Privacy Policy

EFFECTIVE AS OF JANUARY 01, 2024

Welcome to SnapMug.

SnapMug is provided or controlled by WORK SMART LLC (hereinafter “ WORK SMART ”,

“ we ” or “ us ”)

We are committed to protecting and respecting your privacy.

This Privacy Policy (hereinafter the “ Policy ”) sets out the basis on which any personal data we

collect from you, or that you provide to us, will be processed by us. Please read the following

carefully to understand our views and practices regarding your personal data and how we will treat

it. By accessing or using our website, software, services, applications, products and content offered

via SnapMug (collectively, the “ Services ”), you are accepting and consenting to the practices

described in this Policy.

The Types of Personal Data We Collect and Use

We may collect and use the following information about you:

 Information you share with us. This is the information about you or relating to you that is

voluntarily shared by you on SnapMug. Information you share with us may include without

limitation postings that you make on SnapMug (including your public profile, name,

identification number, address, email address, social media login details, telephone number,

information about your device, your browsing records, the comments you make on

SnapMug, as well as account and billing/ payment details, the lists you create, and photos,

videos and voice recordings as accessed with your prior consent through your device

settings you turn on), any postings from others that you re-post and location data and log

data associated with such postings. Information you share with us also includes information

about you (including location data and log data) that others who are using SnapMug share

about you. Information you share with us will remain publicly-available for so long as you

or a user that has shared such information retains it.

 Information you share from your social networks. If you choose to link SnapMug to your

social network or public forum account (including without limitation Facebook, Twitter,

Youtube or Google account), you may provide us or allow your social network to provide

us with information from your social network or public forum accounts. This data may

include your use of SnapMug on such public forums and/or social networks. For further

information as to how and for what purpose the social network provider processes your

data, please see their privacy policies.

 Information on Your Device. We automatically collect certain data from you, including

IP address or other unique device identifiers such as Google advertising ID, Android ID,

Identifier for Advertising, Cookies (as defined below), mobile carrier, time zone and locale

setting, operating system and platform, hardware and software versions, battery level,signal strength, available storage space, browser type, app and file names and types,

Bluetooth signals, International Mobile Equipment Identity, International Mobile

Subscriber Identity, data from device settings: information you allow us to receive through

device settings you turn on, such as access to your GPS location, photos, videos and voice

recordings and such other information on your device. Any automated decision-making,

including profiling, based on the data automatically collected from you, will solely be used

in optimizing the Services and tailoring it to your preferences.

 Behavioral information we collect about you. We also collect information regarding your

use of the Services, e.g. your daily streams on SnapMug or any other content that you

Posted/ Uploaded on or through the Services, views and interactions on SnapMug. In

addition, we link your contact or subscriber information with your activity on SnapMug

across all your devices using your email or social media log-in details, engagement

(including without limitation likes, shares, repeated views) and relate users based on your

behavior. Finally, we collect opt-ins and communication preferences.

 Location data. We may collect and process information about your location, including

location information based on your SIM card, IP address or mobile device location settings,

and if activated on your mobile device, by use of a Global Positioning System (GPS). We

may use such information to provide you with location-based services, such as features,

notifications, marketing, or other content that is influenced by your location. If you do not

wish to share your GPS location with us, you can switch off GPS functionality on your

mobile device.

 Metadata. When you Post/ Upload content, including creative videos, images, texts and

audio to SnapMug, you automatically upload certain metadata that is connected to the

content. In essence, metadata describes other data and provides information about your

content that will not always be evident to the viewer. In connection with your content the

metadata can describe how, when and by whom the piece of content was collected and how

that content is formatted. It further includes information such as your account name that

enables other users to trace back the content to your user account. Metadata will further

consist of additional data that you chose to provide with the content, e.g. Content

Producer’s name, Date of production, any hashtags used to mark keywords to the creative

work (videos).

 Information from third parties. We may receive information if you use any of the other

websites we operate or other Services we provide. We may also receive information from

third parties (such as advertising networks and analytics providers) and from other sources,

including business directories and other commercially or publicly available sources.

 Contact Information. We may collect contact information from your contact list, address

book and your social network to enable you to link your SnapMug with the contact lists on

your device and/or in your account on third party services. We will ask for your consent to

access your contact list and address book before doing so. You may at any time allow or

disallow us to access your contact list and address book by changing your settings.

 Third-party Services. If you create a SnapMug account by connecting with a third-party

service, such as Facebook, Twitter(X), Google, Youtube or Tiktok, we may collectinformation from such third-party service, including without limitation your third-party

service user name, gender, profile image, birthday and third-party service contact list.

Cookies

We use cookies and other similar technologies (e.g. web beacons, Flash cookies, App cache, etc.)

(“ Cookies ”) to enhance your experience using SnapMug. Cookies are small files which, when

placed on your device, enable us to provide certain features and functionality.

We use the following Cookies:

 * Strictly necessary Cookies. These are Cookies that are required for the operation of

SnapMug and to keep your account and data safe and secure. They include, for example,

Cookies that enable you to log into secure areas of SnapMug.

 * Analytical/performance Cookies. They allow us to recognize and count the number of

visitors and to see how visitors move around SnapMug when they are using it. This helps

us to improve the way SnapMug works, for example, by ensuring that users are able to find

what they are looking for easily.

 Functionality Cookies. These are used to recognize you when you return to SnapMug.

This enables us to personalize our content for you, greet you by name and remember your

preferences (for example, your choice of language or region).

 Targeting Cookies. These Cookies record your visit to SnapMug, the pages you have

visited and the links you have followed. We will use this information to make SnapMug

and the advertising displayed on it more relevant to your interests. We may also share this

information with third parties for this purpose.

If for any reason you wish to not take advantage of Cookies, you may disable Cookies by changing

the settings on your browser. However, if you do so, this will affect your enjoyment of SnapMug

and we will no longer be able to offer to you personalized content. Unless you opt out of Cookies,

we will assume you consent to the use of Cookies.

“Do not track” signals are preferences that users can set on their web browser to limit how their

activity is tracked across third-party websites or online services. SnapMug does not respond to “do

not track” signals in your web browser.

Analytics information

On SnapMug, we use third-party analytics tools to help us measure traffic and usage trends for the

Services. Traffic refers to the different data flows surrounding activities of the users on the Services.

These tools, for example, collect information sent by your device or our Services, including the

pages you visit, add-ons, and other information that assists us in improving the Service. The

information will be used to report and evaluate your activities and patterns as a user of SnapMug

to provide services in accordance with these activities.

How We Use Your Personal DataWe will use the information we collect about you in the following ways:

 To administer SnapMug (i.e. to provide our Services to you) and for internal operations,

including troubleshooting, data analysis, testing, research, statistical and survey purposes

(i.e. to guarantee SnapMug’s stability and security) and to solicit your feedback;

 To allow you to participate in interactive features of SnapMug, when you choose to do so;

 To personalize the content you receive and provide you with tailored content that will be

of interest to you;

 To improve and develop SnapMug and conduct product development;

 To measure and understand the effectiveness of our recommendation and service we offer

to you and others;

 To make suggestions and recommendations to you and other users of SnapMug about

goods or services that will interest you or them;

 To allow other users to identify you as a user of the Service and to support the socializing

function of the Services;

 To promote the Services and use information that you give to us, such as content which

you choose to Post/ Upload on or through the Services, as part of our advertising and

marketing campaigns to promote the Services;

 To verify accounts and activity, combat harmful conduct, detect and prevent spam and

other bad experiences, maintain the integrity of SnapMug, and promote safety and security

on and off of SnapMug;

 To notify you about changes to our Services;

 To communicate with you;

 To provide you with user support;

 To enforce our terms, conditions and policies;

 For any other specific reason provided to you at the time we collect your information.

It is in our legitimate interest to promote the Services, and we may use information that you give

to us, such as content that you choose to Post/ Upload on or through the Services, as part of our

advertising and marketing campaigns to promote the Services.

How We Share Your Personal Data

We may share your personal data with selected third parties in or outside your country, including

without limitation:

 Our business partners so that we can make you special offers via SnapMug;

 With respect to on-screen ads, advertisers and advertising networks that require the data to

select and serve advertisements to you and others. Without your consent, we will not share

your contact details to our business partners to avoid direct contact from them, but we may

share other information so that they can make you offers tailored to your requirements;

 Cloud storage providers to store the information you provide and for disaster recovery

services, as well as for the performance of any contract we have entered into with you; Analytics and search engine providers that assist us in the improvement and optimization

of SnapMug.

 IT service providers that help develop, maintain, secure and optimize the SnapMug

framework;

 Our data center and the servers of our host providers.

We may share your information with any member or affiliate of our group, which includes our

subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control,

are controlled by or under common control, and our service providers and strategic business

partners, and their respective subsidiaries, in each case in or outside your country, for the purposes

set out above (“ How We Use Your Personal Data ”).

We may share your information with law enforcement agencies, public or tax authorities or other

organizations if legally required to do so, or if we have a good faith belief that such use is

reasonably necessary to:

 Comply with a legal obligation, process or request (including tax and related reporting

requirements);

 Enforce our Terms of Service and other agreements, policies, and standards, including

investigation of any potential violation thereof;

 Detect, prevent or otherwise address security, fraud or technical issues;

 Protect the rights, property or safety of us, our users, a third party or the public as required

or permitted by law (including exchanging information with other companies and

organizations for the purposes of fraud protection and credit risk reduction).

We may also disclose your information to third parties:

 In the event that we are linking SnapMug to thirdparty specially to create creative video

challenges as aliged in the app/ website, in which case we may disclose your data to the

prospective seller or buyer of such business or assets; or

 * If we merge or partner with other companies or businesses, or pay users through service

providers. In such transactions, user information may be among the transferred assets. In

any such cases, the third-party company or business will adhere to the provisions of this

Privacy Policy and where it will result in a change in any of the provisions herein, such

changes will be communicated to you and you will be given the chance to consent or opt

out at your discretion.

The Security of Your Personal Data

We take steps to ensure that your information is treated securely and in accordance with this policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although

we will do our best to protect your information, for example, by encryption, we cannot guarantee

the security of your information transmitted through SnapMug thus, any transmission is at your

own risk.We have put in place appropriate technical and organizational measures to ensure a level of

security appropriate to the risk of varying likelihood and severity for the rights and freedoms of

you and other users. We maintain these technical and organizational measures and will amend

them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks,

advertisers and affiliates. If you follow a link to any of these websites, please note that these

websites have their own privacy policies and that we do not accept any responsibility or liability

for these policies. Please check these policies before you submit any information to these websites.

Data Retention

We use the following criteria to determine the period for which we will keep your information:

 Our contractual obligations and rights in relation to the information involved;

 Legal obligation(s) under applicable law(s) and regulations to retain data for a certain

period of time;

 Statute of limitations under applicable law(s);

 Our legitimate business purposes;

 Disputes or potential disputes.

After you have terminated your use of our Services, we can store your information in an aggregated

and anonymized format. Notwithstanding the foregoing, we can also retain any personal

information as reasonably necessary to comply with our legal obligations, allow us to resolve and

litigate disputes, and to enforce our agreements.

Information Relating to Children

The Services are not offered to children whose age makes it illegal to process their personal data

or requires parental consent for the processing of their personal data under any applicable laws.

We do not knowingly collect personal data from children under 13 years or under the applicable

age limit in your jurisdiction (the “Age Limit”). If you are under the Age Limit, please do not use

the Services, and do not provide any personal data to us.

If we are aware that we have collected the personal data of a child under the Age Limit, we will

take reasonable steps to delete the personal data.

Complaints

In the event that you wish to make a complaint about how we process your personal data, please

contact us in the first instance at privacy and we will endeavor to deal with your request as soon

as possible. This is without prejudice to your right to launch a claim with your data protection

authority or follow the dispute resolution process provided in the Terms of Service.

ChangesWe may amend and update this Policy from time to time. You can access the latest version of this

Policy on SnapMug. It is your responsibility to remain informed of any changes. Your continued

access to or use of the Services after the date of the updated Policy constitutes your acceptance of

the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the

Services.

Your rights

You have the right to make a request to access and delete the personal data we hold about you, to

rectify any personal data held about you that is inaccurate, the right to data portability and the right

to request the suspension of the processing of your personal data.