Privacy Policy

IMPORTANT NOTICE FOR CALIFORNIA RESIDENTS

If you are a California resident, please read the following important notice.

Pursuant to the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request the following:

• The categories of personal information processed by us;
• The categories of sources from which the personal information is obtained;
• The purpose of processing the user’s personal data;
• The categories of third parties with whom we may share your personal information;
• We may obtain specific pieces of personal information about a particular user, provided that the data offered in the request is reliable enough to identify that user.

Please use the navigation links in this Privacy Policy:

• Personal Information
• Detailed introduction to information categories, sources, and processing purposes >>

Please note that, under the CCPA, Personal Information does not include de-identified or aggregated consumer information.

Sharing

• How Your Information is Shared >>

Please note that all third parties involved in processing user data are Service Providers who use such information under agreement and for a business purpose.

Opt-Out Options

If you do not want us to continue processing your personal information, please contact us at [email protected]. In most cases, the Snap Clear application will not be able to function without functional data, and therefore we recommend that you uninstall the application from your device.

If you do not want us to share device identifiers and geolocation data with Service Providers, please check your device settings and opt-out as follows >>

Requests

To submit a verifiable consumer request to access, transfer, or delete personal data, please contact us at [email protected]. Please include the words "Your California Privacy Rights" in the body of your request.

When submitting a verifiable request, you should be ready to:

1. Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include: name, address, city, state/province/region, postal code, and email address. We may use this information to ask you a series of security questions to verify your identity. If you are submitting a request through an authorized agent, the agent must provide a written authorization form or power of attorney signed by you.
2. Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

We will be unable to respond to your request or provide you with personal information if we are unable to: (i) verify your identity or authority to make the request; or (ii) confirm that the personal information relates to you. We may ask you to provide additional information or documentation to verify your identity. We may also conduct verification, including using third-party identity verification services, before taking any action regarding your personal information. This is considered a safeguard measure designed to prevent the disclosure of your personal information in response to a fraudulent or malicious request.

We guarantee that personal information provided in a verifiable consumer request will be used only for the purpose of verifying the requestor’s identity or authority to make the request and for no other purpose. We will retain this information for as long as is reasonably necessary for the purposes set out above, after which we will delete it.

We endeavor to respond to a verified consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you in writing of the reason and extension period. Please note that we are only required to respond to two requests per customer per year.

Equal Rights

Our response to your requests will in no way constitute discrimination, meaning that we will not set different prices or products, nor provide a different level or quality of services to you if you choose to exercise your rights. However, in certain circumstances, if you choose to delete your personal information from our records, we may not be able to continue providing services to you.

Sale of Data

We do not sell any of your personal data to third parties.

I. Information We Process

The information that may be processed is divided into several categories.

Functional Information and Information You Submit

When you use the Snap Clear application, we request and process the following personal information. This information is essential for the performance of the contract between you and us. Without this information, we will not be able to provide the full functionality of the application and the services you have requested.

• Activity Information directly related to your use of the application. After you make the relevant settings on your device, we may read your calendar information—to retrieve expired events, and access your photos—to search for similar photos. However, we do not collect, use, or store data contained in your calendar events or photos on any of our servers.
• All files that may be processed are stored on your local device and/or iCloud storage and are not accessible to us. Only you can export files through the application and share them with specific parties.

Payment Details

If you have purchased a subscription on the App's webpage and wish to cancel it by contacting us at [email protected], we may ask you to provide one of the following pieces of information:

• The email address registered when purchasing the subscription
• The receipt number used to identify the payment
• The unique identification number of the invoice.

Automatically Processed Information

With your permission, we use third-party automatic data processing technologies (advertising and analytical tools) to analyze certain information your device sends through our application (advertising identifiers for iOS devices, Advertising ID or Android ID for Android devices). Some integrated advertising or analytical tools (see Section IV for a list of tools) initiate automatic processing of your personal data, including profiling. Profiling means any form of automated processing of personal data used to evaluate certain personal characteristics relating to you, in particular to analyze or predict your personal preferences, interests, behavior, location, or movements (see the list of data below). The operation of processing information by automatic data processing technology starts automatically once you allow our application to track your activity. You may withdraw your permission at any time – please refer to the Opt-Out Options in Section VIII below.

Based on our legitimate interests, we may process some information about your device and user behavior. This information falls within the data categories described in the “Automatically Processed Information” subsection above, is usually non-personal, meaning that it cannot be directly associated with any particular individual, and we can only access this information in an aggregated form. We use this information to improve our application and provide the best experience for users.

Data that may be processed:

• Device Details. When you access our application using a mobile device (tablet/phone/smartwatch), we report some details about your device, including a “Device Identifier.” A Device Identifier is a small data file or similar data structure stored on or associated with your mobile device that uniquely identifies your mobile device (but does not identify you). A Device Identifier enables third parties to provide general reporting or personalized content and advertising.

    ⚪︎ Information about the device itself: device type, operating system type and its version, model and manufacturer, screen size, screen density, orientation, volume and battery, device memory usage.

    ⚪︎ Internet connection information: mobile carrier, network provider, network type, IP address, session timestamp and duration, speed, browser.

    ⚪︎ Location-related information: IP address, country/state/city associated with your SIM card or device, language settings, time zone, nearby points of interest (e.g., “coffee shop”).

    ⚪︎ Other device identifiers: e.g., User ID (if set by the application developer).

• Application information, such as name, API key (application identifier), version, and attributes, may be reported for automated processing and analysis. Certain services also record lists of applications and/or processes installed or running on your device.
• Cookies and Similar Technologies. We may use Cookies and similar technologies (e.g., pixels, web beacons, scripts) when you use the Snap Clear application. A Cookie is a text file containing small amounts of information that is downloaded to your device when you access the application. This text file is then sent back to the server each time you use the application. This allows us to operate the application more efficiently. For example, we can learn how many users access specific areas or features within the application and which links or ads they clicked on. We use this aggregated information to understand and optimize how the application is used, improve our marketing efforts, and provide content and features that may be of interest to you. We may invite advertisers or other partners to deliver advertisements or services in the application, and these advertisements or services may use Cookies or similar technologies.

• Log File Information. Log file information is automatically reported each time you request to access the application. Log file information is also generated when the application is installed on your device. When you use our application, analytical tools automatically record certain log file information, including the time and date you start and stop using the application, and how you interact with the application.
• Advertising-related information. The following data may be related to the advertisements you see: the date and time a specific ad was shown; whether the ad was "clicked" or marked as a "conversion" event; the content of the ad; the type of ad (e.g., text, image, or video); the ad placement (where the ad was displayed in the app); whether you responded to the ad.
• In-app events. When you use our application, analytical tools automatically record information about your activity (tutorial steps, upgrades, payments, in-app purchases, custom events, progress events, methods of restricting user data processing).

The information automatically provided to advertising or analytical tools is generally outside of our control, and therefore, we are not responsible for the processing of such information. Please note that some services perform personal data analysis and may use technologies beyond our responsibility to obtain information related to your personality and/or device. If your User ID is associated with your Facebook account, Facebook may combine your device information with classified data already recorded in its database (such as your age, gender, or other demographic information). We do not control, supervise, or guarantee how third parties process your personal data collected through their own means (not through our application). Any request regarding the disclosure of your personal information should be addressed directly to the relevant third party (see Section IV).

Payment Information

Our e-commerce service provider (Apple) is responsible for billing, processing, and charging for your purchases, and for processing your personal information to ensure its absolute security. The processing of this information is part of the performance of the contract between you and us. We do not have access to or use your credit or debit card information.

You can access the applicable rules and policies for "in-app" purchases directly from the application store.

Email Newsletter

When you register within the app and provide your email information by choosing the "Sign in with Apple" option (i.e., create an app account using your Apple ID), we may, based on our legitimate interest, use such email information to send you news concerning special subscription offers, new features, and other app-related news ("Newsletters"). Sending you Newsletters keeps you up to date on the latest from our app, including the best offers. Please note that when you provide email information using "Sign in with Apple," you may choose to share your email address or choose to hide your personal email address (if the "Hide My Email" option is available). If you choose to hide it, Apple will generate and provide us with a unique random email address that automatically forwards to your personal inbox. You hereby confirm and agree to our processing of some of your personal data (e.g., your name information if provided, app registration date, subscription purchase date, geolocation data, activity information, etc.) for market analysis activities, specifically to send you targeted Newsletters that best suit your needs and interests. The email address information we receive from you may be transferred to email marketing tools to optimize and automate the email sending process (see Section IV for more on that tool’s privacy policy and practices). You may also unsubscribe at any time and choose not to receive the Newsletters sent to your email by using the unsubscribe link in every email we send. We will process your unsubscription request within a reasonable time.

II. Purposes of Processing Your Personal Data

Our mission is to constantly improve our application Snap Clear and provide you with new experiences. To achieve this mission, we use your information for the following purposes:

(a) To provide our services. We use functional information, information you submit, and automatically processed information to provide you with all requested services. We may process some of your payment information if you wish to cancel a subscription purchased on the application webpage.

(b) To improve, test, and monitor the effectiveness of our application. We use automatically processed information to better understand user behavior and trends, detect potential failures and technical problems, and to operate, protect, improve, and optimize our application.

(c) To provide you with interest-based (behavioral) advertising or other targeted content. We may use automatically processed information for marketing purposes (showing you advertisements that we believe may be of interest to you based on your preferences). We provide you with personalized content and information, which could include online advertisements or other forms of marketing.

(d) To communicate with you. We use the information we have to communicate with you through Newsletters, such as sending you marketing notices, receiving your feedback on your experience with our application, and informing you about our policies and terms. We also use your information to respond to you when you contact us.

(e) To prevent fraud and spam and to enforce the law. We genuinely want to keep our application free from spam and fraudulent content and to make you feel safe. We may use your information to prevent, detect, and investigate fraud, security breaches, potential prohibited or illegal activity, protect our trademark, and enforce our terms of use.

If any new purposes for processing your personal data arise, we will inform you about the start of processing information for that additional purpose by making appropriate amendments to this Privacy Policy.

III. Information Sharing

We will only share your information with third parties in the ways described in this Privacy Policy. We comply with the Self-Regulatory Principles for Mobile Environments of the Digital Advertising Alliance.

Please note that when integrating external services, we select third parties that ensure all necessary technical and organizational measures are taken to protect users’ personal data. However, we cannot guarantee the security of any information transmitted by us to any such third party. We are not responsible for any accidental loss or unauthorized access caused by the negligence of a third party.

We do not rent or sell your personal data to any third party, but we may share information from tools such as log files, device identifiers, and location data with third-party organizations that provide automated data processing technologies for the application. We cannot control or influence these third-party organizations’ tracking technologies or how they may be used.

We may also share certain information, such as Cookie data, with third-party advertising partners. This information allows third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

We may engage the following third-party service providers to provide us with the necessary infrastructure for delivering and improving our services:

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【Third-Party Service Providers】

1. Google (Google Analytics)

2. Facebook (Facebook Ads)

3. Firebase

4. Apple (App Store & Payment)

5. [Other Service Providers]

If you would like to know more about these services and their privacy options (including opting out), please consult the respective websites and privacy policies. We are not responsible for the use of your personal data by the third parties mentioned above in breach of our instructions.

Our Snap Clear application may contain links to third-party websites/services, or you may be directed to our application from third-party websites. We are not responsible for the privacy practices employed by third-party websites or services linked to or from our application, including the information or content contained therein.

We may disclose your personal information if required for objective reasons, public interest, or other unforeseen circumstances:

• As required by law;
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we will notify you via email and/or a prominent notice on our application of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

IV. International Data Transfers

We operate on a cross-border basis to provide our Snap Clear application to users around the world.

We and the third-party organizations that provide automated data processing technologies for the application or our third-party advertising partners may transfer automatically processed information across borders, from your country or jurisdiction to other countries or jurisdictions around the world.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to countries and jurisdictions that do not have the same data protection laws as your jurisdiction.

This means that your personal information may be transferred to a third country, a territory or one or more specified sectors within that third country, or an international organization, which may not offer the same level of personal data protection as the law of your country on data protection and confidentiality.

We strive to ensure that all recipients of personal data provide an adequate level of protection for the personal data received in accordance with applicable information protection laws and regulations. By using the application, you consent to us transferring your personal data to any third country, a territory or one or more specified sectors within that third country, or an international organization.

To store data, we use the services of hosting providers. We take your privacy seriously, so we encrypt your personal data, where possible, before sending it to a hosting provider for storage. Please note that we only work with hosting providers that have passed our security and reliability check.

V. The Time We Use Your Personal Data

We generally retain your personal information for as long as is necessary to fulfill the functions of the application and comply with our legal obligations. If you no longer want us to use your information that has been actually accessed and stored, you can request that we delete your personal information and close your account.

However, some data may still be stored for a certain period (but not longer than is necessary for the purpose of storage) if required to fulfill legal obligations (tax, accounting, auditing) or to maintain security and data backup settings, prevent fraud, or other malicious actions.

VI. Exercising Your Rights

Applicable data protection laws grant you certain rights regarding your personal information. You have the following choices regarding your personal information that we collect:

• Data Access and Portability. You can request a copy of your personal information.
• Change or Correct Data. If you cannot update the data yourself through your account, you have the right to request that we correct, change, update, or amend your data.
• Data Retention and Deletion. User data is generally retained as long as your user account exists or as necessary to provide the relevant services. However, the specific retention time may vary depending on the particular context of the processing. You have the right to request the deletion of all or part of the personal data we hold about you.
• Right to know about data sharing. You have the right to know whether your data is being shared with third parties. For details on this issue, please refer to Section IV of this Privacy Policy. If you have any questions about this, you can always contact us.
• Restrict Processing. You have the right to limit the ways in which we use your personal information in certain circumstances.

You also have the right to lodge a complaint with a local data protection authority or regulatory body if you believe that your rights under applicable data protection laws have been violated. Please note that when exercising your right to lodge a complaint with a local data protection authority or regulatory body, you may need to provide supplementary information and support your complaint with sufficient objective evidence. By lodging a complaint, you agree to fully explain what you believe has damaged your rights. Also, in some cases, you may need to submit a preliminary complaint to us and, if necessary, ask us for clarification before lodging a complaint with a local data protection authority or regulatory body.

In some cases, you may object to the automated processing of your personal information. If your personal information is used for direct marketing purposes, you can request that your data stop being used for those direct marketing purposes. To exercise your rights, please contact the third-party service providers listed in Section IV of this Privacy Policy to find out how to object to the processing of your data. Most of them provide clear instructions on their privacy pages, functional APIs, or other options.

If you are located in the European Union, you can contact us with any privacy questions at [email protected].

VII. How to Opt-Out

Opting Out of Marketing Tracking

You can manage your activity tracking permissions. For example, if you do not want third-party service providers to serve personalized ads based on your interests, follow these instructions:

• For iOS devices: Go to Settings > Privacy & Security (or Privacy in earlier iOS versions) > Tracking, and tap to turn tracking permission off or on for specific apps.
• You can also control whether apps can ask to track your activity. If you don't want to receive requests or want to stop apps from accessing your device's advertising identifier, go to Settings > Privacy & Security (or Privacy in earlier iOS versions) > Tracking, and turn off the "Allow Apps to Request to Track" switch. If you turn off "Allow Apps to Request to Track," you won’t receive prompts from apps that want to track your activity. Every app that asks for permission to track while this setting is off will be treated as if you tapped "Ask App Not to Track." Visit the following link for more information: https: //support.apple.com/en-us/HT212025 or check the Settings > Privacy & Security (or Privacy in earlier iOS versions) > Tracking section on your device.
• If you wish to turn off Apple's ad targeting, go to Settings > Privacy & Security (or Privacy in earlier iOS versions) > Apple Advertising, and turn the "Personalized Ads" switch off. More information is available here: https: //support.apple.com/en-us/HT202074

Please note that even if you opt out of certain interest-based advertising, you may continue to receive contextual advertisements based on other non-personal information, such as advertisements related to the content of other digital products you are using.

Opting Out of Location Data Processing

If you do not want third-party service providers to use your precise location data or street-level location information, follow these instructions:

For iOS devices, turn off Location Services for the respective product via the Settings > Privacy & Security (or Privacy in earlier iOS versions) > Location Services menu. Then select the respective application and set the "Share My Location" status to "Never." More information is available here: https: //support.apple.com/en-us/HT203033.

VIII. Security

We are committed to the security of your personal information. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures aimed at effectively implementing data protection principles, such as data minimization, and integrating the necessary safeguards into the processing. We strive to use appropriate and strong encryption algorithms (including hashing algorithms where possible) to encrypt your personal data.

Unfortunately, no method of transmission over the Internet or electronic storage is 100% secure. While we do our best to protect your personal data, we cannot guarantee its absolute security. If your personal information is compromised as a result of a security breach, we will promptly notify you in accordance with applicable law.

If you have any questions about the security of our Snap Clear application, you can contact us via the email or contact form shown below.

IX. Children’s Privacy

Our application is not directed to children. Therefore, we do not knowingly or intentionally collect or solicit personal information from any child. For the purposes of this Section X, the term "child" appearing in data processing activities is to be interpreted contextually according to applicable data protection laws. No one who is considered a "child" under applicable data protection laws should provide any personal information directly to this application.

As a general rule, we consider a person under the age of 16 to be a "child" until we have a legal basis to conclude that a person under the age of 16 should be considered an adult, as specified by local data protection rules or based on authorization directly provided to us by a parent.

It is the responsibility of the parent with custodial responsibility to prevent their child from providing personal information through the application without the relevant verifiable parental consent. If we become aware that we have collected personal information from a child without verified parental consent, we will delete that information as quickly as possible. If you have reason to believe that we may hold any information from or about a child, or that a child has directly provided personal information to us through the application without verifiable parental consent, please contact us.

X. Changes to the Privacy Policy

This Privacy Policy is updated periodically.

Whenever we change this Privacy Policy, we will post the changes on this Privacy Policy page and in other places we deem appropriate. Depending on the specific circumstances, we may also provide you with notice of a change or update in other ways.

XI. How to Contact Us

If you have any questions about this Privacy Policy, please feel free to contact us at [email protected].