Effective Date: December 17, 2021 or the date of user acceptance.
Thanks for joining the SNUFFLE community. Take the time to read through how we protect your privacy.
1. Who We Are
SNUFFLE is currently only active in the European Union. The company that is responsible for your information and that hereby is mentioned as the “data controller” is Placemakers SCP.
3. Information We Collect
In order to build our community and to make meaningful encounters between you and other pet owners possible, we need to gather user data which includes the basic profile details you are asked to share about you and your pet(s) once you begin using the SNUFFLE mobile application. Additionally, we gather account data to ensure you a safe and protected profile as well as information from third parties to make your access to our services quick, safe and smooth.
Information shared with Snuffle
When using Snuffle, users agree to share the following information with us:
* As users set up an account, they provide us with a basic amount of user data including basic details about their profile and pets in order for the service to be helpful to them including gender, age and personal interest.
* Users can choose to add additional info such as additional profile description and info about the pet(s) they own plus visual content including a profile picture and a profile gallery. In order for Snuffle to use visual material, users agree to provide Snuffle access to either their camera or photo gallery.
* When users share details through support system or surveys to improve Snuffle’s user experience, you provide us with feedback and insight which we can use to improve our services.
* When users participate in events, contests or promotions set up by Snuffle, we are using the information that users provided to us to benefit from access to these.
* All content published by users on Snuffle including all interaction with other users is processed by Snuffle as part of our operations and safety guidance.
User information collected when using Snuffle
When users use the Snuffle services, we gather information about features that users used, how the user used these and the device they used to access these. The following data is being collected:
* Information about profile usage: Snuffle collects details about your activity on the Snuffle platform, including when the profile was created, when the user logs in, features used, advertising they click on).
* Other information shared upon user permission: We use additional user information after consent in order to enable the user experience including Location, Gallery, Camera. We access those features to allow you share these with other users for better user experience.
4. Cookies and Other Similar Data Collection Technologies
5. How Snuffle Uses User Data
Snuffle uses user data mainly to improve the platforms’ user experience. Additionally, we use the data out of safety purposes and to improve the application in the future. Here are the key reasons how we use users’ data:
- To verify and manage your account and to provide services to the user
- To help users to interact with other members of the Snuffle community
- To ensure a consistent experience for the Snuffle platform across different devices
- To develop and provide new services and features to users
- To show users relevant ads and promotions
- To prevent, detect and fight fraud and other illegal or unauthorized activity on the Snuffle platform
- To ensure legal compliance
To process user info as described, Snuffle relies on the following legal aspects:
- Provide our service to you: When using Snuffle to build connections we use your data to manage your user profile and to make it visible to others
- Consent: We may ask user consent for specific features on Snuffle. You can always withdraw your consent at any time by contacting us.
6. How We Share Information
Snuffle brings pet owners together to create possibilities to improve the social live of pets and their owners. Sharing of user data mostly happens through chat conversations with other users. Additionally, we share user details with service providers and partners who support us in operating Snuffle and with legal authorities on a request basis. We limit the sharing of user data to the following:
- Sharing data with other users: The information you share on your Snuffle profile is being shared with other users of our community. Be mindful with the data you share and be aware that this data is visible in a wide area. Do not share information that you are not comfortable with sharing and avoid sharing any data which is rather sensitive.
- Sharing with external providers and partners: We work together with third parties to operate and improve Snuffle. As they assist us with assignments related to the development of our community, including the improvement of key elements related to our platforms such as data hosting, maintenance, analytics, customer care, marketing, advertising and security operations they need access to a limited and restricted set of community data. We clearly ask each of our service providers and external partners to agree to our strict confidentiality obligations.
- Sharing when required by the letter of the law: We share your data with legal authorities if necessary to either comply with a legal process related to a court order or investigation or other legal requirements, with governmentql institutions for criminal prevention or detection of crime as applicable by law, or in order to protect the safety of any person.
- Sharing to enforce legal rights: Snuffle might need to share information if disclosure would mitigate Snuffle’s liability as part of an actual or threatened lawsuit, if necessary for protecting legal rights of Snuffle and our users, business partners or other external partners, or to investigate any illegal activity conducted on our platforms.
- Sharing with your consent or at your personal demand: In specific situations where Snuffle is about to share any of your details externally, it will ask for your consent. If a user needs to request data for any specific reason he needs to contact our support service to check if the request is valid according to legal guidelines.
7. International Data Transfers
In specific cases, data sharing as specified in the previous section, may involve international cross-border data transfers to other regions around the world. When data is shared outside of the European Economic Area (EAA) it follows the regulations of cross-border data transfers. Snuffle uses common contract clauses approved by the European institutions.
8. Rights For You and Your Pet
Snuffle wants to enable users to control their own information flow. As such, we provide you with the following data management options:
- Profile and Settings tab: In the profile and settings tab of the Snuffle application the user can modify the details shared both of him/herself as well as the data in regards to the pet(s) owned.
- Permissions set by device: Use the settings of your device to protect your rights. Carefully check your device settings and review if you want to increase the protection of public data in regard to you and your pet(s). Make sure not to constraint this too much in order to avoid the Snuffle service functionalities to be blocked from operating smoothly. For example, the user need to share his/her location (failing to provide location may impact the functionality in Snuffle services).
- Delete account: Users can delete their account easily at any time under the settings tab.
Snuffle allows you to review your privacy rights. The following points are key:
- Review your details: You have the right to review your personal info that we keep about you. Please request a copy of your personal data by contacting firstname.lastname@example.org.
- Update your details: If the details we hold about you are dated, wrong or inaccurate, or if we are no longer entitled to use any details you can request deletion or rectification by contacting email@example.com.
For such requests we will ask you to provide proof of identity. Requests may be rejected in case these are unlawful or if these infringe on trade secrets or intellectual property or privacy of another user. Written consent is needed from the other involved user in case you wish to obtain specific data from another involved user.
Another reason not enabling Snuffle to operate is when it blocks Snuffle from further providing its services. For instance, location sharing is needed for Snuffle to operate since it needs your geo-location settings allowed in order to be part of the live community. You can stop all information collected by uninstalling the application from your device. If a user reinstalls the Snuffle application, we will be able to reidentify your profile based on your log in details so the user can continue to use the service. Specific rights to lodge a complaint with a data protection authority are available in certain countries if a user has a doubt about how Snuffle is processing your personal information.
10. How We Protect Your Information
Snuffle actively protects users from unauthorized access of your personal details. However, we cannot promise that your personal data is always fully safe. Understand that we do everything in our ability to protect user data.
Our systems are regularly being monitored against vulnerabilities and attacks. We constantly review and improve the Snuffle security measures for protecting user data. Anyone trying to use Snuffle in a unlawful way will directly be removed from the service. If you believe your profile is no longer secure, please contact us at firstname.lastname@example.org. In case of a security breach, we may suspend a user`s access.
11. How Long We Retain Your Information
Snuffle keeps your details only as long as we need it for legitimate business purposes taking into account the applicable law. User data is kept until two months after deletion of a profile in order to protect the safety and security of other users within the community. During this time frame, profile details are retained but will not be visible on the platform. In case there is any reason related to the applicable law, or if there is an outstanding issue Snuffle will retain user data for another two year time frame until being reviewed before deletion. Bear in mind that we cannot promise all data will be deleted within a specific timeframe due to technical constraints.
Snuffle is fully restricted in usage for people under 13 years old. Anyone under the age of 18 needs to be accompanied by a family member while using the app at all times. In case other users detect users under the age of 13 or anyone under the age 18 unaccompanied of a family member, we kindly request them to report these through the reporting option on Snuffle so our team can address this.
15. Which Data Do We Collect?
Information which we are collecting includes:
- Phone number
- Date of birth
- Pets owned
- Pictures (Profile pictures)