SnapCom acts as a data processor with regard to indirect end user personal identifiable information and our Clients act as the data controller of such data. In the course of Snapcom’s processing and protection of such data, all use will be in conformity with the data controller’s instructions. Specifically, only when enabled via system permission on SNAPPhone Android and SNAPPhone iOS, Snapcom shows personal contacts within the respective application. When the user sends an SMS message to one of his/her phone contacts, or when the user initiates a call to one of his/her phone contacts, the phone number is sent securely through Snapcom’s API. Snapcom does not store this number with any other PII, and it cannot be directly or indirectly attributed to any person or persons; Snapcom stores only the phone number and pertinent metadata so as to be compliant with all applicable state and federal laws, and Snapcom does not share this data with any advertisers or third parties under any circumstances. A user can revoke phone contact access on his/her mobile device at any time, and his/her app experience is not hindered or interrupted. SNAPPhone Android and iOS also uses Gravatar, only when enabled via Settings and UIConfigs, which is a service that provides avatar images linked to the MD5 hash of the user’s email address. This means that, only when Gravatar use is enabled, we hash each contact’s email address and send it to Gravatar to try and retrieve an avatar image. MD5 hashes cannot be directly or indirectly attributed to any person or persons, and we only send the MD5 hash to Gravatar, never the email address in plain text. As with phone contacts, a user can revoke Gravatar access at any time in Settings or via UIConfig, and his/her app experience is not hindered or interrupted. Additionally, PII is processed the same way in regards to data in the SnapcomGo softphone and for SNAPMeet video conferencing software

Snapcom uses such personal information only for relevant, appropriate, and customary purposes. Snapcom will not share or disclose personal information for purposes other than as described herein. Capitalized terms used in this Privacy Policy shall have the meaning as given in Client’s Master Services Agreement (MSA). The following are examples of some of the personal information Snapcom may process.

Snapcom may collect and use personal information about individual contacts of Clients and others who access Snapcom public websites, knowledge bases, forums, ticket systems, or provide personal information through other means. Such information may include but is not limited to account information, first/last name, company name, title, and responsibilities, work email address, work mailing address, telephone numbers, login information, device identifiers, as well as additional information provided by such individuals in the course of receiving Products and Services from Snapcom and/or requesting information about Snapcom. We will use such information for the purposes of providing Products and Services, support, conducting data analytics and product assessments and related activities, and providing information regarding Snapcom Products and Services.

We use the information we collect in various ways, including to: Provide, operate, and maintain our website Improve, personalize, and expand our website Understand and analyze how you use our website Develop new products, services, features, and functionality Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes Send you emails Find and prevent fraud

Snapcom follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

Like any other website, Snapcom uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information. For more general information on cookies, please read “What Are Cookies”.

You may consult this list to find the Privacy Policy for each of the advertising partners of Snapcom. Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Snapcom, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. Note that Snapcom has no access to or control over these cookies that are used by third-party advertisers.

Snapcom’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.

Under the CCPA, among other rights, California consumers have the right to: Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers. Request that a business delete any personal data about the consumer that a business has collected. Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. Snapcom does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.