5. DO WE USE
COOKIES AND
OTHER TRACKING
TECHNOLOGIES?
In Short: We may use
cookies and other
tracking technologies to
collect and store your
information.
We may use cookies and
similar tracking
technologies (like web
beacons and pixels) to
gather information when
you interact with our
Services. Some online
tracking technologies help
us maintain the security
of our Services , prevent crashes, fix bugs,
save your preferences, and
assist with basic site functions.
We also permit third
parties and service
providers to use online
tracking technologies on
our Services for analytics
and advertising, including
to help manage and display
advertisements, to tailor
advertisements to your
interests, or to send
abandoned shopping cart
reminders (depending on
your communication
preferences). The third
parties and service
providers use their
technology to provide
advertising about products
and services tailored to
your interests which may
appear either on our
Services or on other
websites.
To the extent these online
tracking technologies are
deemed to be a "sale"/"sharing" (which includes targeted advertising,
as defined under the applicable
laws) under applicable US state
laws, you can opt out of these
online tracking technologies
by submitting a request as described
below under section " DO UNITED STATES
RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS? "
Specific information
about how we use such
technologies and how you
can refuse certain cookies
is set out in our Cookie
Notice: __________ . Google Analytics
We may share your
information with Google
Analytics to track and analyze the use of the Services. To opt out of being tracked by
Google Analytics across the Services,
visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy
practices of Google, please visit
the Google Privacy &
Terms page.
6. HOW LONG DO
WE KEEP YOUR
INFORMATION?
In Short: We keep your
information for as long
as necessary to fulfill the purposes outlined in
this Privacy Notice unless
otherwise required by law.
We will only keep your
personal information for
as long as it is necessary
for the purposes set out
in this Privacy Notice,
unless a longer retention
period is required or
permitted by law (such as
tax, accounting, or other
legal requirements).
When we have no ongoing
legitimate business need
to process your personal
information, we will
either delete or anonymize such information, or, if this
is not possible (for example,
because your personal information
has been stored in backup archives),
then we will securely store
your personal information and
isolate it from any further
processing until deletion is
possible.
7. HOW DO WE
KEEP YOUR
INFORMATION
SAFE?
In Short: We aim to protect your
personal information
through a system of organizational and technical security measures.
We have implemented
appropriate and reasonable
technical and organizational security measures designed
to protect the security of
any personal information we
process. However, despite our
safeguards and efforts to secure
your information, no electronic
transmission over the Internet
or information storage technology
can be guaranteed to be 100%
secure, so we cannot promise
or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able
to defeat our security and
improperly collect, access,
steal, or modify your information.
Although we will do our best
to protect your personal information,
transmission of personal information
to and from our Services is
at your own risk. You should
only access the Services within
a secure environment.
8. DO WE COLLECT
INFORMATION FROM
MINORS?
In Short: We do not
knowingly collect data
from or market to children under 18 years of
age .
We do not knowingly
collect, solicit data
from, or market to
children under 18 years of
age, nor do we knowingly
sell such personal
information. By using the
Services, you represent
that you are at least 18
or that you are the parent
or guardian of such a
minor and consent to such
minor dependent’s use of
the Services. If we learn
that personal information
from users less than 18
years of age has been
collected, we will
deactivate the account and
take reasonable measures
to promptly delete such
data from our records. If
you become aware of any
data we may have collected
from children under age
18, please contact us at [email protected] .
9. WHAT ARE YOUR
PRIVACY RIGHTS?
In Short: Depending on your state of
residence in the US or in some regions, such as the European Economic Area
(EEA), United Kingdom (UK),
Switzerland, and Canada , you have rights that allow
you greater access to and
control over your personal
information. You may review, change,
or terminate your
account at any time,
depending on your
country, province, or
state of residence.
In some regions (like the EEA, UK, Switzerland, and
Canada ), you have certain rights
under applicable data protection
laws. These may include the
right (i) to request access
and obtain a copy of your personal
information, (ii) to request
rectification or erasure; (iii)
to restrict the processing
of your personal information;
(iv) if applicable, to data
portability; and (v) not to
be subject to automated decision-making.
In certain circumstances, you
may also have the right to
object to the processing of
your personal information.
You can make such a request
by contacting us by using the
contact details provided in
the section " HOW CAN YOU CONTACT US
ABOUT THIS NOTICE? " below.
We will consider and act
upon any request in
accordance with applicable
data protection laws.
Withdrawing your
consent: If we are relying on your consent
to process your personal information, which may be express and/or
implied consent depending on
the applicable law, you have the right to withdraw
your consent at any time. You
can withdraw your consent at
any time by contacting us by
using the contact details provided
in the section " HOW CAN YOU CONTACT US
ABOUT THIS NOTICE? " below .
However, please note that
this will not affect the
lawfulness of the processing
before its withdrawal nor, when applicable law allows, will it affect the processing
of your personal information
conducted in reliance on lawful
processing grounds other than
consent.
Opting out of marketing
and promotional
communications: You
can unsubscribe from our
marketing and promotional
communications at any time
by clicking on the unsubscribe link
in the emails that we send, or by contacting us using the
details provided in the section " HOW CAN YOU CONTACT US
ABOUT THIS NOTICE? " below. You will then be removed
from the marketing lists. However,
we may still communicate with
you — for example, to send you
service-related messages that
are necessary for the administration
and use of your account, to respond
to service requests, or for other
non-marketing purposes.
Cookies and similar
technologies: Most Web browsers are set to
accept cookies by default.
If you prefer, you can usually
choose to set your browser
to remove cookies and to reject
cookies. If you choose to remove
cookies or reject cookies,
this could affect certain features
or services of our Services. For further
information, please see
our Cookie Notice: __________.
If you have questions or
comments about your privacy
rights, you may email us at [email protected] .
10. CONTROLS FOR
DO-NOT-TRACK
FEATURES
Most web browsers and
some mobile operating
systems and mobile
applications include a
Do-Not-Track ( "DNT" ) feature or setting you can
activate to signal your privacy
preference not to have data
about your online browsing
activities monitored and collected.
At this stage, no uniform technology
standard for recognizing and implementing DNT signals
has been finalized . As such, we do not currently
respond to DNT browser signals
or any other mechanism that
automatically communicates
your choice not to be tracked
online. If a standard for online
tracking is adopted that we
must follow in the future,
we will inform you about that
practice in a revised version
of this Privacy Notice.
California law requires us
to let you know how we
respond to web browser DNT
signals. Because there
currently is not an industry
or legal standard for recognizing or honoring DNT signals, we do not respond
to them at this time.
11. DO UNITED
STATES RESIDENTS
HAVE SPECIFIC
PRIVACY RIGHTS?
In Short: If you are a resident
of California, Colorado, Connecticut,
Delaware, Florida, Indiana,
Iowa, Kentucky, Minnesota,
Montana, Nebraska, New Hampshire,
New Jersey, Oregon, Tennessee,
Texas, Utah, or Virginia , you may have the right
to request access to and
receive details about the
personal information we maintain
about you and how we have
processed it, correct inaccuracies,
get a copy of, or delete
your personal information.
You may also have the right
to withdraw your consent
to our processing of your
personal information. These
rights may be limited in
some circumstances by applicable
law. More information is
provided below.Categories of Personal
Information We Collect
We have collected the
following categories of
personal information in
the past twelve (12)
months:
| Category | Examples | Collected |
A. Identifiers | Contact details,
such as real name,
alias, postal
address, telephone
or mobile contact
number, unique
personal
identifier, online
identifier,
Internet Protocol
address, email
address, and
account name |
NO
|
B. Personal
information as
defined in the
California
Customer Records
statute | Name, contact
information,
education,
employment,
employment
history, and
financial
information |
NO
|
C . Protected classification
characteristics under
state or federal law | Gender, age, date
of birth, race and
ethnicity,
national origin,
marital status,
and other
demographic data |
NO
|
D . Commercial information | Transaction
information,
purchase history,
financial details,
and payment
information |
NO
|
E . Biometric information | Fingerprints and
voiceprints |
NO
|
F . Internet or other
similar network activity | Browsing history,
search history,
online behavior , interest data, and
interactions with our
and other websites,
applications, systems,
and advertisements |
NO
|
G . Geolocation data | Device location |
NO
|
H . Audio, electronic,
sensory, or similar
information | Images and audio,
video or call
recordings created
in connection with
our business
activities |
NO
|
I . Professional or employment-related
information | Business contact
details in order
to provide you our
Services at a
business level or
job title, work
history, and
professional
qualifications if
you apply for a
job with us |
NO
|
J . Education Information | Student records
and directory
information |
NO
|
K . Inferences drawn
from collected personal
information | Inferences drawn
from any of the
collected personal
information listed
above to create a
profile or summary
about, for
example, an
individual’s
preferences and
characteristics |
NO
|
| L . Sensitive personal Information | |
NO
|
We may also collect other
personal information outside
of these categories through
instances where you interact
with us in person, online,
or by phone or mail in the
context of:
- Receiving help through our
customer support channels;
- Participation in customer
surveys or contests; and
- Facilitation in the
delivery of our Services and
to respond to your
inquiries.
Will your information
be shared with anyone
else?
We may use your
personal information for
our own business
purposes, such as for
undertaking internal
research for
technological
development and
demonstration. This is
not considered to be "selling" of your personal information.
We have not disclosed,
sold, or shared any
personal information to
third parties for a
business or commercial
purpose in the preceding
twelve (12) months. We will not sell or share
personal information in
the future belonging to
website visitors, users,
and other consumers. Your Rights
You have rights under
certain US state data
protection laws. However,
these rights are not
absolute, and in certain
cases, we may decline your
request as permitted by
law. These rights include:
- Right to know whether or not we are processing
your personal data
- Right to access your personal data
- Right to correct inaccuracies in your
personal data
- Right to request the deletion of your personal
data
- Right to obtain a
copy of the personal data you
previously shared with us
- Right to
non-discrimination for exercising your rights
- Right to opt out of the processing of your personal
data if it is used for targeted
advertising (or sharing as defined under
California’s privacy law) , the sale of personal data,
or profiling in furtherance
of decisions that produce legal
or similarly significant effects
( "profiling" )
Depending upon the state
where you live, you may
also have the following
rights:
- Right to access the
categories of personal
data being processed (as
permitted by applicable
law, including Minnesota’s
privacy law)
- Right to obtain a list of
the categories of third
parties to which we have
disclosed personal data
(as permitted by
applicable law, including California's and Delaware's privacy law)
- Right to obtain a list of
specific third parties to
which we have disclosed
personal data (as
permitted by applicable
law, including Minnesota's and Oregon's privacy law)
- Right to review,
understand, question, and
correct how personal data
has been profiled (as
permitted by applicable
law, including Minnesota’s
privacy law)
- Right to limit use and
disclosure of sensitive
personal data (as
permitted by applicable
law, including
California’s privacy law)
- Right to opt out of the
collection of sensitive
data and personal data
collected through the
operation of a voice or
facial recognition feature
(as permitted by
applicable law, including
Florida’s privacy law)
How to Exercise Your
Rights
To exercise these
rights, you can contact
us by submitting a data subject access
request, by emailing us at [email protected] , or by referring to the
contact details at the
bottom of this document.
Under certain US state
data protection laws, you
can designate an authorized agent to make a request on
your behalf. We may deny a
request from an authorized agent that does not submit
proof that they have been validly authorized to act on your behalf in accordance
with applicable laws.
Request Verification
Upon receiving your
request, we will need to
verify your identity to
determine you are the same
person about whom we have
the information in our
system. We will only use
personal information
provided in your request
to verify your identity or
authority to make the
request. However, if we
cannot verify your
identity from the
information already
maintained by us, we may
request that you provide
additional information for
the purposes of verifying
your identity and for
security or
fraud-prevention purposes.
If you submit the request
through an authorized agent, we may need to collect
additional information to verify
your identity before processing
your request and the agent
will need to provide a written
and signed permission from
you to submit such request
on your behalf. Appeals
Under certain US state
data protection laws, if
we decline to take action
regarding your request,
you may appeal our
decision by emailing us at __________ . We will inform you in writing
of any action taken or not
taken in response to the appeal,
including a written explanation
of the reasons for the decisions.
If your appeal is denied, you
may submit a complaint to your
state attorney general. California "Shine The Light" Law
California Civil Code
Section 1798.83, also
known as the "Shine The Light" law, permits our users who
are California residents to
request and obtain from us,
once a year and free of charge,
information about categories
of personal information (if
any) we disclosed to third
parties for direct marketing
purposes and the names and
addresses of all third parties
with which we shared personal
information in the immediately
preceding calendar year. If
you are a California resident
and would like to make such
a request, please submit your
request in writing to us by
using the contact details provided
in the section " HOW CAN YOU CONTACT US
ABOUT THIS NOTICE? "
12. DO WE MAKE
UPDATES TO
THIS NOTICE?
In Short: Yes, we will update
this notice as
necessary to stay
compliant with
relevant laws.
We may update this
Privacy Notice from time
to time. The updated
version will be
indicated by an updated "Revised" date at the top of this Privacy
Notice. If we make material
changes to this Privacy Notice,
we may notify you either
by prominently posting a
notice of such changes or
by directly sending you a
notification. We encourage
you to review this Privacy
Notice frequently to be informed
of how we are protecting
your information.
SNAP Editions,
LLC
27 E 95th St, New York,
NY 10128, USA
New York , NY 10128
United States
14. HOW CAN
YOU REVIEW,
UPDATE, OR
DELETE THE
DATA WE
COLLECT FROM
YOU?
Based on the applicable laws
of your country or state of residence in
the US , you may have the right to
request access to
the personal
information we
collect from you,
details about how we
have processed it,
correct
inaccuracies, or
delete your personal
information. You may
also have the right
to withdraw your consent
to our processing of
your personal information.
These rights may be limited
in some circumstances
by applicable law. To
request to review, update,
or delete your personal
information, please fill out and submit a data subject
access request .