with other Users;

2.1.8 Enabling you to communicate with Snag;

2.1.9 Performing analytics, debugging, and conducting research;

2.1.10 Providing customer service training;

2.1.11 Sending you messages, updates, security alerts, and account notifications;

2.1.12 Allowing you to send or receive communications or data;

2.1.13 Personalizing and customizing your experience based on your interactions with the Services;

2.1.14 Allowing you and other Users to see “friends” or “contacts” (including those that are mutual between Users) including through your voluntary sharing of your contacts;

2.1.15 Displaying your usage information to other Users or outside parties in an anonymized or aggregated format in which you cannot be specifically identified as an individual to improve the Services or to provide trends and insights;

2.1.16 Sending you messages from time to time through the Services to provide you with useful information.

2.1.17 Processing bookings, payments, payouts, security deposits, refunds, cancellation and other fees, and related transactions, and administering claims and dispute resolution processes;

2.1.18 Facilitating identity verification, and facilitating tenant screening reports that Sublessors request from independent consumer reporting agencies with the applicant’s authorization;

2.1.19 Enforcing our Terms of Use and policies, including recording and acting on reports of access failures, unavailable Sublets, cancellations, and other performance failures, and recovering amounts owed by offset against Payouts, debit of a payout account, or charge to a payment method.

2.2 Sensitive Personal Information: We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

2.3 Third-Party Information. We may receive information concerning our Users from third parties and information about third parties from our Users.

2.4 Processing Information. We process your information to provide, improve, and administer our Platform and Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid reason to do so.

2.5 Sharing Information. We may share your information in specific situations with certain third parties or other Users of our Platform or Services.

2.6 Information Safety: We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

2.7 Phone Number; Contacts. At sign-up, Snag will request that you share your phone number for account verification. Once you have verified, Snag may ask that you share your contacts from your device. You are not obligated to share your contacts, but certain features of the Services will not be accessible to you unless and until you share your contacts. Many of Snag’s features are based on identification of shared contacts you have with other Users. Once you have granted Snag permission to access, import, and store your contacts, Snag may periodically import and store your contacts to improve your experience with the Services. Snag uses information about your contacts and connections to provide and improve our Services. By entering your phone number and continuing past the sign-up screen, you also acknowledge this Privacy Policy and agree to receive the text messages described in Section 5.

2.8 Your Rights. Depending on where you are located geographically, applicable privacy laws may mean you have certain rights regarding your personal information.

2.9 Exercising Your Rights. The easiest way to exercise your rights is by reading and following this Privacy Policy, or by contacting us according to your specific rights set forth herein. We will consider and act upon requests as required by applicable data protection laws.

3. INFORMATION WE COLLECT

3.1 Personal Information Provided by You. We collect personal information that you voluntarily provide to us when you register to access the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

3.2 Types of Personal Information: The personal information we collect may include the following:

3.2.1 Names

3.2.2 Phone numbers

3.2.3 Email addresses

3.2.4 Contact or authentication data

3.2.5 Contact preferences

3.2.6 Photos

3.2.7 Social Media Handles

3.2.8 Payment and transaction information, such as payment method details, billing information, authorization holds, charges, security deposit amounts and dispositions, transaction amounts, and transaction history. Full payment card numbers and bank account credentials are collected and processed directly by our third-party payment processors (currently Stripe, Inc. and its affiliates) and are not stored by Snag;

3.2.9 Identity verification information, such as a photograph of your face and an image of your government-issued identification document, collected and processed by our third-party verification provider, which may derive and compare biometric information (such as a scan of face geometry) from them with your consent in order to verify your identity.

3.2.10 Identity and payout verification information required for Users who receive payouts, such as date of birth, taxpayer identification number, and government-issued identification, collected and processed by our payment processor.

3.2.11 Screening information, where a Sublessor requests a tenant screening report and you authorize it, such as the status of the screening and the results furnished by the consumer reporting agency (currently Checkr, Inc.). Screening reports are prepared and furnished by the consumer reporting agency, not by Snag.

3.2.12 Performance and enforcement information, such as reports that access to a Sublet was not provided or that a Sublet was unavailable, claim submissions and supporting evidence, determinations, and resulting account actions.

3.3 Sensitive Information. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information: government-issued identification documents and numbers; biometric information derived by our verification provider from your face photograph and identification document for identity verification, with your consent; and, where a Sublessor requests a screening report and you authorize it, information contained in the resulting consumer report.

3.4 Information Automatically Collected. When you visit our Services, we may collect information such as your Internet Protocol (IP) address and/or browser and device characteristics. We may automatically collect certain information when you visit, use, access, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

3.5 Third Parties and Cookies. Like many businesses, we may also collect information through cookies, web beacons, flash cookies, pixels, and similar technologies.

3.6 Additional Information. We may collect the following additional information:

3.6.1 Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers may automatically collect when you access or use our Services and which we may record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Services (by way of example but not limitation, date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take and which features you use), and device event information (such as system activity, error reports – sometimes called “crash dumps”, and hardware settings).

3.6.2 Device Data. We may collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.

3.6.3 Location Data. We may collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. If you choose to opt out, you may not be able to use certain aspects of the Services.

3.6.4 Second-Party User Contextual Data. Data analyzed and determined from user contact and role information, such as name, phone number, social media handles, and photos.

3.7 Biometric Information. Where identity verification uses biometric comparison, we and our verification provider collect, use, and store the associated biometric information only with your prior written consent, obtained at the time of verification, and only for identity verification and related security and fraud-prevention purposes. Biometric information is not sold, leased, traded, or otherwise disclosed for consideration. Biometric information collected for a verification is permanently destroyed when the purpose of collection has been satisfied, and in any event no later than three (3) years after your last interaction with us, unless a shorter period is required by applicable law.

4. HOW WE PROCESS YOUR INFORMATION

4.1 Purpose. We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

4.1.1 To facilitate account creation and authentication or otherwise manage User accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order;

4.1.2 To deliver and facilitate delivery of services to each User. We may process your information to provide you with requested aspects of the Services;

4.1.3 To respond to User inquiries and/or offer support to Users. We may process your information to respond to your inquiries and to solve any potential issues you may have with the Services;

4.1.4 To send administrative information to you. We may process your information to send you details about our products and Services, changes to our Terms and policies, and similar information;

4.1.5 To fulfill and manage your orders or payments. We may process your information to fulfill and manage orders or payments made through the Services;

4.1.6 To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. Additionally, to provide, maintain, and manage our Services, ensuring they function as intended;

4.1.7 To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm;

4.1.8 To communicate. To communicate with you or other Users regarding updates, offerings, and to respond to inquiries and feedback;

4.1.9 To enhance the Services. To improve the functionality and security of our Platform and Services, including upgrading features and enhancing user experience;

4.1.10 To comply with legal obligations. To comply with legal requirements, enforce our Terms of Use, and protect our rights as well as those of our Users.

5. SMS POLICY

5.1 Generally. When you enter your mobile phone number at sign-up or log-in and continue, consistent with our Terms of Use and Messaging Policy, you consent to receive SMS text messages from us about verification codes, booking requests, booking confirmations, and other account and transaction messages related to your use of the Platform and Services. Consent to receive marketing or promotional text messages is not required to use the Services; we send those messages only to Users who have separately opted in.

5.2 Use of Information. We use your mobile phone number solely for the purpose of sending you SMS messages as described in this Policy.

5.3 Personalization. We may use information you provide, including, without limitation, preferences and usage data, to personalize your experience and improve our services.

5.4 Data Aggregation. We may aggregate and analyze usage data for statistical purposes without identifying individual Users.

5.5 Compliance with TCPA and CTIA Guidelines

5.5.1 TCPA Compliance. We strictly adhere to the TCPA by ensuring that:

5.5.1.1 All SMS marketing messages are sent only to Users who have provided explicit consent;

5.5.1.2 You are provided with clear instructions on how to opt-out (e.g. “Reply STOP to unsubscribe”);

5.5.1.3 All messages include the identity of the sender.

5.5.2 CTIA Guidelines. We follow CTIA’s best practices by:

5.5.2.1 Clearly disclosing message frequency and associated costs, if applicable;

5.5.2.2 Including opt-out instructions in every SMS message;

5.5.2.3 Ensuring that any promotional SMS campaigns are conducted in a manner consistent with CTIA guidelines, including not sending messages outside of permissible hours (e.g. between 8 a.m. and 9 p.m. local time).

5.6 Opt-Out and Help Instructions. At any time, you may opt-out of receiving further SMS messages by replying “STOP” to any message. Once you opt-out, you will no longer receive SMS communications from us, except as required to confirm your opt-out, unless and until you resubscribe to receive SMS messages from us.

5.7 Help. If you require assistance or more information about our SMS program, you may contact us at hi@joinsnag.com.

5.8 Security; Data Retention.

5.8.1 Security. We take reasonable measures to protect your mobile number and any other personal data from unauthorized access, disclosure, or misuse;

5.8.2 Data Retention. We will retain your information only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable law.

5.9 Third-Party Service Providers. We may share your information with third-party service providers solely for the purpose of delivering SMS communications. These providers are contractually obligated to safeguard your information and use it only for the purposes for which it was disclosed.

6. SPECIFIC LEGAL BASES FOR INFORMATION PROCESSING

6.1 Generally. We only process your personal information when we believe it is necessary and we have a valid legal basis to do so under applicable law, like with your consent, to comply with laws, to provide you with Services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

6.2 EU or UK. If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases to process your personal information:

6.2.1 Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

6.2.2 Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations, including providing our Services or, at your request, prior to entering into a contract with you.

6.2.3 Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests where those interests do not outweigh your interests and fundamental rights and freedoms. By way of example but not limitation, we may process your personal information for some of the purposes described herein to diagnose problems and/or prevent fraudulent activities.

6.2.4 Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

6.2.5 Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the life, health, welfare, or safety of any person.

6.3 Canada. If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time by emailing us at hi@joinsnag.com. In certain exceptional circumstances, we may be legally authorized under applicable law to process your information without obtaining your consent. Such circumstances may include, but are not limited to, the following:

6.3.1 If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;

6.3.2 For investigations and fraud detection and prevention;

6.3.3 For business transactions provided certain conditions are met;

6.3.4 If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;

6.3.5 For identifying injured, ill, or deceased persons and communicating with next of kin;

6.3.6 If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;

6.3.7 If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;

6.3.8 If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;

6.3.9 If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;

6.3.10 If the collection is solely for journalistic, artistic, or literary purposes;

6.3.11 If the information is publicly available and is specified by regulations.

7. SHARING OF PERSONAL INFORMATION

7.1 Personal Information. We may share information in specific situations described in this section and/or with the third parties as set forth herein. Our Services may include links to third-party websites, which are not governed by this Privacy Policy. We may share your personal information in the following situations:

7.1.1 Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company;

7.1.2 Third Parties. We may share or transfer your information with third-party service providers who support our business operations;

7.1.3 Legal Obligations. We may share or transfer your information to comply with legal obligations, court orders, or governmental requests;

7.1.4 Rights. We may share or transfer your information for the protection of our rights, privacy, safety, or property, and/or that of our affiliates, you, or others;

7.1.5 Sale. We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.

7.1.6 Payment Processors. We may share your information with third-party payment processors (currently Stripe, Inc. and its affiliates) in order to process payments, payouts, authorization holds, and security deposits, verify identity as required by applicable law (including “know-your-customer” and sanctions-screening obligations), prevent fraud, and satisfy tax and information-reporting obligations. Information payment processors collect directly from you is governed by their own privacy policies;

7.1.7 Screening and Verification Providers. Where a Sublessor requests a tenant screening report and you authorize it, we share the information needed to initiate the screening with the consumer reporting agency (currently Checkr, Inc.), which collects your authorization and additional information directly from you under its own privacy policy and consumer disclosure documents; and where you verify your profile, we share the information needed to perform the verification with our verification provider. Screening results are furnished by the consumer reporting agency to the requesting Sublessor;

7.1.8 Other Users. We may share your information with the other party to your Booking as needed to facilitate the Booking and the parties’ sublease agreement, for example by sharing your name, Profile information, contact information upon Booking confirmation, screening status (and, for a requesting Sublessor, screening results), and the executed sublease agreement with your counterparty.

7.1.9 Landlords and Building Management. Where a Booking requires the consent or approval of the owner, landlord, or managing agent of the Property, or where a landlord or property manager lists a Property directly, we may share with that person or entity the information needed for the approval or the Booking, such as your name, contact information, the dates and terms of the Booking, whether you completed screening (but not your screening results, unless you authorize it), and the executed sublease agreement.

8. COOKIES AND TRACKING

8.1 Cookies and Tracking Technologies. We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

8.2 Advertising. We advertise on third-party platforms, including, without limitation, Meta (Facebook and Instagram), Google, and TikTok. To measure our ads and to show ads to people who may be interested in Snag, including existing Users, we and those platforms may use pixels, software development kits, and similar technologies on the Site and App, and we may share hashed contact information (such as an email address or phone number) with those platforms to create custom or similar audiences. Those platforms process this information under their own privacy policies. You may opt out of targeted advertising as described in Section 15.

8.3 No Cookie Banner; Your Controls. The Site does not currently display a cookie consent banner. When you choose to sign up from the Site, the Site directs you to the App to create your account. You can block or delete cookies through your browser settings, and you can use a universal opt-out preference signal, such as Global Privacy Control, which we treat as described in Section 15.

9. INTERNATIONAL TRANSFER OF INFORMATION

9.1 International Transfers. We may transfer, store, and process your information in countries other than your own.

9.2 Servers. Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by third parties with whom we may share your personal information in the United States or in other countries.

9.3 EEA, UK or Switzerland. If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

10. DURATION OF INFORMATION STORAGE

10.1 Retention Period. We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements, including in anticipation of litigation).

10.2 Deletion or Anonymization. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

11. INFORMATION SECURITY

11.1 Security Measures. We aim to protect your personal information through a system of organizational and technical security measures. We use administrative, technical, and physical safeguards designed to protect data against unauthorized access, alteration, disclosure, or destruction, aimed to protect the security of personal information we process. These measures include, without limitation, encryption, security audits, and access controls. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and other personal information will be encrypted using SSL technology. If we have given you (or you have chosen) a password for access to certain parts of our Services, you are responsible for keeping that password confidential.

11.2 Limitations. Despite safeguards, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will endeavor to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

12. MINORS

12.1 Minors. The Services are not intended for children under 18 years of age. We do not knowingly solicit to or collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor-dependent’s use of the Services.

12.2 Reporting and Deletion of Data of Minors. If we become aware that personal information from persons under the age of 18 has been collected, or if we learn we have collected or received personal information from a minor under 18 without verification of parental consent, we will delete that information. We will deactivate the account of any person we discover to be under the age of 18 and will take reasonable measures to promptly delete corresponding data from our records. If you become aware of any data we may have collected from minors under age 18, please contact us at hi@joinsnag.com.

13. PRIVACY RIGHTS

13.1 Rights by Region. In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. These rights may include the ability to review, change, or terminate your account at any time.

13.2 Exercise of Rights. In some regions (such as the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:

13.2.1 to request access and obtain a copy of your personal information;

13.2.2 to request rectification or erasure;

13.2.3 to restrict the processing of your personal information;

13.2.4 if applicable, to data portability; and

13.2.5 to not to be subject to automated decision-making.

In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at hi@joinsnag.com. We will consider and act upon any request in accordance with applicable data protection laws. If we cannot honor a request to restrict or stop processing while continuing to provide the Services to you, we will tell you, and you may choose to close your account.

13.3 EEA, UK, Switzerland Data Complaints. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

13.4 Withdrawing Consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by updating your in-app consent preferences or by emailing us with a request to withdraw consent at hi@joinsnag.com. Please be advised that this will not affect the lawfulness of information processing before consent withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

13.5 Marketing Opt-Out. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by updating your in app preferences for marketing communications. We may still communicate with you, including, without limitation, by sending you Services-related messages that are necessary for the administration and use of your account, to respond to requests, or for other non-marketing purposes.

13.6 Account Information. If, at any time, you would like to review or change the information in your account or terminate your account, you may do so through your account in our Platform or by sending a request to hi@joinsnag.com.

13.7 Termination Request. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases within a reasonable time period. Notwithstanding the foregoing, we may retain some or all information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our terms, or comply with applicable legal requirements including those regarding the preservation of information in anticipation of potential litigation.

13.8 Cookies and Similar Technologies. Many browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies or to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

14. CONTROLS FOR DO-NOT-TRACK FEATURES

14.1 Do-Not-Track. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

14.2 Current Practices. At this time, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

15. U.S. STATE-BASED PRIVACY RIGHTS

15.1 State-Based Privacy Rights. This Section applies to residents of U.S. states with comprehensive consumer privacy laws, including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, in each case to the extent the applicable law applies to us and to you. We extend the core rights described in this Section to residents of every such state, and where your state’s law provides a right or protection beyond those described here, we will honor it as that law requires.

15.2 Categories of Personal Information We Collect. We may collect the following categories of personal information:

We will use and retain the collected personal information as needed to provide the Services or for the following time periods unless required to retain same for longer to comply with legal obligations:

15.2.1 Category A - As long as the user has an account with us;

15.2.2 Category B - As long as the user has an account with us;

15.2.3 Category D - As long as the user has an account with us, and thereafter as required for tax, accounting, fraud-prevention, claims, and other legal compliance purposes. Screening results are retained for no longer than two (2) years after the screening, or such shorter period as applicable law requires, and are then deleted;

15.2.4 Category E - Until the purpose of collection has been satisfied, and in any event no later than three (3) years after your last interaction with us, as described in Section 3.7;

15.2.5 Category F - As long as the user has an account with us;

15.2.6 Category H - As long as the user has an account with us;

15.2.7 Category I - As long as the user has an account with us;

15.2.8 Category L - As long as the user has an account with us. Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

15.2.9 Receiving help through our customer support channels;

15.2.10 Participation in customer surveys or contests; and

15.2.11 Facilitation in the delivery of our Services and to respond to your inquiries

15.3 Sharing, Use, and Retention of Personal Information. We may disclose your personal information with our service providers pursuant to a written contract between us and any such service provider, and we may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information. Your personal information may be stored on third-party servers with industry-leading vendors such as Amazon, Google, or Microsoft and may be sold, shared, or communicated to third-parties consistent with this Privacy Policy.

15.4 Your State Privacy Rights. To the extent an applicable state privacy law applies to us and to you, you have the following rights with respect to your personal information, subject to the exceptions and conditions in that law:

15.4.1 Know and Access. The right to confirm whether we are processing your personal information and to access it, including, where required, the categories collected, the purposes, the categories of third parties to whom it was disclosed, and the specific pieces of personal information we hold about you;

15.4.2 Correct. The right to correct inaccuracies in your personal information;

15.4.3 Delete. The right to request deletion of your personal information;

15.4.4 Portability. The right to obtain a copy of personal information you provided to us in a portable and readily usable format;

15.4.5 Opt Out. The right to opt out of the sale of your personal information, the sharing or processing of your personal information for targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. We do not sell personal information for money; where our use of analytics or advertising technology constitutes a “sale,” “sharing,” or “targeted advertising” under your state’s law, you may opt out as described in this Section;

15.4.6 Non-Discrimination. The right not to receive discriminatory treatment for exercising these rights.

15.5 Sensitive Personal Information. Where your state’s law requires consent before we process sensitive personal information (such as government identification numbers, precise geolocation, or biometric information), we collect and process those categories only with your consent, as described in Sections 3.3 and 3.7, or as otherwise permitted by law. California residents may limit our use and disclosure of sensitive personal information as described in the California addendum below. For Maryland residents, we process sensitive personal information only where strictly necessary to provide or maintain a product or service you have requested, and we do not sell sensitive personal information.

15.6 Opt-Out Preference Signals. Where required by applicable law, we treat a recognized universal opt-out preference signal, such as the Global Privacy Control, transmitted by your browser or device as a valid request to opt out of the sale of personal information and of targeted advertising for that browser or device and, where we can reasonably associate the signal with your account, for your account.

15.7 Exercising Your Rights; Verification; Authorized Agents. You may exercise these rights by contacting us at hi@joinsnag.com or through your account settings in our Platform. We may need to verify your identity before acting on a request, by matching information you provide against information we hold or by contacting you through a communication method on file, and we will use information provided for verification only for that purpose. Where your state’s law permits, you may designate an authorized agent to submit a request on your behalf; we may require proof of the agent’s authority and may deny a request from an agent who does not submit it.

15.8 Response Timing; Appeals. We will respond to a rights request without undue delay and within the period required by your state’s law (generally forty-five (45) days, extendable once where permitted with notice to you). If we decline to act on your request, we will explain why, and you may appeal by replying to our decision or by emailing hi@joinsnag.com with the subject line “Privacy Appeal.” We will respond to an appeal in writing within the period your state’s law requires, with an explanation; if your appeal is denied, you may contact your state Attorney General to submit a complaint.

15.9 California Addendum. This subsection applies only to California residents and supplements the rights above.

15.9.1 Shine the Light; Minors. California Civil Code Section 1798.83 (“Shine the Light” law) permits California residents to request, once a year and free of charge, information about personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year; we do not currently share personal information with third parties for their direct marketing purposes. California residents under 18 with a registered account may request removal of content they publicly posted by contacting us at hi@joinsnag.com with a statement that they reside in California; removal from public display does not guarantee complete deletion from all our systems.

15.9.2 Right to Know. The categories of personal information we collect, the sources, the purposes, and the categories of third parties to whom we disclose them are described in Sections 3, 4, 7, and 15.2 of this Privacy Policy.

15.9.3 Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive personal information (including government identification numbers, account log-in credentials, financial account credentials, precise geolocation, biometric data, and the other categories listed in California law) to the uses necessary to perform the Services and the other purposes California law permits. To exercise this right, contact us at hi@joinsnag.com. Once we receive your request, we will not use or disclose your sensitive personal information for other purposes unless you later provide consent.

15.9.4 Opt-Out Requests. Upon receiving a request to opt out of selling or sharing, we will act on the request as soon as feasibly possible, and no later than fifteen (15) days from its receipt.

16. THIRD PARTY ANALYTICS

16.1 Analytics Companies. We may partner with third-parties, including analytics companies. Analytics companies may use cookies (described above) or other tracking technologies to analyze visitors’ use of parts of the Services for various reasons, including, without limitation, to determine the popularity of content and to better understand online activity. To access our Services, you may be requested to consent to the collection and use of your information by certain third-party analytic companies. If you choose not to consent, you may not be able to access parts of the Services. We may not transfer your personal information to analytics companies but reserve the right to allow them use of, or access to, same as may be necessary or appropriate as contemplated under this Section. In such cases, you should review any such analytics company’s Privacy Policy and contact them directly if you have questions about how your data may be used for analytics purposes as contemplated hereunder. If you do not want any information to be collected and used by tracking technologies, we encourage you to visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

16.1.1 Google Analytics: You can opt-out of having your activity on Our Site or Application made available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents Google Analytics from retrieving information about your visits to our Site or Application. For more information about Google’s Privacy Policy, please visit: https://policies.google.com/privacy.

16.1.2 Facebook. You can opt-out of Facebook’s interest-based ads by visiting: https://www.facebook.com/help/568137493302217. You can learn more about Facebook’s Privacy Policy at: https://www.facebook.com/full_data_use_policy

17. UPDATES TO THIS PRIVACY POLICY

17.1 Updates. We will periodically update this Privacy Policy as necessary or appropriate or to stay compliant with relevant laws.

17.2 Notification of Changes. We may update this Privacy Policy from time to time. The updated version will be indicated by changes to the version number and date at the top of this Privacy Policy. The updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes through the Services or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting and processing your information.

If you have questions or comments about this privacy policy and our privacy practices, or would like to register a complaint or concern, you may contact us at hi@joinsnag.com.

If you wish to request access to the personal information we collect from you, to update that information, or to delete it, please contact us at hi@joinsnag.com.