Privacy

You’re trusting us with some of your most cherished family moments, so of course you want to be sure that we’re looking after your information properly. Our privacy policy sets out exactly how we collect, store and use information about you, but here’s the summary in plain English: we promise that we will never share your personal information, photos, videos or updates without your consent.

It’s that simple.

We use the information you give us to make sure the app works for you, to ensure your approved friends and family get notifications about your updates and to occasionally get in touch via email to let you know about new features or updates. Another comforting thought? Your content is all stored in a highly secure online environment – the same type of system used to securely process credit card details.

If you have any questions about our privacy policy, don’t hesitate to contact us.

Privacy and Cookies - The Legal Stuff

23 Snaps Limited (“We”; “Us”) is committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms and Conditions www.23snaps.com/home/terms and any other documents referred to therein), sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how We will treat it.

1. DATA CONTROLLER

For the purpose of the Data Protection Act 1998 (the “Act”), the Data Controller is 23 Snaps Limited (Company Registration 07853831) having its registered address at 21A Noel Street, London, England, W1F 8GR.

2. INFORMATION WE MAY COLLECT FROM YOU

The information we collect from you may vary depending on whether you are logged in to the mobile device application and/or the website, which is located at www.23snaps.com (the mobile application and website being referred to collectively as the “App” ).

We may collect and process the following data about you:

(a) information that you provide when you use our App. This includes information provided at the time you register to become a User of the App, content made available by you at any time while you are a User and the login credentials to your social network accounts if you choose to connect those accounts with your 23snaps account;

(b) information that you provide to Us when you report a problem with the App;

(c) information collected automatically when you use the App, such as your location/GPS coordinates (you may enable or disable location services at any time, through your mobile device settings), a device identifier (but not the UDID), MAC address, Internet Protocol (IP) address (if using a browser), operating system, the browser type, the address of a referring site and your activity on the App;

(d) if you contact Us by telephone or in writing, We may keep a copy of that correspondence or communication.

If you have provided Us with the personal data of another person, you confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a Data Controller and provided him/her with a copy of this Privacy Policy and our Terms and Conditions.

3. IP ADDRESSES AND COOKIES

We may collect information about your mobile phone, computer or other device from which you access the App including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.

Our website uses cookies (small files stored by your browser that allow it to recognise you as a user and store your preferred settings). Cookies are widely used to make websites function efficiently. Our website uses the following cookies:

Cookie Name (type) Purpose of Cookie Further Information
Session ID (session cookie) This cookie enables Us to track the session ID when you use our Website. This cookie does not make use of any personal information or personal data.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Website, including areas offering special offers. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log in to our website.

Please note that our advertisers may also use cookies, over which We have no control.

4. PROTECTION AND RETENTION OF YOUR INFORMATION

We take appropriate measures to ensure that any information collected from you is kept secure and kept only for so long as is necessary for the purpose for which such information is used.

5. CHANGES TO YOUR INFORMATION AND DEACTIVATION OF YOUR ACCOUT

If any of your personal data changes, you can use your login to access and modify the personal information you provided Us that is associated with your account.

You can delete your account by contacting us at info@23snaps.com. After you have deleted your account some information may remain in archived/backup copies for our records and as otherwise required by law.

We normally update your personal data immediately with any new or updated personal data being provided to Us, to ensure that the personal data We hold about you is as accurate and up to date as possible.

6. USES MADE OF YOUR INFORMATION

We use information held about you in the following ways:

(a) to provide our services or information you request, and to process and complete any transactions;

(b) to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;

(c) to monitor and analyze usage and trends, and to personalize and improve the App and your experiences when you use the App, such as providing content or features that match your profile or interests, and to increase the functionality and user friendliness of our services;

(d) to send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, our services;

(e) to allow you to add your location to your posts;

(f) to find and connect with your friends (when instructed by you);

(g) to let your friends know about your content on the App

(h) to let your friends know it’s your birthday (if you don’t disable this feature); and

(i) to ensure that content from our App is presented in the most effective manner for you and your device;

(j) to notify you about changes to our services;

(k) to provide you with any other information that We feel maybe of use or interest to you; and

(l) any other purpose for which the information was collected.

If you do not wish to receive communications from Us, please select the opt-out option in our emails, or amend your preferences in your account settings.

We will not share your data with third parties for marketing purposes unless We have procured your express consent to do so.

7. DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.

We will not share the personal information we have collected from you, except as described below:

(a) with your connected users on the App according to the preferences set in your account;

(b) with certain social networking services, if you allow such sharing through our services;

(c) with service providers who are working with Us in connection with the operation of our site or our services (these service providers have access to your personal information only to perform services on our behalf and are obligated not to disclose it or use it for any other purposes);

(d) we may share aggregated information and non-identifiable information with third parties for industry analysis, demographic profiling and other similar purposes;

(e) when you give Us your consent to do so, including if we notify you that the information you provide will be shared in a particular manner and you provide such information;

(f) when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders;

(g) to enforce or apply our privacy and cookies policy, our terms of use or our other policies or agreements;

(h) in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where personal information may be disclosed or transferred as one of our business assets; and

(i) to protect the rights, property or safety of 23snaps Limited, our users or others.

Where any of our service providers are located outside the EEA, we have appropriate protection in place to safeguard your information, in accordance with the Act.

8. YOUR RIGHTS

You have the right to ask Us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes. You can exercise your right to prevent such processing at any time by contacting Us using the contact details below or by amending your privacy settings by logging into your 23snaps account. If you opt out of these messages, you will still receive emails from Us, about your account, our services and other pertinent information related to our services. These communications are considered part of the service and your account, which you cannot opt-out from receiving.

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a reasonable administrative fee to meet our costs in providing you with details of the information We hold about you.

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies.

9. CHANGES TO OUR PRIVACY POLICY

Any changes We may make to our Privacy Policy in the future will be posted on this page and on our App.

10. CONTACT

Questions, comments and requests regarding this Privacy and Cookies are welcomed and should be addressed to info@23snaps.com.

Effective: June 2012

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