This Privacy Notice explains how the Snap4me Group of companies (comprising Snap4me Pte Ltd (Singapore), and their subsidiaries and associated companies) (collectively, “Snap4me”, “we”, “us", and “our”) collects, uses, discloses, processes, and stores information regarding Personal Data (as defined below) provided to us by users through our various channels such as our websites, applications and third party social networks.

Please read this Privacy Notice carefully to understand our policies and practices regarding your Personal Data and how we will treat it.

Key Terms

“Personal Data” refers to information (whether true or not) from which you can be identified. This includes your name, photo, contact details, address, and other data which can be used alone or in combination with such information to identify you, as well as any other personal information you may input as free text into fields on forms contained on our websites, applications and on third party social networks.

“User” and “you” refer to any individual, firm, corporation, organization or other entity who accesses and/or uses Snap4me’s websites, applications, and/or who interacts with Snap4me through a third party social network.

Consent and changes to this Privacy Notice

By accessing and/or using our websites, applications, interacting with us through a third party social network, and/or giving us information about you, you accept and agree to this Privacy Notice, and the collection and processing of your information as described in this Privacy Notice.

If you do not agree to any part of this Privacy Notice, please cease immediately your access and/or use of our websites, applications and third party social networks, and do not provide us any Personal Data.

We reserve the right to amend, revise or change the terms of this Privacy Notice at any time. Notice of any change to this Privacy Notice will be posted on our website(s). Therefore, we encourage you to return to our website(s) frequently to stay up to date on our current privacy practices. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email, text messaging or in-app notifications.

Once posted on our website(s) or otherwise notified to you, the revised Privacy Notice supersedes all previous versions, and continued access to and/or use of our websites, applications or interaction with us through a third party social network after the date of such revision constitutes your acknowledgment of such changes and agreement to be legally bound by the terms of the revised Privacy Notice.

How to contact us

You may contact our Data Protection Officer at the following physical and/or email address if you have any enquiries or feedback on our personal data protection policies, or if you wish to make any request:

Snap4me Pte Ltd

101 Cecil Street

#20-05 Tong Eng Building

Singapore 069533

Email: support@snap4me.com

If you do not want us to share your email address with other parties, please inform us immediately by email at support@snap4me.com.

Personal Data we collect about you

1. Information you provide to us. Personal data you may provide to us through our services, or otherwise, includes:

• Contact data, such as your first and last name, email address, phone number.
• Communications data such as data that we exchange with you, including when you contact us with questions or feedback, through our services, social media, or otherwise.
• Marketing data such as your preferences for receiving our marketing communications and details about your engagement with them, including your location
• Job application data such as first name, last name, phone number, email address, LinkedIn URL, resume, cover letter and information that you voluntarily provide.
• Other data not specifically listed here, which we will use as described in this Privacy Notice or as otherwise disclosed at the time of collection.

2. Third-party sources. We may combine Personal Data we receive from third party vendors and/or other commercially available sources with the Personal Data we collected. The third-party sources from which we may receive Personal Data are:

• Public sources, such as social media platforms and other publicly available sources.
• Data providers, such as information services and data licensors that provide demographic and other information.
• Third party vendors, such as service providers providing fraud warnings or enrichment service providers to enhance and personalize your user experience.
• Marketing partners, such as joint marketing partners and event co-sponsors.

If you choose to interact with us by using a third-party platform (or network), such as Facebook/Instagram/LinkedIn/TikTok/SnapChat or other social media platforms, we may collect data from that platform (or network) regarding your interactions with our websites or applications on these third-party platform (or network).

3. Automatic data collection We may automatically collect data about you, your computer or mobile device while you access, browse, view or otherwise interact with our services, the data we collect may include:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

4. Cookies and similar technologiesWe use cookies and similar technologies (such as web beacons, pixels, tags and scripts) to improve and personalize your experience, provide our services, analyse website performance and for marketing purposes. To find out more about cookies, you may visit http://www.allaboutcookies.org/. You can delete cookies at any time or you can set your browser to reject or disable cookies by following the instructions available at the following link: http://www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html.Do note, however, that rejecting and/or disabling cookies may limit the functionality of our website(s).

How and why your Personal Data is used

We will only use your Personal Data to the extent permitted by law.

We may also use and/or disclose Personal Data obtained from you through our website(s), application(s) and third party social networks for the following purposes:

• Any purpose(s) for which the Personal Data was requested, and related purposes to fulfil our contractual obligations to you;
• To verify your identity;
• Processing payment or credit transactions;
• To respond to your enquiries, and provide information you have requested;
• For security purposes, and/or to detect and prevent fraud, illegal activities and misuse of services;
• To improve and personalise your user experience when you access and/or use our website(s) or application(s);
• To process your job application;
• To send you information, updates, promotions, and marketing and advertising materials in relation to Snap4me and its goods, products and/or services by electronic means. (If you no longer wish to receive such marketing or promotional communications, you can unsubscribe from them at any time through links available in our electronic communications, or logging into third party social networks and adjusting your account settings);
• To improve the content, usability and functionality of our website(s) and application(s);
• For research and analysis purposes;
• To improve our products and services;
• To improve our marketing and promotional efforts;
• To evaluate and implement a potential merger, sale, acquisition or other change of ownership or control by or of us;
• To enforce contractual and legal rights and obligations, and/or to prosecute or defend legal actions or other proceedings;
• To comply with any applicable law, regulation, request from governmental and regulatory authorities, and order of a competent court or tribunal that Snap4me may be subject to;
• To transmit to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
• Any other incidental business purposes related to or in connection with the above;
• For the purposes of our overriding legitimate interests; and
• Any other purpose for which we have obtained your prior informed consent.

We do not sell any of your Personal Data to third parties.

How and/or where your Personal Data is stored

The Personal Data that we collect from you is processed by our authorized staff or agents, for the specific purposes for which the data was collected. We have put in place industry-standard measures to protect the security of your Personal Data and the information we collect. However, the transmission of information via the Internet is never completely secure and while we will do our best to protect your Personal Data, we will not be responsible for any interception or interruption of any communications through the Internet, or for any changes to or losses of data.

Please be advised that the Personal Data that we collect from you may be transferred between members of the Snap4me Group and to third parties in connection with the purposes set out above. Therefore, we may transfer your Personal Data outside of Singapore. Where we do so, we will ensure that we take appropriate steps to ensure that such recipients are bound by legally enforceable obligations or specified certifications to provide the transferred Personal Data a standard of protection that is comparable to that under the Personal Data Protection Act 2012 (“PDPA”).

When you provide your Personal Data to us via our websites, applications or third-party social networks, you agree to any such transfers, storage or other processing.

For how long your Personal Data is stored

We will only retain your Personal Data insofar and as long as it is necessary for the purposes for which the information was collected or as permitted under applicable law. This includes retention of your Personal Data where it is in our legitimate interest or to comply with any legal obligations and/or requirements which we may be subject to (such as a legal requirement to retain data for a minimum period of time, or for tax and accounting purposes).

Please be advised that in certain situations, we may anonymise your Personal Data (such that it can no longer be linked to your identity) for research or statistical purposes. In such situations, we may continue to process such data indefinitely without further notice to you.

Withdrawing your consent

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided in the “How to contact us” section above.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 14 business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email to our Data Protection Officer.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Access to and correction of personal data

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within 14 business days. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing, within 30 days, of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Personal Data of minors

As we are unable to distinguish the age of persons who access and/or use our websites, a blanket privacy policy is applied. We do not knowingly collect any Personal Data from persons under the age of 18. If you think that a person below the age of 18 has provided us with Personal Data without parental or guardian consent, we strongly encourage you to contact us immediately and we will use our best efforts to promptly remove such information from our records.

Third party websites and services

Our websites may contain links to third party websites and services with which we have no affiliation, and who may adopt different data protection and privacy policies than us. A link to or other availability of any third party website or service does not mean we endorse it, or the quality or accuracy of the information presented on it. When you click on one of those links, you are entering another website over which we have no control and will bear no responsibility. Our Privacy Notice does not apply to those third party websites and services, and we encourage you to carefully review the legal and privacy policies of those third parties if you decide to visit their websites and/or use their services.

Privacy Notice for Snap4me
(For India)

Disclaimer: In the event of any discrepancy or conflict, the English version will prevail over the other translated versions.

Snap4me Private Limited, an entity registered under the laws of Singapore, owns, and operates the website https://www.snap4me.com/ and the Snap4me mobile application (“Platform” or “Snap4me”). The Platform is operated in India by D-Tach Innovation Private Limited, a private limited company incorporated under the (Indian) Companies Act, 2013. Snap4me Private Limited and D-Tach Innovation Private Limited are hereinafter collectively referred to as "We", “our”, and “Us”. This privacy policy (“Privacy Policy”) governs the receipt, collection, processing, storage, usage, transfer, and disclosure of personal data (“Personal Data”) of users (“You”, “Your”, and/or “User/s”) through the Platform. We process Personal Data of Users in its capacity as a data fiduciary as the term is defined under the Digital Personal Data Protection Act, 2023.

Snap4me is a platform which allows Users (referred to as a seeker) to raise a request for a photograph, video or livestream of any location around the world and any other User of the Platform (referred to as a snapper), can then accept this request, travel to the location and share the photograph, video or livestream through the Platform. The Users (both snappers and seekers) can be from any country in the world. Please note that this Privacy Policy has to be read along with the Terms of Use of our Platform which is available at https://www.snap4me.com/terms. The protection and security of Your Personal Data is one of our top priorities. This Privacy Policy applies to our Users who have registered on the Platform either as a snapper or a seeker. By accessing, browsing, and using the Platform, You agree to the practices and policies set forth in this Privacy Policy. You hereby acknowledge that You have expressly consented to our collection, use, processing, storing, disclosure and/ or transfer of Your Personal Data in the manner as described hereinunder and for the specified purposes. If you do not agree to any part of this Privacy Policy, please immediately cease access and/or use of our Platform, and do not provide Us with any Personal Data.

Please note that this Privacy Policy does not apply to websites maintained by other companies or organizations with which We partner with and/or link, and We are not responsible for any Personal Data You submit to third parties via the Platform. Please ensure that You read the privacy policy of such third parties before submitting Your details. Please further note that our Platform is hosted on Google Cloud and therefore We urge You to review Google Cloud’s privacy policy, which is available at https://cloud.google.com/terms/cloud-privacy-notice.

1. Modes of collection of Personal Data

1. Information You provide us: We will collect Personal Data that You choose to provide Us through the Platform, for registration purposes and in relation to the services provided by Us. For example, for verification, payment / billing / invoicing, marketing communications, and sending notifications to You, etc.
2. Automatically collected information: When You use the Platform, We collect activity information, such as Your device’s IP address, at what time Your device used the Platform, etc. In this regard, We may utilise cookies, pixel tags, web beacons, etc., as further specified in our “Cookie Policy” in Section 3 of the Privacy Policy.

2. Nature of Personal Data Collected and their respective Purposes

3. Cookie Policy

1. We may use cookies, pixel tags, web beacons, and similar files or technologies to collect and store information with respect to Your use of our Platform. This information is collected automatically when You navigate our Platform. A cookie is a small text file that is stored on Your mobile application/ computer that enables Us to recognize You, when You visit our portal, store Your preferences and settings, track Your use of Our Platform, and assist with security and administrative functions as well as monitor Your navigation and search patters on our Platform.
2. Users have the option to accept or disable cookies at any time through their browsers however this may affect the functioning of our Platform.

4. Disclosure and/ or transfer of Your Personal Data with third parties:

We will not share the Personal Data we have collected from You, except as described below:

1. We may share and/ or transfer Your Personal Data with a third-party vendor for verification of identity of the Users. We will share Your Personal Data on a need-to-know basis with these third-parties and only to enable them to perform their services.
2. International Transfer: Your Personal Data may be transferred to and maintained on computers located outside of Your state, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

   If You are located outside India and choose to provide information to Us, please note that We transfer the information, including Personal Data, to India and process it there. Your consent to this Privacy Policy followed by Your submission of Your Personal Data represents Your agreement to that transfer.

3. We may disclose Your Personal Data to law enforcement or regulatory authorities and / or government agencies, as applicable. We may disclose Your Personal Data if required to do so for compliance of a legal obligation under applicable laws or in good faith belief that such disclosure is reasonably necessary to respond to summons, court orders, or other legal process, law enforcement authorities, government authorities, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities. Your Personal Data may be shared, without obtaining prior consent, with government agencies mandated under the applicable laws or any law in India to obtain Your Personal Data for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences. Your Personal Data so obtained by the government agency or authority is not published or shared with any third party, unless the disclosure to any third party is required by an order under the applicable laws in India for the time being in force.
4. We may also disclose Your Personal Data to respond to claims that the uploaded content violates the rights of a third party, or protect the rights, property or personal safety of Our Users or the general public.
5. We may share and/ or transfer some or all of Your Personal Data with another business entity should We plan to merge with, or be acquired by that business entity, or for the purposes of M&A transactions, reorganization, amalgamation or restructuring of our business.
6. If We share and/ or transfer Your Personal Data to third parties for purposes stated in this Privacy Policy, We will use best endeavours to put in place appropriate controls and safeguards to ensure that Your Personal Data is adequately protected and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is necessary.

5. Your rights as Users

1. Access information about Personal Data: You can request a summary of the Personal Data which is being processed by Us and the processing activities undertaken by Us with respect to such Personal Data. You can also request for the identities of all data fiduciaries and data processors with whom Your Personal Data has been shared by Us along with a description of such Personal Data shared. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
2. Option to not provide the Personal Data: You can always elect not to disclose Your Personal Data to Us. However, please keep in mind that We may need some information to allow You to register with Us or for You to take advantage of some or all of the features offered on Our Platform, and if You choose not to provide that information, Your ability to use our Platform and services may be limited.
3. Correction of data: You have an option to always access Your account and Your Personal Data in order to view, add, alter, update and/or modify Personal Data provided to Us. In the event You alter or update Your Personal Data provided to us, some additional documents may be required for verification of such updates. This is to protect Your account.
4. Erasure of Personal Data: You can request for erasure of any Personal Data.
5. Deactivation and/or deletion: You have a right to request for deactivation of Your account, and post such deactivation, Your Personal Data shall not be collected or processed. However, Your Personal Data collected by Us till the deactivation of Your account shall be maintained by Us at least for a period of one hundred and eighty (180) days, as required by applicable law, post which it may be deleted if not required to be retained as per applicable law.
6. Right to withdraw consent (not limited to deactivation and/or deletion): You have the right to withdraw Your consent previously given for the collection, use or processing of all and/or any part of the Personal Data collected by Us, however, please note that this may disrupt Your user experience on Our Platform. You may withdraw Your consent by writing to Us at support@snap4me.com. We shall discontinue processing Your Personal Data (and require other third-parties to discontinue processing) once We receive a request from You in writing, however, We have a right to retain and will not be held liable for processing any Personal Data that We collected prior to the said withdrawal request. We may also need to continue processing if such processing is required or authorized under laws applicable in India.
7. Right to grievance redressal: Please see Section 11 of the Privacy Policy on the grievance redressal mechanism available to You.
8. Right to nominate: You have the right to nominate any other individual who can, in the event of death or incapacity, exercise rights on Your behalf.
9. Timeline: We will respond to Your request as soon as reasonably possible. In general, our response will be within 30 (thirty) business days. In the event We are not able to respond to You within 30 (thirty) business days after receiving Your request, We will inform You in writing, of the time by which We will be able to respond to Your request. If We are unable to provide you with the Personal Data or to make a correction requested by You, We shall inform You of the reasons why We are unable to do so (except where We are not required to do so under applicable Indian laws).

6. Data Security

1. We use commercially reasonable security measures (including physical, electronic and procedural measures) to safeguard Personal Data against loss, misuse, damage or modification and unauthorised access or disclosure. However, no system for transmitting or storing information electronically can be completely secure. Therefore, we cannot guarantee that Personal Data or other communications will always remain secure.
2. We maintain Personal Data pertaining to You in our business records as per current regulatory requirements. We have secure and appropriate data collection, storage, and processing practices. Our security measures protect against unauthorized access, alteration, disclosure or destruction of Your Information including Your username, password, transaction information and data stored on the mobile application or in our database.
3. All private information exchange and transactions on the Platform happen through secured communication channels and is protected. Securing Your Personal Data is of paramount importance to Us.
4. From time to time, We may reveal general statistical information about our Platform and visitors, such as number of Users, examples of requests made by seekers, etc., however, this will be anonymized or de-identified.
5. Only those of our employees and / or third-party partner’s employees, who need access to Your information in order to perform their duties as mentioned in the purpose section of this Privacy Policy, are allowed such access. We guarantee that our employees and/or any other person processing Your Personal Data will respect the internal rules and procedures related to the Personal Data protection, including the technical and organizational security measures implemented to protect Your Personal Data.
6. In this context, We regularly review and update our practices to enhance Your privacy and ensure that its internal rules and procedures are duly followed. Our data collection, handling and processing practices are also continually reviewed to ensure compliance with the applicable data protection and privacy laws and regulations in India.
7. We assume no liability or responsibility for disclosure of Your Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
8. If You have come across a vulnerability or would like to report a security incident, You can directly contact the Grievance Officer by using the contact information provided in Section 11 of this Privacy Policy.

7. Retention of Data

1. We will retain Your Personal Data and any data only for the period necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by Indian law.
2. Pursuant to withdrawal of consent or cancellation of registration, We will retain Your Personal Data for a period of at least one hundred and eighty (180) days.
3. Under Indian laws, We process Your Personal Data with Your consent. However, You are entitled to withdraw Your consent any time and ask Us to stop such processing, in which case We will process Your data for a short period of time after this (and solely to allow Us to implement Your requests), provided there is no other legal ground for further processing.
4. If deleting Your data would make ongoing research impossible, or significantly impair it, We may keep the necessary part of Your data for use solely as required for that research. After that, Your Personal Data will be deleted or anonymized.

8. General

1. To help Us in protecting Your privacy, You should maintain secrecy of Your login ID and password, if any, provided to You in connection with Your account. You should not share/transfer/ disclose Your account related information or one-time password with anyone, nor will any of our representative(s) ask You for the same. Multiple access of Your account is also prohibited.
2. You acknowledge and agree that if You provide any Personal Data that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete over a period of time), or We have reasonable grounds to suspect that such Personal Data is untrue, inaccurate, not current or incomplete, We may not be able to provide You with continued access to our Platform. Your Personal Data collected and access to our Platform is subject to the Terms of Use of our Platform, and You are advised to read the same carefully in conjunction with this Privacy Policy.

9. Minors

1. Our Platform is directed to be used by adults only and not meant for use by minors. We will not knowingly collect or solicit Personal Data from minors or provide access to minors. If You are not an adult, while You may look at our site, You should not register, or submit information to Us. We or our associates / affiliates do not knowingly collect information from minors. If We learn that We have collected Personal Data from a minor under the age of 18, We will delete that information as quickly as possible. If You believe that a child under the age of 18 may have provided Us with Personal Data, please contact us at support@snap4me.com.

10. Changes to privacy policy

1. The Privacy Policy may be amended from time to time. This could be undertaken to reflect changes to the Platform or the applicable Indian laws. We will provide You with the updated Privacy Policy by appropriate means as required by applicable Indian laws. In any case, We recommend that You review this Privacy Policy each time You use the Platform.
2. Once posted on our Platform or otherwise notified to You, the revised Privacy Policy supersedes all previous versions, and continued access to and/or use of our Platform after the date of such revision constitutes your acknowledgment of such changes and agreement to be legally bound by the terms of the revised Privacy Policy.

11. Grievance Redressal Mechanism and Grievance Officer

1. For the purpose of grievance redressal or in the event You have any questions regarding our privacy practices or this Privacy Policy, please contact our Grievance Officer:

   Name: Mr. Mukesh Kumar Jindal

   Postal Address: D TACH INNOVATION PRIVATE LIMITED 403, 4th Floor, Bajaj House 97, Nehru Place, South Delhi, Delhi, 110019

   Email: support@snap4me.com

2. We will acknowledge Your complaints/ grievances within 1 (one) business day and resolve such complaints/ grievances within 15 (fifteen) business days.