SNAPP DIGITAL LLC

PRIVACY POLICY

This privacy policy (this "Privacy Policy") is effective as of January 1, 2015.

Your privacy is important to Snapp Digital LLC (together with its subsidiaries and affiliates, "SNAPP" or "us"). This Privacy Policy discloses the information practices for SNAPP’s websites, from what type of information about our websites’ users is gathered and tracked, to how the information is used, shared or otherwise processed offline. It also describes how cookies, web beacons and other technologies may be used in our Software products.

This Privacy Policy applies to SNAPP websites that link to this Privacy Policy. From time to time, we may supplement this Privacy Policy with additional information relating to a particular interaction we have with you.

Collection of Personal Information

You may choose to give us personal information directly in a variety of situations. For example, you may want to give us your name and contact information to communicate with you, to order a product, to process an order, to register for a service, to provide you with a subscription, or to do business with us if you are a supplier or a business partner. You may also share a description of your education and work experience in connection with a job opening at SNAPP for which you wish to be considered. If you tell us that you do not want us to use your information to make further contact with you beyond fulfilling your request, we will respect your wishes.

We may also collect information relating to your use of our websites and Software through the use of various technologies. For example, when you visit our websites or access our Software, we may log certain information that your browser sends us, such as your IP address, browser type and language, access time, and referring website addresses, and we may collect information about the pages you view within our sites and other actions you take while visiting us. In addition, some of our software products include technologies that allow SNAPP to collect certain information about product use. We may also use such technologies to determine whether you’ve opened an e-mail or clicked on a link contained in an e-mail. Collecting information in this manner allows us to collect statistics about the usage and effectiveness of our websites and our Software products, personalize your experience and tailor our interactions with you. For details regarding the technologies we employ, see Cookies, Web Beacon and Other Technologies below.

From time to time, we may also collect information that pertains to you indirectly through other sources, such as list vendors. When we do so, we ask the vendors to confirm that the information was legally acquired by the third party and that we have the right to obtain it from them and use it.

The information that we collect, either directly or indirectly, may be combined to help us improve overall accuracy and completeness and to help us better tailor our interactions with you.

Use of Personal Information

The following paragraphs describe in more detail how SNAPP may use your personal information.

Fulfilling your Transaction Request

If you request something from SNAPP, for example, a product or service, a callback, or specific marketing materials, we will use the information you provide to fulfill your request. To help us do this, we may share information with others, for instance, SNAPP’s business partners, financial institutions, shipping companies, payment processors, or postal or government authorities involved in fulfillment. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

Personalizing your Experience on our Websites

We may use information we collect about you to provide you with a personalized experience on our websites, such as providing you with content in which you may be interested and making navigation on our sites easier.

Providing Support

We may use your personal information to support products or services, such as notifying you of a product update or fix.

We may from time to time provide "Live Chat" sessions on our websites to assist you while you’re navigating through our sites; we will use personal information you provide via these sessions in accordance with this Privacy Policy.

In the course of providing technical support to you, we may sometimes have incidental access to data that you have provided to us or data that is located on your system. This data may contain information about you, your organization’s employees, customers, partners, or suppliers. This Privacy Policy does not apply to our access to or handling of this information; the conditions regarding the handling and processing of that data is covered by the applicable Terms of Use or other agreements between you and SNAPP.

Marketing

The information you provide to SNAPP, as well as the information we have collected about you indirectly, may be used by SNAPP for marketing purposes. Before we do so, however, we will offer you the opportunity to choose whether or not to have your information used in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, by indicating so if we call you, or by contacting us directly. Some of our offerings may be co-branded, that is sponsored by both SNAPP and third parties. If you sign up for these offerings, be aware that your information may also be collected by and shared with those third parties. We encourage you to familiarize yourself with their privacy policies to gain an understanding of the manner in which they will handle information about you.

Recruitment

In connection with a job application or inquiry, whether advertised on a SNAPP website or otherwise, you may provide us with information about yourself, such as a resume. We may use this information throughout SNAPP in order to address your inquiry or consider you for employment purposes. Unless you tell us not to do so, we may keep the information for future consideration.

Monitoring or Recording of Calls, Chats and Other Interactions

Certain online transactions may involve you calling us or us calling you. They may also involve online chats. Please be aware that it is SNAPP’s general practice to monitor and in some cases record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction.

Mobile Applications and Use of Information in the Social Computing Environment

SNAPP may from time to time make available mobile applications for download from various mobile application marketplaces. SNAPP may also provide social computing tools on some of its websites to enable online sharing and collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms.

When downloading and using these applications or registering to use these social computing tools, you may be asked to provide certain personal information. Registration information will be subject to and protected in accordance with this Privacy Policy, except for the information that is automatically made available to other participants as part of your profile. These applications and tools may also include supplemental Policy(s) with specific information about collection and handling practices. Read those supplemental statements to understand what the tools and applications may do.

Any other content you post, such as pictures, information, opinions, or any other type of personal information that you make available to other participants on these social platforms or applications, is not subject to this Privacy Policy. Rather, such content is subject to the Terms of Use of those applications or platforms, and any additional guidelines and privacy information provided in relation to their use, as well as the process by which you can remove your content from such tools or get help to do so. Please refer to them to better understand yours, SNAPP’s, and other parties’ rights and obligations with regard to such content. You should be aware that the content you post on any such social computing platforms may be made broadly available to others inside and outside SNAPP.

Protect the Rights and Property of SNAPP and Others

We may also use or share your information to protect the rights or property of SNAPP, our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, or legal process served on our websites.

Information for Business Partners

If you represent a SNAPP business partner, you may visit SNAPP websites intended specifically for SNAPP business partners. We may use information provided on that site to administer and develop our business relationship with you, the business partner you represent, and SNAPP business partners generally. For instance, this may involve using your information to send you details of SNAPP business partner programs. It may also include sharing certain information with other business partners (subject to any confidentiality obligations that may exist), or SNAPP customers or prospects. In connection with a particular transaction or program, we may also contact you as part of customer satisfaction surveys or for market research purposes.

Information for Suppliers

If you represent a SNAPP supplier, you may visit SNAPP websites intended specifically for use by SNAPP suppliers. We may use the information provided on that site in connection with entering into or performing a transaction with you. For example, this may include sharing information with other parts of SNAPP, SNAPP’s business partners, customers, shipping companies, financial institutions and postal or government authorities involved in fulfillment. It may also be used to administer and develop our relationship with you, the supplier you represent, and other SNAPP suppliers generally.

Sharing of Personal Information and International Transfers

In some cases, SNAPP may use suppliers located in various countries to collect, use, analyze, and otherwise process information on its behalf. It is SNAPP’s practice to require such suppliers to handle information in a manner consistent with SNAPP’s policies.

From time to time, we may disclose information that identifies you at an individual level and which we collected on our websites to other non-SNAPP entities that are not acting as our suppliers, such as our business partners. Except as described in this Privacy Policy, we will only do so with your prior consent. We do not sell or lease such information; however, circumstances may arise where, whether for strategic or other business reasons, SNAPP decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is SNAPP’s practice to seek appropriate protection for information in these types of transactions.

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your information to protect the rights or property of SNAPP, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

Information Security and Accuracy

We intend to protect your personal information and to maintain its accuracy. SNAPP implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt certain sensitive personal information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure.

Retention

We will retain your registration information for as long as your account is active or as needed to provide you services. If you wish to request that we no longer use your registration information to provide you services contact us at support@snappdigital.com. We will retain and use your registration information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Cookies, Web Beacons and Other Technologies

As mentioned above, we collect information from your visits to our websites and your use of our Software products to help us gather statistics about usage and effectiveness, personalize your experience, and tailor our interactions with you. We do so through the use of various technologies, including one called "cookies". A cookie is a piece of data that a website can send to your browser, which may then be stored on your computer as a tag that identifies your computer. While cookies are often only used to measure website usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any personal information, they are also used at times to personalize a known visitor’s experience to a website by being associated with profile information or user preferences. Over time this information provides valuable insight to help improve the user experience.

Cookies are typically categorized as "session" cookies or "persistent" cookies. Session cookies help you navigate through the website efficiently, keeping track of your progression from page to page so that you are not asked for information you have already provided during the current visit. Session cookies are stored in temporary memory and erased when the web browser is closed. Persistent cookies, on the other hand, store user preferences for current and successive visits. They are written on your device’s hard disk, and are still valid when you restart your browser. We use persistent cookies, for example, to record your choice of language and country location.

While SNAPP websites at this time do not recognize automated browser signals regarding tracking mechanisms, such as "do not track" instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies though your web browser. Look under the heading "Tools" (or similar heading) in your particular browser for information about controlling cookies. You can set your browser in most instances to notify you before you receive a cookie, giving you the chance to decide whether to accept it or not. You can also generally set your browser to turn off cookies. Since cookies allow you to take advantage of some of our websites’ features or features of our Software products, we recommend that you leave them turned on. If you block, turn off or otherwise reject our cookies, some web pages may not display properly or you will not be able, for instance, to add items to your shopping cart, proceed to checkout, or use any website services that require you to sign in. Some SNAPP websites, Software products may also use web beacon or other technologies to better tailor those sites to provide better customer service. These technologies may be in use on a number of pages across SNAPP’s websites. When a visitor accesses these pages, a non-identifiable notice of that visit is generated which may be processed by us or by our suppliers. These web beacons usually work in conjunction with cookies. If you don’t want your cookie information to be associated with your visits to these pages or use of these products, you can set your browser to turn off cookies. If you turn off cookies, web beacon and other technologies will still detect visits to these pages; however, they will not be associated with information otherwise stored in cookies.

We may also include web beacons in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links contained within clicked on.

Some of our business partners may set web beacons and cookies on our site. In addition third-party social media buttons may log certain information such as your IP address, browser type and language, access time, and referring website addresses, and, if you are logged in to those social media sites, they may also link such collected information with your profile information on that site. We do not control these third party tracking technologies. Note that the "www.snappdigital.com" domain used to deliver static content on some of our websites is managed by SNAPP, and not by a third party.

Online Advertising

SNAPP does not deliver third party online advertisements on our websites but we may advertise our products and services on others’ websites. Please familiarize yourself with those website operators’ or network advertisers’ privacy policies to understand their practices relating to advertising, including what type of information they may collect about your Internet usage.

We may also elect to engage certain third parties to manage some of our advertising on other sites. These third parties may use cookies and web beacons to collect information (such as your IP address) about your activities on SNAPP’s and others’ websites to provide you targeted SNAPP advertisements based upon your interests.

Links to Non-SNAPP Websites and Third Party Applications

To allow you to interact with other websites on which you may have accounts (such as Facebook and other social media sites) or join communities on such sites, we may provide links or embed third-party applications that allow you to login, post content or join communities from our websites. We may also provide you with general links to non-SNAPP websites. Your use of these links and applications is subject to the third parties’ privacy policies, and you should become familiar with the third party sites’ privacy policies before using the links or applications. SNAPP is not responsible for the privacy practices or the content of those other websites.

Notification of Changes

We will post a notice for 30 days at the top of this page notifying users when this Privacy Policy is updated or modified in a material way. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you, and you will have a choice as to whether or not we can use your personal information in such a way.

Privacy Questions and Access

If you have a question about this Privacy Policy or SNAPP’s handling of your information, you can send an email to support@snappdigital.com. You can also contact us at:

SNAPP’s Privacy Officer

Snapp Digital LLC

c/o Privacy Officer

5000 Euclid Ave., Suite 303

Cleveland, Ohio 44103.

Through your online account you may have the ability to view or edit your personal information. In the event your information is not accessible online or if you become aware the information is incorrect and you would like us to correct, please contact us at support@snappdigital.com.

Before SNAPP is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will contact you within 30 days of your request. If you no longer wish to receive marketing e-mails from SNAPP, please send an e-mail to support@snappdigital.com or follow the unsubscribe instructions included in each marketing email.

Last Updated: 1/13/2015