Updated: Mar 16th, 2022
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 Us Directly
• Your SNS ID and SNS Profile image when you register for an account.
• Profile information that you provide for your user profile (e.g., ID, Instagram ID, Profile image).
• User Content (e.g., photos, facial scans, comments, and other materials) that you post to the Application.
• Information you provided to other users through the Application.
• Information you provided for customer service (e.g., e-mail, country information, etc)
• Communications between you and SNOW. (For example, we may send you Application-related emails. Note that you may not opt out of Application-related e-mails.)
Information We Collect from Your Use of the Application
• In-app purchases
When you made in-app purchases ( e.g. Regular subscription, etc.) in SNOW, we will collect related order information , including IP address, unique device identification code, order number, transaction time, product category and product price.
• Analytics Information.
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 with analytics information from other users so that it cannot reasonably be used to identify any particular individual user.
• Location Information.
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.
• Cookies and Similar Technologies.
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/.
• Log information.
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.
- 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.
Metadata refers to technical data associated with user content. Put simply, metadata is data that describes data. For example, metadata can describe the analysis results of facial features, the characters in photos, and other elements contained in photos, which are generated and tagged by the computer algorithm and artificial intelligence. When you use the Services, we will use photo metadata to provide you with certain features including precise “Facial Recognition,” “Key-Points Recognition, ” “Region Segmentation, ” “Content Tags” and other custom features based on a combination of these basic features. We may use your photo metadata to provide you with more suitable filters and better photo effects when the Application processes your photos; we may also make use of the metadata to serve up a more contextually relevant products or services to you.
• Face Recognition.
SNOW uses face recognition technology to recognize faces in photos, videos, and camera experiences.
We detect facial marks only to provide face recognition contents and facial manipulation features - specifically, to apply filters and makeup on the appropriate face position.
The information we collect cannot be used for identifying a specific person at all. This information is processed in real-time for providing mentioned features only. This information is only used within the users' devices.
However, the following features (filters, effects, etc.) will send, use and process facial recognition information, metadata, or images to/on our servers. Still, this information is deleted from SNOW’s servers after the user has finished using the specific features (filters, effects, etc.), or when the application is closed while using the features. This information is not saved on our servers.
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• Device and Usage Information.
We may collect device and usage information such as:
- Precise geolocation data pertaining to users’ devices (only upon your consent), which may be expressed by latitude-longitude coordinates obtained through GPS tools, WiFi data, cell tower triangulation or other techniques (collectively, “Device Geolocation Data”) and linked to a device identifier, such IDFA for iOS devices or Android ID for Android devices.
- 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.
• Local Storage.
- We may access metadata and other information associated with other files stored on your device. This may include, for example, photographs and contacts (only for the purpose of inviting friends to use the Application with your permission).
• Third-Party Social Media Site.
<This clause applies to Apple device users only.>
• Use of Information from Apple's TrueDepth API.
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 SNOW (such as photo, video, effects, and more). However, this information is processed in real-time for delivering and improving these features only. This information is not saved on our servers or shared with any third parties.
3. HOW WE USE YOUR INFORMATION
• To provide the functionality of the Application
• To help us develop, deliver, test and improve the Application
• To monitor metrics such as total number of visitors, traffic, and demographic patterns
• To provide personalized content and information to you and others, which could include sending you promotional messages, marketing, advertising and other information that may be of interest to you
• To diagnose or fix technology problems
• To allow us to keep you posted on SNOW’s latest product announcements, application updates, and upcoming events
• To provide customer support and respond to your inquiries and requests
• To allow professionals to contact you through the Application (as further described below)
• To administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our third-party business partners
• To find and prevent fraud
• To resolve disputes, to protect the rights, property, or safety of SNOW, our Application visitors, customers, or the public, and to enforce any legal terms that govern your use of the Application or our other services and products
• To comply with our legal and regulatory obligations
• For the performance of any contract with you or to take steps at your request before entering into a contract
• Where you have given consent
• For any other legitimate interest or those of a third party
4. INFORMATION SHARING AND DISCLOSURE TO THIRD PARTIES
Third-Party Service Providers
Third-Party Advertising Network
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.
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:
• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; user alias; other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers
• Characteristics of protected classifications under California or federal law, such as age and gender
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information : audio, electronic, visual, and similar information
• User Content (e.g., photos, facial scans, comments, or other materials) that you post to the Application
• Your preferences, characteristics, predispositions, behavior, and attitudes.
6. YOUR CHOICES ABOUT YOUR INFORMATION
You may update or correct information you have provided to us by going into the User Account settings screen within the Application. If you wish to deactivate your account, please delete the Application, but note that we may retain your information as required by law and for business purposes.
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
When you have opted out of using this setting on a device, advertisers will not use in-Application information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests. Please note, however, that opting-out will not block general advertisements that are sent at random, and not tied to the perceived interest of the User of a particular device.
Users 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/.
Control or Disable the Collection of Geolocation Information
We do not collect geolocation information from you unless we obtain your explicit consent through your device’s settings menu. You can also control the collection of certain precise location information by changing the preferences on your mobile device (but certain services may lose functionality as a result).
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.
You may view, update, or edit the information (profile picture, nickname, Instagram ID, bio (introduction)) that you have provided to the company in the application’s “Hot > Profile” at top right.
If you no longer wish to use the service, you may withdraw from the service and delete your account.
The details are as follows.
Removal of Personal Information
You may directly delete content that you created while using the service via the following methods.
In addition, you may delete all of the content (username, profile picture, nickname, Instagram ID,
bio (introduction), my filters, favorite filters and effects, followers, following) that you created or provided to the company by selecting Settings > Account Settings > Delete Account.
However, please note that you cannot edit or delete your uploaded content after deleting your account. Please edit or delete the content before deleting your account.
If you need to delete your created content after deleting your account, please contact us via email@example.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, and the reason will be provided when requests are denied.
7. HOW LONG WE KEEP YOUR INFORMATION
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
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. The Application and its content are not directed at children under the age of 16. In the event that we learn that we have collected personal information from a child under age 16 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org
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. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
We use commercially reasonable safeguards to help keep the information collected through the Application secure. However, SNOW cannot ensure the security of any information you transmit to the 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
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.
15. HOW TO CONTACT US