A. The data we collect

Snape collects data: 

• provided by users to Snape, such as during account creation
• created during use of our services, such as location, app usage, and device data
• from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities

For your convenience, we’ve provided a visual summary of the data we collect and how we use it here.

Snape collects the following data:

1. Data provided by users. This includes:

• User profile information: We collect data when users create or update their Snape accounts, or place orders via guest checkout features. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), Snaper’s license and other government issued documents (which may include identification numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of Snapers and delivery persons, emergency contact information, user settings, and evidence of health or fitness to provide services using Snape apps. 
• Background check information (Snapers and delivery persons): This includes information submitted during the Snaper/delivery person application process, such as Snaper history or criminal record (where permitted by law), license status, known aliases, prior addresses, and right to work. This information may be collected by an authorized vendor on Snape’s behalf.
• Identity verification photos: This includes photos of users (such as, selfies) and/or their government issued identifications (such as, Snaper’s license or passports). Such photos may be used to verify a user’s identity, such as through facial verification technologies. Please see the section titled “How we use personal data” for more information regarding how user photos are used for safety and security purposes, including identity verification.
• Demographic data: We may collect demographic data about users, such as birth date/age, gender or occupation, when required for certain Snape services or programs, such as Snape Cash
• We may also collect demographic data through user surveys.
• User content: We collect the data submitted by users when they contact Snape customer support (including at Snape Greenlight Hubs or via phone chat or video conferencing tools), provide ratings or feedback for other users contact Snape. This may include photographs, or audio or video recordings submitted by users in connection with a customer support request. This also includes metadata relating to the method you use to communicate with Snape. The contents of photos and recordings submitted by users are subject to Snape’s Community Guidelines.

  2. Data created during use of our services. This includes: 

• Location data (Snaper and person): We collect precise or approximate location data from Snapers’ and delivery persons’ mobile devices when the Snape app is running in the foreground (app open and on-screen) or background (app open but not on-screen).
• Location data (clients and order recipients). We collect precise or approximate location information from clients’ and order recipients’ mobile devices if they enable us to do so via their device settings.

  Snape collects such data from the time a order is requested until it is finished, and any time the app is running in the foreground (app open and on-screen). See “Choice and transparency” below for information on how clients and order recipients can enable precise location data collection.

  Clients and order recipients may use the Snape apps without enabling collection of location data from their mobile devices. However, this may affect certain features in the Snape apps.

• In addition, precise location data collected from a Snaper’s device during an order is linked to the clients’s account, even if the client has not enabled precise location data to be collected from their device. This data is used for purposes such as receipt generation, customer support, fraud detection, insurance, and litigation.
• Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided; trip or order details (such as date and time, requested shoot/job addresses, distance traveled and items ordered); and payment transaction information (such as a restaurant’s or merchant’s name and location, amount charged, and payment method). We also associate a user’s name with that of anyone who uses their promotion code.
• Usage data: We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, and app crashes and other system activity.
• Device data: We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
• Communications data: We collect data regarding phone, text or in-app communications between users that are enabled through Snape’s apps. This includes date and time, as well as the content of text or in-app messages. We may also collect the content of phone calls solely where users are notified in advance that the call may be recorded.

3. Data from other sources. These include:

• users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s data from that user.
• Snape account owners who request services for or on behalf of other users (such as friends or family members), or who enable other users to request or receive services through their business
•  
• users or others providing information in connection with claims or disputes.
• Snape business partners through which users create or access their Snape account, such as payment providers, social media services, or apps or websites that use Snape’s APIs or whose APIs Snape uses. 
• Snape business partners in connection with debit or credit cards issued by a financial institution in partnership with Snape to the extent disclosed in the terms and conditions for the card.
• vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements. 
• publicly available sources.
• marketing service providers or data resellers whose data Snape uses for marketing or research.
• law enforcement officials, public health officials, and other government authorities.

B. How we use personal data

Snape uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use such data:

• to enhance the safety and security of our users and services
• for customer support  
• for research and development  
• to enable communications between users 
• for marketing and advertising
• to send non-marketing communications to users
• in connection with legal proceedings

We use the data we collect:

1. To provide our services. Snape uses data to provide, personalize, maintain, and improve our services.

This includes using data to:

• create/update accounts.
• enable transportation, delivery and other services/features, such as:
  • using location data to navigate client job information, calculate ETAs, and track the progress of shoot or deliveries.
  • features that involve data sharing, such as sharing Snaper first name and specialty  information with clients to facilitate orders, user profile and shoot details for ETA sharing and fare splitting, and user ratings and compliments.
  • features that facilitate use of our services by those with disabilities.
  • features that involve account linking, such as linking of email to create Snape Travel itineraries and linking of rewards programs to enable partnership benefits
  •  
• enable dynamic pricing, in which the price of a shoot, or the delivery fee for Snape orders, is determined based on factors such as estimated time and distance

2. Safety and security. We use data to help maintain the safety, security, and integrity of our services and users. This includes:

• verifying users’ identity and eligibility to provide services, including through reviews of background checks, to help prevent use of our services by unsafe Snapers and/or clients.

  In certain regions, this includes Snape’s Real-Time ID Check feature, which prompts Snapers share a selfie before going online to help ensure that the Snaper or delivery person using the app matches the Snape account we have on file. We may also use this feature for other verification purposes such as verifying change of bank account information or regaining account access.

  In addition, we may use facial recognition technology to process user profile photographs, identification photographs, or other user-submitted photographs to prevent identity-borrowing or use of our services by unauthorized Snapers or delivery people.

  We may also use selfies to verify that users are wearing masks, helmets or other safety gear through the use of object verification technology.

  In some countries, clients may be required to verify their identity to use cash and certain other payment methods. In such cases, Snape allows clients to provide their ID number and/or a photo of their identification card to complete such verifications.

  Similarly, order recipients may be required to provide their age and an image of their government issued identification to verify their eligibility to order and receive alcohol deliveries.

•  
• using Snaper location information, and communications between clients and Snapers, to identify cancellation fees earned or induced through fraud. For example, if we determine that a Snaper is delaying a client job in order to induce a cancellation, we will not charge the client a cancellation fee and will adjust the amounts paid to the Snaper to omit such a fee.
•  
• using device, location, user profile, usage, and other data to prevent, detect, and combat other types of fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorized Snapers , verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts. In some cases, such as when a user is determined to be abusing Snape’s referral program or has submitted fraudulent documents, such behavior may result in automatic deactivation, or in the European Union or where 3. Customer support. Snape uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.

  Snape performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users or for purposes of Snape’s legitimate interest in monitoring and improving its customer support services.

4. Research and development. We use data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features.

Snape performs the above activities on the grounds that they are necessary for purposes of Snape’s legitimate interests in improving and developing new services and features.

5. Enabling communications between users. For example, a Snaper may message or call a client to confirm a pick-up location, a client may call a Snaper to retrieve a lost item, or a restaurant or delivery person may contact an order recipient with information about their order.

Snape performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users.

6. Marketing and Advertising. Snape uses data (other than Guest Users’ data) to market its services, and those of Snape partners. This may include:

• Sending emails, text messages, push notification, and in-app messages or other communications marketing or advertising Snape products, services, features, offers, promotions, sweepstakes, news and events.

  we may send push notifications suggesting a user’s favorite destinations or merchants, or in-app messages offering discounts or promo for products or merchants similar to those a user has previously ordered. 

• Displaying Snape advertising on third party apps or websites. This includes using location, trip and order history, and usage data, and sharing hashed email addresses and device or user identifiers with advertising partners (such as Facebook and TikTok), to personalize such ads to users’ interests.
• Displaying third party advertising in Snape’s apps or in connection with our services.
  .

  This also includes ads for other third party products or services that are personalized based on users’ observed or inferred interests and characteristics, which we determine using data such as approximate location, trip information and history, usage data, demographic data (which may include inferred gender), and device or user identifiers.

   

• Snape performs the above activities on the grounds that they are necessary for purposes of Snape’s legitimate interests in informing users about Snape services and features or those offered by Snape partners. See the sections titled “Choice and transparency” and “Marketing and advertising choices” for information on your choices regarding how Snape may use your data for marketing and advertising.

7. Non-marketing communications. Snape may use data to send surveys and other communications that are not for the purpose of marketing the services or products of Snape or its partners. We may also send users communications regarding elections, ballots, referenda, and other political processes that relate to our services. For example, Snape has notified some users by email of ballot measures or pending legislation relating to Snape’s services in those users’ areas.

Snape performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, or for purposes of Snape’s and its users’ legitimate interests in informing users about events that may have an impact on their use of Snape services.

8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of Snape’s services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.

Snape performs the above activities on the grounds that they are necessary for purposes of Snape’s legitimate interests in investigating and responding to claims and disputes relating to use of Snape’s services and features, and/or necessary for compliance with applicable legal requirements.

C. Cookies and third-party technologies

Snape and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and Snape’s Cookie Notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Snape uses cookies and similar technologies for purposes such as:

• authenticating users
• remembering user preferences and settings
• determining the popularity of content
• delivering and measuring the effectiveness of advertising campaigns

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

D. Data sharing and disclosure

Some of Snape’s services and features require that we share data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Snape may share data:

1. With other users

This includes sharing:

• clients’ first name, rating, and job locations with Snapers.
• order recipients’ first name, job address, and order information

2. At the user’s request

This includes sharing data with:

• Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s trip information when they split a fare with a friend.
• Snape business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Snape may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurants, merchants or other Snape business partners and their users in connection with promotions, contests, or specialized services.
• Emergency services: We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.  

3. With the general public

Questions or comments from users submitted through public forums such as Snape blogs and Snape social media pages may be viewable by the public, including any data included in the questions or comments submitted by a user.

8. With consent

Snape may share a user’s data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion

Snape retains user data for as long as necessary for the purposes described above, including to provide its services and comply with legal obligations.

Snape retains user data for as long as necessary for the purposes described above. The period for which we retain user data is determined by the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

The length for which Snape retains user data may further be determined by legal and regulatory requirements, purposes of safety, security, and fraud prevention, or by issues relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.

For example, we retain data:

• for the life of users’ accounts if such data is necessary to provide our services. E.g., user profile information and credentials.
• for 7 years if necessary to comply with tax requirements. E.g., Snapers’ and delivery persons’ trip or delivery location information.
• for defined periods as necessary for purposes of safety or fraud prevention. E.g., we retain incomplete Snaper applications for 1 year, and rejected Snaper applications for 7 years.
• after requests for account deletion if necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute).

Users may request deletion of their accounts at any time. Snape may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.

Users may request deletion of their account at any time through the Settings > Privacy menus in the Snape app, or through Snape’s website (clients and order recipients here; Snapers and delivery persons here; guest checkout users here).

Following an account deletion request, Snape deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to Snapers and delivery persons, this generally means that we retain their account and data for the applicable statutory retention period after a deletion request. For clients and order recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

Snape enables users to access and/or control data that Snape collects, including through: 

• privacy settings
• device permissions
• in-app ratings pages
• marketing choices 

Snape also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that Snape restrict its processing of user data.