Privacy Policy

Last updated: 06/03/2024

1. Who We Are

Snaxx Labs LTD and its subsidiaries ("Snaxx" "we" "us" or "our") places a high value on your privacy and is dedicated to safeguarding the personal data we process about you. Snaxx operates as a social network offering a platform that empowers both "Creators" to share and monetize their own content as well as allowing "Fans" to subscribe to and access Creators' content.

2. About this Policy

This privacy policy ("Policy") outlines our data handling practices concerning the personal information we collect from our Creators and Fans. Certain sections of this Policy are tailored to address Creators while others pertain to Fans. It also extends to the processing of personal data of individuals featured in content uploaded by a Creator ("Content Creators") and any instances where we process personal data in the context of our business relationships.

We process your personal data when you engage with our website which can be found at www.snaxx.app ("Website") as well as when we provide the services that we periodically offer via our Website. Additionally we process your personal data when you interact with us through our social media profiles on third-party platforms (e.g. Twitter and Instagram) or through other means. In this Policy we collectively refer to these activities as the "Services."

We act as a "data controller" of the personal data we process in relation to the Services. This means that we determine the purposes and methods of processing personal data about you.

Please take the time to carefully read this Policy to comprehend how we handle your personal data concerning the Services. By utilizing our Services you acknowledge that you have reviewed and comprehended the contents of this Policy.

If you have any inquiries regarding this Policy or our processing of your personal data please refer to Section 19 (assistance and contact information) for guidance on how to contact us.

3. What is Personal Data?

"Personal data" signifies information that identifies pertains to explains is reasonably capable of being linked with or could be reasonably linked directly or indirectly to a specific individual or household. Moreover, we may collect data that does not have the capacity to identify you or is unrelated or unlinked to you in any manner such as de-identified aggregated or anonymized information. Such data does not fall under the category of personal data and its use is not subject to the terms of this Policy.

4. Notifying Us of Changes

Ensuring the accuracy and currency of the personal data we retain about you is vital. Please keep us informed if your personal data undergoes any modifications during your association with us. You can make updates or corrections through your account settings on our Website.

5. Applicability of this Policy (18+)

This Policy is presented as an additional document separate from our Terms of Service (which incorporates our Acceptable Use Policy) governing your utilization of our Website and the Services. Our Services are explicitly designed for individuals aged 18 years or older. Access to the Services is prohibited for anyone under the age of 18. By engaging with the Services you affirm that you are 18 years of age or older.

6. Third-Party Links

Our Website may contain links to websites of third parties as well as plug-ins and applications. Clicking on these links or enabling these connections might permit third parties to collect or share personal data about you. We do not bear responsibility for and this Policy does not encompass the content security or privacy practices of these external websites plug-ins or applications. We encourage you to consult the privacy and cookie policies/notices of these third parties to understand how they may use your personal data.

7. Opting Not to Provide Personal Data

To offer access to the Services or particular features and functionalities within the Services as per our contract with you (i.e. our Terms of Service) we must collect particular personal data from you. In accordance with applicable laws we are also obligated to process certain personal data. Please be aware that if you choose not to provide personal data when requested we may be unable to grant you access to the Services or specific features and functionalities within the Services.

8. Updates to this Policy

We may periodically revise this Policy and such revisions will become effective upon our publication of the updated Policy on our Website. We will exert reasonable efforts to notify you in the event of substantial revisions to this Policy which may include sending you a feed notification or a chat message through your account on our Website.

9. Categories of Personal Data

We or our third-party service providers acting on our behalf process various categories of personal data concerning Creators and Fans. We have categorized this data as follows:

Category of Personal data	Description
User Data	Creators and Content Creators Full name Country of residence Email address Telephone number Third-party social media link such as Instagram Fans Full name Country of residence Email address Telephone number
Third-Party Onboarding Data	Creators Residential address Name A copy of the government identity document Bank information for money withdrawals Phone number Fans Payment card information Name Please refer to Section 10 (our onboarding processes) below for more details. It's important to note that Third-Party Onboarding Data and Technical Data do not include Face Recognition Data as explained further below.
Account Data	Creators Profile name Phone number Email Date of birth Country Password Profile Picture Banner Picture Information related to your subscriptions, subscribers, and referrals Category of Creator Posts you have made to your Creator account Comments on posts made from your Creator account Chat messages exchanged between you and other users Customer support queries submitted to us Fans Profile name Phone number Email Date of birth Country Password Profile Picture Banner Picture Details regarding your subscriptions Comments on posts made from your Fan account Chat messages exchanged between you and other users Customer support queries submitted to us
Financial Data	Creators Currency Payout country
Transaction Data	Creators Earnings Payout requests Payments made to your Creator account Any failed payments Fans Payments made from your Fan account to Creators Any failed payments
Technical Data	Creators and Fans Internet or other electronic network activity information including: Internet Protocol (IP) address (and associated location data) Internet Service Provider (ISP) Name and version of browser
Usage Data	Creators and Fans We utilize cookies when necessary (to enable you to navigate the Services and access specific pages on the Website) and subject to your consent we employ cookies for the following purposes: Performance on the Website (e.g. analyzing user interactions with the Website to enhance the Services and for Creators recognizing referrals made through your unique referral code). Ensuring Website functionality (e.g. maintaining your logged-in status). It's important to highlight that we do not presently employ any cross-site tracking technologies and we neither sell nor share personal data collected about you for cross-context behavioral advertising purposes.

10. Our User Verification Processes

For Creators:

To ensure the integrity of our platform and adhere to legal requirements Snaxx has established stringent verification processes for all Creators on the platform. Before activating a Creator account you will be required to complete the following steps:

Provide Creator User Data: As outlined in Section 9 (categories of personal data) you will need to submit specific personal information.
Residence Verification: We may verify your country of residence to ensure compliance with local laws.
Financial Data: To facilitate payments for your content and earnings access through our platform we will request financial information. This also serves as a verification and anti-fraud measure.
Check for Prior Website Bans: We may confirm that you have not previously been banned from using our platform typically due to violations of our Terms of Service.

For Fans:

To ensure that our platform is utilized by individuals who meet legal age requirements and in some cases to verify their identity Snaxx has established specific verification processes for Fans. Before creating a Fan account you will need to complete the following steps:

Provide Fan User Data: As outlined in Section 9 (categories of personal data) you will need to submit specific personal information.
Financial Data: To enable payments to Creators as well as to implement anti-fraud measures we will request financial information.

11. How and Why Your Personal Data is Used and Legal Bases for Processing

We process personal data based on one or more of the following legal grounds:

Consent: Your consent is specifically sought in certain circumstances.
Performance of a Contract: When you use our Services you enter into a contract with us through our Terms of Service. We process personal data to fulfill the obligations of this contract such as handling transactions between Fans and Creators and managing Creator earnings. We also use this information to enforce the terms of the contract.
Legitimate Interests: We may process personal data if it aligns with our legitimate interests or those of third parties as detailed in the table below. This includes activities like investigating and responding to reports submitted through DMCA takedown procedure to protect Creator intellectual property rights.
Compliance with Legal Obligations: As a global entity we process personal data to comply with applicable laws regulations and rules in the regions where we operate.
Tasks in the Public Interest: We may process personal data when necessary for tasks carried out in the public interest. This includes reporting illegal activities to relevant law enforcement agencies governmental bodies and non-governmental organizations.

We will only utilize your personal data for the purposes for which it was originally collected unless we reasonably determine that another purpose is compatible with the original intent.

Purpose / activity	Lawful basis for processing
Account creation (both Creators and Fans).	Performance of a contract
Creator age and identity verification and where applicable subsequent authentication (specifically in relation to the processing of Face Recognition Data). Please see Section 10 (our onboarding processes) above for further information.	Consent
Government identity document validity check and maintaining a record of the age and identity verification process (for Creators).	Performance of a contract
Providing the Services including the hosting of Creator content the fulfillment of transactions between Fans and Creators and processing Creator earnings.	Performance of a contract
Providing technical support to Fans and Creators.	Performance of a contract
Communicating with you about the Services responding to support requests or sharing information about the Services (e.g. providing you with updates to our Terms of Service or this Policy).	Performance of a contract
Ensuring compliance with and enforcing our Terms of Service and other usage policies (e.g. our Acceptable Use Policy).	Performance of a contract
Moderation and filtration: text and content uploaded to the Website livestreaming on the Website content sent in chat messages on the Website to monitor and investigate violations of our Terms of Service.	Performance of a contract
Filtration of text sent in direct messages on the Website to investigate violations of our Terms of Service.	Performance of a contract
Removal from the Services of text and content uploaded by users that is identified as illegal and suspending or deactivating those user accounts.	Compliance with legal obligations, Performance of a contract
Removal from the Services of text and content uploaded by users that is identified as violating our Terms of Service and where appropriate suspending or deactivating user accounts.	Performance of a contract
Maintaining a record of banned users to prevent further access to the Website.	Legitimate interests
Reporting illegal activity to relevant law enforcement authorities or governmental agencies.	Legitimate interests, Task carried out in the public interest
Preservation and sharing of personal data in the context of legal proceedings (e.g. litigation).	Legitimate interests
Complying with applicable laws, rules and regulations.	Compliance with legal obligations, Legitimate interests
Monitoring transactions and company network systems, applications and data to: detect malicious, deceptive, fraudulent, or illegal activity in order to protect information security and integrity and user safety; and respond to / investigate incidents where appropriate.	Legitimate interests, Task carried out in the public interest
As necessary or appropriate to protect the rights and property of our users, us and other third parties.	Legitimate interests
Data analysis and testing, system maintenance, reporting, and hosting of data to maintain, develop and improve the provision of the Services (e.g. safety, performance and functionality).	Consent (involving Usage Data where this is personal data collected via cookies), Legitimate interests
As necessary in the context of a possible sale, merger, acquisition, business reorganisation or group restructuring exercise.	Legitimate Interests
Processing of personal data in connection with sponsorships and our relationship with service providers, professional advisers and other third parties for business purposes (e.g. business contact information and correspondence).	Performance of a contract, Legitimate Interests

12. Collection of Your Personal Data

We obtain your personal data from the following categories of sources:

Directly from you: When you provide information to us to open an account and utilize our services, update your personal data in your account or engage in correspondence with us (e.g. User Data, Account Data).
Automatically or indirectly from you: For instance, through your use of our services, we collect data such as Transaction Data, Technical Data and Usage Data.
From our service providers: In cases where permitted by applicable law, we receive Third-Party Onboarding Data and specific Technical Data from third-party age and identity verification providers.

13. Disclosure of Your Personal Data

We disclose personal data to the following categories of third parties:

Our third-party service providers: This includes providers of IT, payment processing. The legal basis for sharing personal data with these entities is our legitimate interest in receiving services that support business functionality.
Our professional advisers: This involves legal advisors, bankers, auditors, accountants, consultants and insurers. Our professional advisers process personal data as necessary to provide their services to us and the legal basis for sharing personal data is our legitimate interest in receiving professional services.
Corporate: Relevant third parties in the event of a potential sale, merger, acquisition, business reorganization or group restructuring exercise. The legal basis for sharing personal data with these entities is ours and the relevant third parties' legitimate interests in assessing and implementing potential transactions.
Our group companies: For centralized coordination and management of our business as outlined in Section 9 (categories of personal data). These recipients process personal data in line with this Policy and the legal basis for sharing personal data is our legitimate interest in coordinating the global operations of our business.
Relevant authorities, regulators and organizations: In response to requests from governmental authorities (including law enforcement and tax authorities), regulators and certain non-governmental organizations. These recipients use personal data in the performance of their regulatory, law enforcement or charitable roles. The legal basis for sharing personal data is either the necessity to comply with a legal obligation, our or a third party's legitimate interests, or where it is in the public interest (specifically reporting illegal content to and assisting with requests from such authorities, regulators and organizations to protect the safety of our users and third parties).

14. Transfer of Personal Data Internationally

We share your personal data within our group companies and with our third parties as detailed in Section 13 (disclosure of your personal data). In certain situations this may involve transferring your data outside the UK and the EEA. We make these transfers: (i) to countries deemed to provide an adequate level of protection for personal data; (ii) using appropriate safeguards; or (iii) where otherwise authorized by applicable law.

For further information on the specific mechanism used when transferring your personal data outside the UK and the EEA please contact us using the details provided in Section 19 (assistance and contact information).

15. Your Rights Regarding Personal Data

You have specific rights concerning the collection and processing of personal data and you can exercise these rights by contacting us as detailed in Section 19 (assistance and contact information).

Under certain circumstances and subject to specific exemptions you have the right to:

Withdraw your consent to the processing of your personal data (please note that withdrawing consent does not affect the lawfulness of prior processing).
Request access to your personal data and receive a copy of the information we hold verifying its lawful processing.
Request correction of incomplete or inaccurate personal data.
Request deletion or removal of your personal data where there is no legitimate reason for continued processing.
Request restriction of processing of your personal data such as suspending processing to verify accuracy or reasons for processing.
Request transfer of specific sections of your personal data to another party.

You also have the right to object to processing of your personal data when relying on a legitimate interest provided there are grounds specific to your situation. We do not engage in solely automated decision-making with legal or similarly significant effects on you.

You also have the right to file a complaint with a data protection regulator such as the Information Commissioner's Office (ICO) in the UK or your local country/state-specific data protection regulator if you reside in the EEA. Depending on your location to not face retaliatory or discriminatory treatment in connection with exercising your rights or to appeal decisions related to privacy rights requests. All appeal requests should be submitted using the contact details in Section 19.

16. Exercising Your Rights

To exercise your rights outlined in Section 15 (your rights regarding personal data) contact us using the details provided in Section 19 (assistance and contact information). When making the request yourself ensure it contains enough information for us to confirm your identity and comprehend, evaluate and respond appropriately. We may request additional personal data to verify your identity considering our relationship with you and the sensitivity of the request. In certain situations we may decline a privacy rights request if unable to verify your identity. If a third party authorized by you submits the request we will need proof of their authority to do so (e.g. a signed document).

17. Choices and Control Over Your Personal Data

Modifying and deleting your personal data: If you have an account with us you can update your account settings on our Website. Note that changes may take time to take effect.

Email notification opt-out: Opt-out of certain email communications by clicking the associated links at the bottom of our emails or by contacting us as described in Section 19. Please include "E-mail notification opt-out" in the email's subject line with your name and account email address in the body. Note that you cannot opt-out of essential automated email notifications required by law or for service provision.

18. Storage Duration of Personal Data

We will retain your personal data only for the period reasonably necessary to fulfill the purposes outlined in this Policy. In general we hold personal data for a duration of 6 months following the deletion or deactivation of your account on the Website.

Important points to note:

We may delete your personal data earlier if a shorter retention period is mandated by applicable law.
Extended retention may occur if necessary for processing activities specified in this Policy such as:

Compliance with relevant laws and regulatory obligations applicable to us. This may include adhering to record-keeping/maintenance requirements in specific jurisdictions and fulfilling financial/tax reporting obligations which in some instances span up to 10 years. Additionally if we receive a valid legal request such as a preservation order or search warrant related to your account your personal data may be retained.
Identification and reporting of illegal activity safeguarding the safety of our users and third parties or protecting the rights and property of users, us and other third parties. This includes situations where a user has or we reasonably believe a user has violated our Terms of Service leading to a ban on further access to the Website.
Legal proceedings such as defense in litigation related to a claim involving you.
Response to requests from third parties concerning your account including those from law enforcement authorities, governmental bodies (e.g. tax and regulatory authorities) and non-governmental organizations.

The determination of the personal data retained and the duration of retention will be made on a case-by-case basis taking into account specific circumstances.

19. Assistance and Contact Information

For inquiries about this Policy or the processing of your personal data please submit a ticket through your account or contact us via email at [email protected]. Alternatively once you are logged into your Snaxx account you can also reach out to us by navigating to the Account section and clicking on "Contact Us." This action will directly send your request to our team.

20. Supplementary U.S. State Privacy Disclosures

For residents of California, Colorado, Connecticut, Nevada, Utah and Virginia the following additional U.S. State Privacy Disclosures ("U.S. Disclosures") provide further insights into our personal data processing practices concerning individual residents of these states. These U.S. Disclosures complement the information presented in the Policy and unless explicitly stated otherwise the terms defined in this Policy maintain their meanings in these U.S. Disclosures.

Sensitive Information

While sensitive information may be disclosed for a business purpose as detailed below it's essential to note that we do not sell or share sensitive information for targeted advertising purposes. The following personal data elements collected by us or our service providers may fall under the category of "sensitive" according to certain privacy laws ("sensitive information"):

Password
Social security number, driver's license number, and passport number
Government identifiers (e.g. driver's license numbers)
Partial payment card number and the name registered with your payment card

We utilize this sensitive information for the purposes outlined in Section 11 (how/why we use your personal data and lawful bases for processing). This includes operations essential for our Services, fulfilling contractual obligations, complying with legal and regulatory requirements, ensuring the safety of our users and third parties or as otherwise permissible for our internal purposes in accordance with applicable laws.

Deidentified Information

On occasion we may receive or process personal data to generate deidentified information that no longer reasonably links to or infers information about a specific individual or household. In cases where we maintain deidentified information we handle and use the information in its deidentified form. We refrain from attempting to reidentify the information except when required or permitted by applicable law.

Minors

Our Services are exclusively intended for individuals aged 18 or older. Individuals under the age of 18 are prohibited from using the Services. By utilizing the Services you affirm that you are 18 years of age or older.

California Specific Disclosures

The following disclosures specifically apply to residents of the State of California:

Personal Data Collection

California law necessitates disclosures about the personal data we collect categorized according to California law. To fulfill this requirement we've identified the pertinent California personal data categories detailed in Section 9 (categories of personal data):

Identifiers: Such as name, address, phone number, email, passport, government identity information, account details or similar identifiers.
Customer Records: Including driver's license number, passport number, partial debit/credit card information, and financial information.
Protected Classification Characteristics: Such as age, date of birth, and gender.
Commercial Information: Details about purchased products, service usage.
Internet/Network Information: Device information, log data, analytics data.
Sensory Information: Pictures and videos uploaded to the Website.
Other Personal Data: Communication preferences, customer service history, social media interactions, and messages sent through Services.
Inferences: Information generated from your Service use.

We may disclose these categories for business purposes to service providers or other third parties as outlined in this Policy.

Disclosure of Personal Data

As described in Section 13 (sharing your personal data) we may disclose the identified personal data categories to third parties for various business purposes including our group and affiliated companies, service providers, professional advisers, business partners, and other businesses for Services provision. Disclosure may occur with your consent, in corporate transactions or as required by law.

Sources of Personal Data

We collect personal data directly from you, your browser or device interactions with our Services and from business partners, affiliates, third parties you authorize to share information, and other providers. Refer to Section 12 (obtaining your personal data) for more details.

Purpose for Collection

Personal data is collected for purposes outlined in Section 11 (how/why we use your personal data and lawful bases for processing).

Notice of Financial Incentives

Currently, we don't use cross-site tracking technologies, sell collected personal data or share data for cross-context behavioral advertising. We don't engage in direct marketing emails. Our referral program, subject to our Terms of Service, involves referral payments to existing Creators who introduce new Creators to the Website. Personal data associated with this program is processed in accordance with this Policy.

You have the right to exercise your rights concerning your personal data as detailed in this Policy. If applicable, you can do so by submitting a ticket through your account or by sending an email to [email protected].