Updated: Aug. 19th, 2022

 

This privacy policy “Privacy Policy” contains important information regarding SNOW Corp. (“SNOW,” “us,” “our,” or “we”), and how and why we collect, store, use, and share your personal information.  It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

Please read this Privacy Policy carefully before using SNOW’s VITA mobile application and related services, VITA website, and all publicly available websites and subdomains provided by us on which a link to this Privacy Policy is displayed (collectively or individually referred to as the “Application”).  By using the Application, you consent to the collection, transfer, process, storage, disclosure, and use of your information as described in this Privacy Policy.  If you do not agree with this Privacy Policy, then please do not use the Application.

This Privacy Policy may change from time to time.  Your continued use of the Application after we revise this Privacy Policy means you accept those changes, so please check the Privacy Policy periodically for updates.

 

1. SCOPE OF PRIVACY POLICY

This Privacy Policy is part of the Terms of Service for the Application and includes any separate privacy notices and/or notices posted on particular pages of the Application that may provide more detail regarding the information we collect on those pages, why we need that information, and choices you may have about the ways we use that information.  No matter where your information is collected, used, transferred or stored, if it was collected through the Application, it will be subject to the terms of this Privacy Policy.

 

2. INFORMATION WE COLLECT

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer:

Information You Provide To Us Directly

When you download, register with, or use this Application, we may ask that you provide:

Information We Collect from Your Use of the Application

When you use the Application, it may use technology to automatically collect:

We use third-party analytics tools to help us measure traffic and usage trends for the Application.  These tools collect information sent by your device to our Application, including the content and ads that you view or click, and other information that assists us in improving the Application.  We collect and use this analytics information in the aggregate with analytics information from other users so that it cannot reasonably be used to identify any particular individual user.

Upon your consent, we may collect different types of information about your general location (e.g., IP address, zip code) or more specific location information (e.g., precise location from your mobile GPS) through methods such as mobile “SDKs” which allows us to periodically determine your location, including your location relative to and within third-party merchant locations, and share such information with third parties, for purposes related to advertising (e.g., customized ads in the Application), analytics, attribution (e.g., measuring ad performance), and research.  You may prevent location information from being collected by this or other apps through your device settings (but this may affect the functionality of certain Application features).  We may collect this information when the Application runs in the background on your device.

When you use the Application, we allow third-party companies to collect certain information.  These companies may utilize cookies, pixels, or other similar technologies to collect and use non-personally identifiable information in order to provide advertisements about goods and services likely to be of greater interest to you.  To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info and Networking Advertising Initiative at www.networkadvertising.org/choices/.

When you use the Application, we may automatically collect and store certain information in server logs.  This may include:

- Information on how you interact with the Application.

- Your IP address.

- Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.

We may collect device and usage information such as:

- Mobile ad identifiers such as iOS Identifier for Advertising(IDFA) and Android Advertising ID(AAID)

- Other information about a user’s device, such as: device type (e.g., tablet, smartphone), operating system, IP address, network provider, mobile carrier, mobile browser type (e.g., Firefox, Chrome, Safari), other apps and SDKs installed on the device, timestamp, time zone, information about the speed, bearing, orientation, and altitude of a device, or other device-identifying information.

- Information about the possible relationships among different devices.

- Data about user activities (e.g., the pages you view, the time and duration of your activities in the App) that helps us determine how a user interacts with advertising or content, such as determining whether a user who viewed a particular advertisement ultimately purchased the advertised product or service.

We may collect this information when the Application runs in the background on your device.

If you do not want this information to be linked to your device, you may go to your device settings (which are somewhat different for iOS and Android devices) and opt out of interest-based or personalized advertising Click here for more information 

- We may access metadata and other information associated with other files stored on your device.  This may include, for example, photographs and contacts for the purpose of inviting friends to use the Application.

SNOW may use Apple’s TrueDepth camera to collect additional information from your device’s camera in order to deliver and improve features provided by VITA (such as photo, video, effects, and more).  The use of such information, to the extent including facial geometry information, is governed by the Face Recognition terms set forth above.

Information Collection and Tracking Technologies

 

3. HOW WE USE YOUR INFORMATION

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive and the choices you make in your settings:

4. INFORMATION SHARING AND DISCLOSURE TO THIRD PARTIES

Third-Party Service Providers

We use a variety of third-party service providers to help us provide the Application including business analytics, marketing, and other services.  These providers have limited access to your information, including in some instances User Content, to perform these tasks on our behalf and are contractually obligated to use it consistent with this Privacy Policy.

Third-Party Advertising Network

We may share or disclose non-personally identifiable information, aggregated, usage information, geolocation information or device-level information (such as anonymous usage data, platform types, number of clicks, location data, etc.) with unaffiliated partners and third parties (e.g., advertising networks) that wish to market products.  You can control or disable the use of location services for the Application in the device’s settings menu.  See Section 6 “Your Choices About Your Information” of this Privacy Policy for further instructions.

Professionals and Other Users

Any information that you provide to other users via the Application are shared and disclosed to them.  By sending your information to other users, you acknowledge and agree that they may contact you via the Application.

Business Transfers and Affiliates

We may share your information with companies or organizations connected or affiliated with SNOW.  We may also transfer your information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of SNOW’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

Legal Disclosures

Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property.  However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

 

5. PERSONAL INFORMATION WE SOLD OR DISCLOSED FOR A BUSINESS PURPOSE

In the preceding 12 months, we have sold or disclosed to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer:

 

6. YOUR CHOICES ABOUT YOUR INFORMATION

Promotional Communications

You may opt out of receiving promotional communications from us by following the instructions in those messages.  If you opt out, please note that we may still send you Application-related communications, such as those about your account or our ongoing business relations.

Opting Out of Interest-Based Advertising Services

You may opt-out from any interest-based advertising by turning on “Limit Ad Tracking” in your device settings.

To limit Ad Track on an Apple device, see instructions at: https://support.apple.com/en-us/HT202074

To limit Ad Tracking on an Android device, see instructions at: https://support.google.com/ads/answer/2662922

Please note that opting-out will not block general advertisements that are sent at random and not tied to your perceived interest.

You may learn more about personalized and behavioral advertising and how to opt out of this type of advertising from the Digital Advertising Alliance at www.aboutads.info and Networking Advertising Initiative at www.networkadvertising.org/choices/.

Push Notifications

We may send push notifications to your device.  You can deactivate these messages at any time by changing the notification settings within the Application or your device settings.

Content information

You may directly edit or delete content that you created while using the service via the following methods.

If you need to delete your created content, please contact us via dl_vita_support@snowcorp.com with the content you wish to delete and the reason, and we will help you with the process after confirming your identity.

Deletion requests may be sent by creators themselves or through a legal representative.  If the representative sends the request, the company may request the submission of a letter of attorney to confirm the legitimacy of the representative.

Deletion requests may be denied if the requesting person is not the creator themselves (or a legal representative) or if the content must be preserved according to the law (in our sole discretion).

7. HOW LONG WE KEEP YOUR INFORMATION

The Company may process and retain your personal information for the period necessary to get consent from you or to accomplish the purpose of the task specified in the Terms and Conditions and Privacy Policy.

If the period specified below expires, all information, including personal information, will be deleted.

However, in any of the following events, the information may be stored until the relevant issues are resolved.

 

8. CHILDREN’S PRIVACY

This Application is not intended for children under 16 years of age.  We do not knowingly collect or solicit any information from anyone under the age of 16 or knowingly allow such persons to register for the Application.  If you believe that we might have any information from or about a child under 16, please contact us at sn_service_privacy@snowcorp.com

 

9. TRANSFERRING YOUR DATA

Your information collected through the Application may be stored and processed in the United States or any other country in which SNOW, its affiliates or service providers maintain facilities.  As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions (including the United States) that may not provide equivalent levels of data protection as your home jurisdiction.

By registering for and using the Application, you consent to the transfer of information to the United States or to any other country in which SNOW, its affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

 

 

10. SECURITY

VITA cannot fully ensure the security of any information you transmit to the VITA Application or guarantee that information on the Application may not be accessed, disclosed, altered, or destroyed.  You are responsible for maintaining the secrecy of your unique password and account information at all times.  Your privacy settings may also be affected by changes that the social media services you connect to SNOW make to their services.  We are not responsible for the functionality, privacy, or security measures of any other organization.

 

 

11. EXTERNAL LINKS

The Application may contain links to third-party sites or online services.  We are not responsible for the practices of such third parties, whose information practices are subject to their own policies and procedures, not to this Privacy Policy.

 

 

12. CALIFORNIA CONSUMER PRIVACY RIGHTS

If you are a California resident, you have rights under the California Consumer Privacy Act of 2018 (CCPA), as applicable, to exercise free of charge. 

Click here for more information.

 

13. DO NOT TRACK

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties.  We do not currently respond to DNT signals.

 

 

14. CHANGES TO OUR PRIVACY POLICY

VITA may modify or update this Privacy Policy from time to time, so please review it periodically.  We may provide you additional forms or notice of modifications or updates as appropriate under the circumstances.  Your continued use of the Application after any modification to this Privacy Policy will constitute your acceptance of such modification.

 

15. HOW TO CONTACT US

If you have questions or concerns about VITA’s Privacy Policy or to submit a request for information, please contact us at sn_service_privacy@snowcorp.com.