Data Privacy Data privacy matters to Snibble Corp. (“Snibble” or “us” or “we”), because its founders believe that the current large digital platforms have abused their market positions and not protected data from consumers, advertisers and content providers. We aim to set a better standard of data privacy because of Snibble’s fundamental belief that digital should and can be better. This policy applies to users of Snibble’s services anywhere in the world, including users of Snibble’s apps, websites, features or other services. This policy describes how Snibble and its affiliates collect and use personal information to provide our services. This policy applies to all users of our apps, websites, features or other services anywhere in the world, unless covered by a separate privacy policy. The practices described in this policy are subject to applicable laws in the places in which we operate. This means that we only engage in the practices described in this policy in a particular country or region if permitted under the laws of those places. Please contact us if you have questions on our practices in your country or region. We encourage our end users to read this privacy policy carefully and to contact us through with any questions or concerns about our privacy policies. Collection and Use of Personal Information Personal information is data that can be used to identify or contact a single person. You may be asked to provide your personal information anytime you are in contact with Snibble or one of its affiliates. Snibble and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have. Here are some examples of the types of personal information Snibble may collect and how we may use it: ● When you create or update a Snibble account, download our application or software update, purchase a product, connect to our services, contact us or participate in an online survey or quiz, contact us for points or a reward, we may collect a variety of data and information, including your name, mailing address, phone number, email address, contact preferences, login name and password, demographic information, banking information, device identifiers, phone number, IP address, location information, and credit card information. ● When you share your content with family and friends using Snibble, send gift certificates and products, or invite others to participate in Snibble services or forums, Snibble may collect the information you provide about those people such as name, mailing address, email address, and phone number. Snibble will use such information to fulfill your requests, provide the relevant product or service, provide rewards, or for anti-fraud purposes. ● In certain jurisdictions, we may ask for a government issued identification (ID) in limited circumstances including when setting up a Snibble account and activating your Snibble app, for the purpose of extending commercial credit, managing reservations, or as required by law. How we use your personal information We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which Snibble is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Snibble or a third party to whom it may be necessary to disclose information. ● The personal information we collect allows us to keep you posted on Snibble’s latest content, product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences. ● We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, provide rewards, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for antifraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources. ● We may use your personal information, including date of birth, telephone number, security questions, etc., to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Snibble account holders. ● From time to time, we may use your personal information to send updates, important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your continued interaction with Snibble, you may not opt out of receiving these communications. ● We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Snibble’s products, services, and customer communications. ● If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs. Source of your personal information where they are not collected from you We may have received your personal information from other persons if that person has shared their content with you using Snibble products or services, sent gift certificates and products, or invited you to participate in Snibble services or forums. We may also validate the information provided by you when creating a Snibble account with a third party for security and fraud prevention purposes. For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein. Collection and Use of Non-Personal Information We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it: ● We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where a Snibble product is used so that we can better understand customer behavior and improve our products, services, and advertising. ● We may collect information regarding customer activities on our Snibble application, website, and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy. ● We may collect and store details of how you use our products and services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure the quality of our services over the Internet, such information will not be associated with your IP address. ● With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps. If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined. Cookies and Other Technologies Snibble’s websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our applications and websites people have visited, and facilitate and measure the effectiveness of specific content, advertisements and web searches. We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy. Ads that are delivered by Snibble’s advertising platform may appear in Apple News and in the App Store and Google Play Store. In general, Snibble provides non-skippable ads as a “Fair trade” in exchange for your attention. Use of the Snibble mobile app requires you to receive ads that target your interests from Snibble’s advertising platform. Snibble and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Snibble more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit Snibble. Knowing your country and language helps us provide a customized and more useful viewing experience. Knowing someone using your phone, computer or device has shopped for a certain video or product or used a particular service helps us make our advertising and email communications more relevant to your interests. It also helps ensure that we do not show ads not related to your interests. In addition, knowing your contact information, hardware identifiers, and information about your phone, device or computer, helps provide you with better customer service. As is true of most internet services, we gather some types of information automatically and store it in log files. This information includes IP addresses, mobile phone type, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the application and websites, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Snibble may use this information in our marketing and advertising services. In some of our email messages, we use a “click-through URL” linked to content on the Snibble website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers. Disclosure to Third Parties At times Snibble may make certain personal information available to strategic partners that work with Snibble to provide products and services, or that help Snibble market to customers. For example, when you purchase and activate the Snibble app on your device you may authorize Snibble and your carrier to exchange the information you provide during the activation process to carry out a service. One example of this would be to purchase a product online. If you are approved for service, your account will be governed by Snibble and your carrier’s respective privacy policies. Personal information will only be shared by Snibble to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes. Service Providers Snibble shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Snibble operates. Others It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Snibble to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party. Protection of Personal Information Snibble takes the security of your personal information very seriously. All our services are designed to protect your personal information at rest and during transit using encryption. When your personal data is stored by Snibble, we use computer systems with limited access housed in facilities using physical security measures. When you use Snibble’s products, services, or applications or post on a Snibble forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features. If you or anyone else using Snibble to share information on to a device that is owned by a third party, any information shared within your family and friends—including calendar, location, videos etc. —may be downloaded on to that third-party device thereby disclosing any such shared information. The existence of Automated Decision-Making, Artificial intelligence, Including Profiling Snibble will use your preferences and viewing history as well as the histories of other users only to help serve up content and/or advertising that is relevant to you. Integrity and Retention of Personal Information Snibble makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law. Access to Personal Information You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your Snibble ID account pages. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if Snibble is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Online tools for the exercise of access, correction, or deletion requests are available on a regional basis by writing to us. Children & Education We understand the importance of taking extra precautions to protect the privacy and safety of children using Snibble products and services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own Snibble ID. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with their child’s Snibble ID, they may contact us through one of the options provided at the bottom of this page. Location-Based Services To provide location-based services on Snibble products, Snibble and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your device and Snibble app or computer. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Snibble and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services. The location-based services offered by Snibble, are designed to provide you with the best possible viewing experience. Third-Party Sites and Services Snibble applications, websites, products, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties − for example, from our advertising or content partners. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties. International Users and data storage All the data and information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Personal information, relating to Snibble services, regarding individuals who reside in a member state of the European Economic Area and Switzerland is controlled by Snibble in Canada and subject to the laws of this country. Snibble abides by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure the protection of personal information transferred among participating APEC economies. To learn more about the APEC Certification and Dispute Resolution, please click on the TRUSTe seal. How we secure Data and Information All Snibble products are built with security features that continuously protect your information. The features help us detect and automatically block security threats from ever reaching you. If Snibble detects something risky that we think you should know about, we’ll notify you and help guide you through steps to stay better protected. Snibble works hard to protect you from unauthorized access, alteration, disclosure, or destruction of information we hold, including: ● We use encryption to keep your data private while in transit; ● We offer a range of security features to help you protect your account; ● We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our system; and ● We restrict access to personal information to employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. What are the end-user data protection rights? Snibble wants to ensure that all of our end-users are fully aware of their data protection rights. As such, every user is given the following rights: 1. The Right to Access - end users have the right to require that Snibble provide copies of their personal data. Snibble reserves the right to charge a small fee for providing this service. 2. The Right to Rectification - end users have the right to request that Snibble correct any information that is not seen to be accurate. As well, end users have the right to request Snibble to complete information they believe to be incomplete. 3. The Right to be Forgotten - end users have the right to request that Snibble erase all personal data. Again Snibble reserves the right to charge a small fee for providing this service. 4. The Right to Restrict Processing - end users have the right to request that Snibble restrict the processing of personal data. 5. The Right to Object to Processing - end users have the right to object to Snibble processing data. 6. The Right to Data Portability - end users have the right to request that Snibble transfer the data that we have collected to another organization, or directly to the end user, under certain conditions. Snibble reserves the right to charge a fee for this service. How long do we keep personal data Snibble requires user profile information in order to provide its services, and retains such information for as long as you maintain your Snibble account. Snibble retains certain information, including transaction, location, device and usage information for a minimum of 7 years in connection with regulatory, tax, insurance and other requirements in the places in which it operates. Once such information is no longer necessary to provide Snibble’s services, enable customer support, enhance the user experience or other operational purposes, Snibble takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection. You may request deletion of your account at any time through the Privacy Settings in the Snibble app, or via Snibble’s website. Following such request, Snibble deletes the information that it is not required to retain. In certain circumstances, Snibble may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Snibble will delete your account as described above. Snibble may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, if Snibble shuts down a user's account because of unsafe behavior or security incidents, Snibble may retain certain information about that account to prevent that user from opening a new Snibble account in the future. Our Company wide Commitment to Your Privacy To make sure your personal information is secure, we communicate our privacy and security guidelines to Snibble employees and partners and strictly enforce privacy safeguards within the company. Privacy Questions If you have any questions or concerns about Snibble’s Privacy Policy or data processing, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at the numbers listed on our website When a privacy question or question about personal information received in response to an access/download request is received we have a dedicated team which triages the contacts and seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances. Snibble may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. Snibble Corp. 80 Sherbourne Avenue, Unit 101, Toronto, Ontario, Canada M5A 2R1.