Privacy Policy

Last Updated: April 12, 2023

Privacy Statement Summary

We take your privacy seriously and will only use your personal information to provide the services you have requested from us and to send you information about services you may be interested in. We will never sell, share, or use your personal information other than as described here.

About This Privacy Policy

This policy sets out how we will use and share the information that you give us. This policy describes your relationship with Snaptron, Inc.

We operate in line with the General Data Protection Regulation (GDPR) guidelines and other applicable data protection regulations. The GDPR describes how organizations must collect, handle, process, and store personal information.

These rules apply regardless of whether data is stored electronically, on paper, or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely, and not disclosed unlawfully. GDPR is underpinned by eight important principals. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant, and not excessive
• Be accurate and kept up to date
• Not be held for any longer than is necessary
• Processed in accordance with the rights of the data subjects
• Be protected in appropriate ways
• Not be transferred outside the European Economic Area, unless that country or territory also ensures an adequate level of protection

We take these responsibilities seriously; this document describes our approach to data protection. This policy helps to protect us from data security risks, including:

• Commercial, financial, and reputational damage caused by a data breach.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
• Any other loss or damage caused as a result of failure to meet Data Protection regulations

Who We Are And How To Contact Us

Snaptron is a trading name of Snaptron Inc that is registered in the USA and is registered with the Information Commissioner’s Office. The data controller is Ashley Steinbach. You can contact us in any of the following ways:

• Email: [email protected]
• Phone: +1970.686.5682
• Website: https://www.snaptron.com
• Post: Snaptron Inc. 960 Diamond Valley Drive, Windsor, CO 80550, USA

Who this privacy policy applies to

Snaptron is a manufacturer. Processing of your data is required in order to offer you our products and services. This policy applies to individuals who have shared their data with Snaptron as either a potential customer, customer, employee, supplier or in any other capacity.

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

• Names of Individuals
• Postal addresses
• Email Addresses
• Telephone numbers
• Image and Video Content
• Electronic and Printed Media
• Likeness and edited images of identifiable individuals
• Individuals captured on images other than the principle subjects

What this policy applies to

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:

• The Information you provide when you contact us in order to discuss using our services
• Information we collect about how you use the website
• Information relating to services we offer to you and other transactions including financial and other personal information required to complete these transactions
• Information that is given and stored as part of our ongoing relationship
• Images, videos, and other media
• All material (electronic / printed / other) capturing your image and likeness

We do not normally collect or process sensitive data about you, however where this is necessary, we will take appropriate precautions to protect your data.

How your information will be used

We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:

We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), product and service details, purchase history, and data collected as part of any finance application or payment (including previous addresses, employment details, and bank account details). As part of the services we provide to you we will collect, store, and process images in various formats. We may take personal information from:

• Information that you provide to us when registering with our website (including your email address)
• Information that you provide when completing your online profile (including your name, gender, date of birth and any educational details and employment details you provide)
• Information that you provide to us when signing up to any distribution lists to receive correspondence from us
• Information relating to any purchases you make of our services, including any other transaction details made via any of our websites (including your address, telephone number, and payment details)

Personal data we receive will be used for the purposes it was provided, including:

• To respond to queries from you regarding the possible purchase of services
• To carry out our obligations arising from any contracts entered into between you and us including the provision of services, and to respond to queries from you regarding those contracts
• To manage and administer the relationships between you and us
• To notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us
• To obtain feedback from you regarding us
• Images, videos, and other media collected, stored, or processed as a result of the services we have provided to you

In accordance with your preferences, we may also use your personal information to provide you with information about services, promotions and offers that may be of interest to you. We may use your personal information in order to ascertain the services, promotions, and offers that are likely to be of particular interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any purchases you make or services you use.

How to change your preferences

We operate in line with EU GDPR (May 2018) data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data, and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller, or you can visit our website, call, or email us to contact us to change your preferences at any time.

Scope of Agreement

By submitting your personal data on this site or as required for us to provide products and services to you, you are affirming your agreement for such information to be used in accordance with this privacy policy. You will be able to change your preferences at any time by the methods described as prescribed in this document.

We may, from time to time, use your information for marketing, account management, or relationship management purposes. The main purpose of this is to provide you with information about the services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.

Opting out at a later date

Where you give your consent for us to process your data, for example when you agree to us sending you marketing information or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at any time. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.

How we store and process your data

Your data will initially be collected stored and processed securely at our operating facility in Windsor, Colorado, USA. Where possible we store your data in the EU; however, we may use cloud storage options outside the EU. Where this is the case, we will take reasonable precautions to ensure your data is secure at all times. Your data may be stored indefinitely to ensure we have records of service, payments, and other interactions we have with you and to be able to provide copies of photos, videos, and other material to you in the future. Subject to your right to demand deletion of data.

In order to provide our services to you, we use recognized third parties to take payment, conduct credit reports, and other checks, manage our company accounts, and provide banking services. We will store transactions, payment, and order data for up to 7 years or for as long as required by the various applicable financial and company regulations. These third parties may operate outside the EU, if this is the case we will ensure precautions are in place to protect your data.

Depending on your location, data transfers may involve transferring your data to a country other than your own. To find out more about the place of processing of such transferred data, you can check the section,  “Detailed Information on the Processing of Personal Data,” containing details about the processing of personal data.

You are also entitled to learn about the legal basis of data transfers to a country outside the EU or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Snaptron to safeguard their data.

If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with us by using the information provided in the “Contacting Us” section.

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

You will only receive marketing communications from us if you have:

• Requested information from us or purchased services from us
• If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications
• You have not opted out of receiving marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Our obligations

We are a data controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the GDPR (2018) and other applicable regulations in the way we use and share your personal data.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

We will of course respect all your rights under GDPR, PECR, ePrivacy, and other relevant legislation. You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Third Parties

We may have to share your personal data with the parties set out below for the purposes described in this document:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance, and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
• Companies we use to provide our products and services to you and to meet our contractual commitments.  This may include a range of contractors, suppliers, third parties, delivery companies, etc.…

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Detailed Information on the Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.

Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section “How to opt-out of interest-based advertising” in this document.

LinkedIn Ads (LinkedIn Corporation)

LinkedIn Ads is an advertising service provided by LinkedIn Corporation.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

Analytics

Heat Mapping and Session Recording

Heat mapping services are used to display the areas of this website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.

Some of these services may record sessions and make them available for later visual playback.

Contacting the User

Platform services and hosting

These services have the purpose of hosting and running key components of the website, therefore allowing the provision of the website from within a unified platform. Such platforms provide a wide range of tools to Snaptron– e.g., analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.

Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

SPAM protection

This type of service analyses the traffic of this website, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages, and content that are recognized as SPAM.

Tag Management

This type of service helps Snaptron manage the tags or scripts needed on the website in a centralized fashion.

This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

User Database Management

This type of service allows Snaptron to build user profiles by starting from an email address, a personal name, or other information that the User provides to the website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that Snaptron Inc can display and use for improving the website.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this website.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookie Policy

This Application uses Trackers. To learn more, the User may consult the Cookie Policy.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyze data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

As well as your ability to accept or reject cookies, we also require your permission to store cookies on your machine, which is why when you visit our site, you are presented with the ability to accept our terms of use, including the storage of cookies on your machine. Should you not accept then you are free to leave our website at any time.

Legitimate Interests

Under the GDPR, we are also permitted to collect, process, and store your data as required to reasonably operate our business.

Contacting us, exercising your information rights and Complaints

If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact us. We will process SARs within 30 days, SAR responses are usually free, but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.

If you remain dissatisfied, then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk

The contact information for all other EU data protection authorities can be found at:
https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

We have appointed EU and UK Representatives under Article 27 of the EU GDPR and UK GDPR, respectively. Our appointed representatives are:

Our EU Representative:
Under Article 27 of the GDPR , we have appointed an EU Representative to act as our data protection
agent. Our nominated EU Representative is :

Instant EU GDPR Representative Ltd.
Adam Brogden [email protected]
Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD
Office 2,
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8
Ireland

Our UK Representative:
Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data
protection agent. Our nominated UK Representative is: GDPR Local Ltd.

Adam Brogden [email protected]
Tel +44 1772 217800
1st Floor Front Suite
27-29 North Street, Brighton
England
BN1 1EB

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