Privacy Policy

1. Privacy Policy For Website

Introduction

This privacy policy will help you understand how we may collect and use your personal information. This policy also describes your rights and how you can use your rights. You can easily contact SnapSurv if you have any questions related to this policy.

SnapSurv Ltd a company with the registration number 12891576 whose registered office is 2d, Station Yard, Thame, England, OX9 3UH is considered is considered Data Controller of your personal data.

Processed Data

On SnapSurv’s websites we may offer you to subscribe to our newsletters, be notified about events, receive occasional news, insights and best practices, receive commercial offerings as well as fill in a contact request as well as register to access educational content. The type of personal data that SnapSurv processes about you may be:

  • Your contact details such as name, address, telephone number and email address
  • Your job title, position including preferences and interests in a professional context
  • Website traffic information as provided by your web browser such as browser type, language and the address of the referring website and other traffic information such as IP address
  • Website visitor behaviour such as which links you click and when.

In general, SnapSurv collects personal data directly from you when you register on our sites or fill out a form. We may also, with your consent, use cookies and other tracking technology when you use our websites in order to optimize your experience of these.

We may also collect information about you from other sources, including publicly available databases or third parties from whom we have purchased data or to whom you have provided your data, and combine this data with information we already have about you. This helps us to update, expand and analyse our records, identify new prospects for marketing, and provide information about our products and services that may be of interest to you.

Purposes of Processing

Your personal data may be saved and processed by SnapSurv for the following purposes:

  • In order to answer a contact request or to send you educational content, newsletters or invitations for seminars and similar events to you. Accordingly, if you do not provide the requested personal information, SnapSurv will not be able to respond to a contact request or to send you any newsletters or invitations and information.
  • For marketing and market research, as well as basis for SnapSurv’ market and customer analyses, business and product development, and statistics
  • To personalize your experience (your information helps us to better respond to your individual needs)
  • To improve our websites (we continually strive to improve our websites offerings based on the information and feedback we receive from you)

Legal Ground

In accordance with SnapSurv’ assessment, the processing is necessary for the purposes of SnapSurv’ legitimate interest in answering a contact request, and administering newsletters, information and invitations to you in accordance with your wishes to be contacted or to receive requested information, respectively.

In addition, SnapSurv’s processing of your personal data for marketing purposes, for market research, for market and customer analysis, business and product development and statistics, is based on a legitimate interest. According to SnapSurv’ assessment, the processing is necessary for SnapSurv’ legitimate interest to market its products and services, and to analyse and develop its business and operations.

Retention of Personal Data

In general, SnapSurv will only retain your personal data for as long as necessary for the stated purpose, while also taking into account our need to answer queries or resolve problems and to comply with legal requirements under applicable law. This means that we may retain your personal data for a reasonable period after your last interaction with us (normally for a period of three calendar years from your last interaction with us). When the personal data that we collect is no longer required in this way, we destroy or delete it in a secure manner.

Personal data provided in connection with newsletter subscriptions, event registrations or information requests are stored by SnapSurv until you unsubscribe from the applicable service. However, if you unsubscribe, SnapSurv will continue to process your personal data to the extent necessary to ensure by technical means that no further posting of newsletters, event invitations, educational information and similar are sent to you. If SnapSurv does not save your personal data in this respect, SnapSurv will not be able to ensure that no further newsletters, invitations or information will be sent to you. The continued processing of your personal data is, according to SnapSurv’ assessment, necessary for the purposes of SnapSurv’ legitimate interest in preventing sending of newsletters, information and invitations to you in accordance with your expressed desire.

Your Privacy Rights under Applicable Data Protection Laws

You have the right to request a confirmation from SnapSurv as to whether or not personal data concerning you are being processed and, where that is the case, obtain access to your personal data. You also have the right to request that SnapSurv corrects any inaccuracies in your personal data and that SnapSurv shall erase your personal data or restrict the processing of your personal data. You further have the right, at any time, to object to SnapSurv’ processing of your personal data if you believe that SnapSurv has no legitimate interest in processing the personal data or to the use of your personal data for the purposes of direct marketing. You are finally entitled to lodge a complaint regarding SnapSurv’s processing of your personal data with a supervisory authority. Nevertheless, please note that the SnapSurv’s processing of your Personal Data may be on other legal grounds than what we have set out in this Privacy Policy. Furthermore, we will assess all requests on a case by case basis and might in some cases not be able to adhere to your request.

To exercise the aforementioned rights in relation to us, or if you have any questions about our sharing practices, your rights under Applicable Data Protection Laws, or wish to have your Personal Data removed, please contact us at the following address: SnapSurv 2d, Station Yard, Thame, England, OX9 3UH. In order to ensure that you receive a swift response, please state in your letter your full name and, if applicable, your address and user name. Please note that you should sign the request in order to receive information of the processing of your Personal Data, and that you may be asked to verify your identity before any Personal Data is disclosed or information given. You can also contact SnapSurv at [email protected] for more information about these rights.

Disclosure of Personal Data

Ensuring your privacy is important to SnapSurv. We do not share your personal data with third parties except as described in this privacy policy. We may share your personal data with:

  • Third party service providers (for example to partners that are administrating webinars or websites on behalf of SnapSurv);
  • Business partners; and
  • As needed for legal purposes (for example to authorities in accordance with applicable laws and regulations).

SnapSurv may also share your personal data with consultants. When sharing your personal data with third parties we take appropriate technical, organizational and legal measures in accordance with applicable data protection legislation. When required by applicable law, SnapSurv has established Data Processing Addendums with any third party with which your personal data is shared.

Security

SnapSurv takes security seriously. We take various steps to protect information you provide to us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology.

Changes to this privacy policy

This policy was last updated on 23rd November 2020. We may change this policy from time to time and if we do we will post any changes on this page. If you continue to interact with us after those changes are in effect, you are agreeing to the revised policy.

2. Privacy Policy for SnapSurv End Users

Dear User,

Welcome to SnapSurv Video Based Remote Guidance (the “Software”), which is provided by SnapSurv Ltd a company with the registration number 12891576 whose registered office is 2d, Station Yard, Thame, England, OX9 3UH (“SnapSurv” or “we” or “us”), offered to companies (with each such legal person having entered into an agreement with us regarding use of said solution being an “End User” or “You”).

You may use the Software acting as an authorized officer, director, employee, agent, representative or adviser of an End User (“Representative”). Reference is also made to our End User License Agreement (the “EULA”).

When you use the Software, the End User having authorized your use is the personal data controller for the processing of your Personal Data (as defined below), and we are the personal data processor of the End User, processing such data on behalf of and according to the instructions of said End User. Nevertheless, we collect and process certain information, to the extent necessary for improving the Software and the functioning of the Software and your use thereof, and we are the data controller in relation to this processing of Personal Data. Your privacy is important to us. This document contains a policy statement regarding the collection, use and processing of Personal Data within the Software and your rights in relation to your Personal Data, as well as information about with whom we share such information with. With “Personal Data” we mean information which is directly or indirectly referable to a natural living person, e.g. name and address but also possibly, device ID, location data or IP addresses. We collect the information set out below, which include your Personal Data.

Please read this Privacy Policy before you use the Software.

Processed DATA

The following Personal Data is collected and processed when you use the Software:

  • Your user id, typically your e-mail address.
  • Optionally your name, if entered into the system
  • Your chat conversations
  • Records of video calls made, including other parties in the call, time and duration.
  • Records of any notes made during the call
  • Technical data, including your unique device ID, IP address, network and device performance and other information about your use of the Software.

PURPOSES OF PROCESSING

End User

The End User that has authorized your use of the Software processes the Personal Data for the purpose of carrying out activities involving the use of SnapSurv. Use of the Personal Data collected for other purposes, if applicable, are to be communicated to you by each such End User in their capacity of personal data controllers.

SnapSurv

We will process the information set out above for the following purposes:

  • to administrate your account, to enable and provide the Software and improve the Software, and to otherwise fulfil our obligations with regard to the agreements entered into with our End Users;
  • to inform you about updates of the Software or our EULA;
  • to improve and develop the Software;
  • to ensure the technical functioning of the Software and to prevent use of the Software in breach of the EULA;
  • to enforce the EULA, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary; and
  • to fulfil requirements by law.

LEGAL GROUND

The processing of Personal Data is based on our legitimate interests, which serves as the legal ground for the processing.

Our legitimate interests are (i) to provide our services to the End User; and (ii) to continually offer, improve and develop the Software. We are not able to fulfil our legitimate interests without processing some Personal Data.

In the balancing of interests between our legitimate interests, and your interests and rights and freedoms, it is considered that in your position as a Representative of the End User it is expected of you to use the tools and services that you are directed to use by the End User. Therefore, since you have not objected to such processing of Personal Data, we assume that you are not opposing to our processing of Personal Data when providing the Software. Furthermore, we respect the value and integrity of Personal Data – therefore, we have implemented technical and organizational security measures to ensure the integrity and confidentiality of the Personal Data. The number of employees that processes Personal Data at SnapSurv is kept to a minimum, they are trained to process the Personal Data in accordance with our internal data protection policies, and they are subject to confidentiality undertakings. The types and amount of Personal Data that is processed, is the minimum data possible to enable us to fulfil our legitimate interests. The Personal Data will not be used for any other purposes than what is set out in this Privacy Policy and will not be used for additional purposes in the future. In light of this, we consider that the processing of Personal Data conducted by us does not infringe your rights and freedoms, and that our legitimate interests set out above are not incompatible with your interests. Please note that the End User’s processing of your Personal Data may be based on other legal grounds than what we have set out here.

DISCLOSURE OF PERSONAL DATA

We may share and disclose your Personal Data to our sub-contractors.

Your e-mail address may be disclosed to other users of the Software that you choose to connect within the Software.

RETENTION OF PERSONAL DATA

The Personal Data is processed for the period during which the Software is provided to you. Upon termination of a user account, the Personal Data relating to such an account will be deleted within 3 months after the termination of the applicable customer agreement or within reasonable time after the 3 months period.

RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM

We can access, preserve and share your information in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations, if we have a good faith belief that the applicable law require us to do so.

This includes responding to legal requests from jurisdictions outside of the EU/EEA when we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

Information that we receive about you when you use our Software, can be accessed, preserved and retained for an extended period of time when it is the subject of a legal request or obligation, government investigation, or investigations concerning possible violations of our EULA or policies, or otherwise to prevent harm.

SOME OTHER THINGS YOU NEED TO KNOW

Change of Control

If the ownership of our business changes, we will transfer your information to the new owners so they can continue deliver our solution for remote guidance, including the Software. The new owner will still have to honour the commitments we have made in this Privacy Policy.

Notice of changes

If we make changes to this Privacy Policy, we will notify you by publication here. If the changes are material, we will provide you additional, prominent notice as appropriate under the circumstances and, where required under applicable law, ask for your consent.

Your Privacy Rights under Applicable Data Protection Laws

Applicable Data Protection Laws permits residents of the Member States to request details about what Personal Data is stored with us, the source of the data and the identity of parties to whom the data has been provided free of charge, as well as other information, without indicating any reasons.

You can object to the use of your Personal Data at any time. Nevertheless, please note that the End User’s processing of your Personal Data may be on other legal grounds than what we have set out in this Privacy Policy. In addition, you can request rectification, erasure or blocking at any time of any Personal Data. However, if we are under legal obligation to save the data, such data can only be blocked. Furthermore, we will assess all requests on a case by case basis and might in some cases not be able to adhere to your request.

To exercise the aforementioned rights in relation to us, or if you have any questions about our sharing practices, your rights under Applicable Data Protection Laws, or wish to have your Personal Data removed, please contact us at the following address: SnapSurv Ltd 2d, Station Yard, Thame, England, OX9 3UH. In order to ensure that you receive a swift response, please state in your letter your full name and, if applicable, your address and user name. Please note that you should sign the request in order to receive information of the processing of your Personal Data, and that you may be asked to verify your identity before any Personal Data is disclosed or information given.

3. Privacy Policy for SnapSurv Supporters

Welcome to SnapSurv Video Based Remote Guidance (the “Software”), which is provided by SnapSurv Ltd a company with the registration number 12891576 whose registered office is 2d, Station Yard, Thame, England, OX9 3UH (“we” or “us” or “SnapSurv”), offered to companies (with each such legal person having entered into an agreement with us regarding use of said solution being an “End User”).

SnapSurv maybe conducted with the help of an individual in the location where the video based remote guidance is being used (“Supporter” or “You”).

When you use the Software, the End User having authorized your use is the personal data controller for the processing of your Personal Data (as defined below), and we are the personal data processor of the End User, processing such data on behalf of and according to the instructions of said End User. Nevertheless, we collect and process certain information, to the extent necessary for improving the Software and the functioning of the Software and your use thereof, and we are the data controller in relation to this processing of Personal Data. Your privacy is important to us. This document contains a policy statement regarding the collection, use and processing of Personal Data within the Software and your rights in relation to your Personal Data, as well as information about with whom we share such information with. With “Personal Data” we mean information which is directly or indirectly referable to a natural living person, e.g. name and address but also possibly, device ID, location data or IP addresses. We collect the information set out below, which include your Personal Data.

Please read this Privacy Policy carefully.

Processed DATA

The following Personal Data is collected and processed when you use the Software:

  • Your contact information used to initiate the Software typically your e-mail address or phone number.
  • Optionally your name, if entered into the system
  • Your chat conversations
  • Records of video calls made, including other parties in the call, time and duration.
  • Records of photos made through the use of the Software
  • Records of any notes made by the End User during the call
  • Technical data, including your unique device ID, IP address, network and device performance and other information about your use of the Software.

PURPOSES OF PROCESSING

End User

By using SnapSurv, you agree to the End User collecting your data in their capacity as the personal data controller and you agree to SnapSurv processing the data.

SnapSurv

We will process the information set out above for the following purposes:

  • to enable and provide the Software and improve the Software, and to otherwise fulfil our obligations with regard to the agreements entered into with our End Users;
  • to improve and develop the Software;
  • to ensure the technical functioning of the Software and to prevent use of the Software in breach of the EULA;
  • to enforce the EULA, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary; and
  • to fulfil requirements by law.

LEGAL GROUND

The processing of Personal Data is based on our legitimate interests, which serves as the legal ground for the processing.

Our legitimate interests are (i) to provide our services to the End User; and (ii) to continually offer, improve and develop the Software. We are not able to fulfill our legitimate interests without processing some Personal Data.

In the balancing of interests between our legitimate interests, and your interests and rights and freedoms, it is considered that in your position as a Supporter in the Software is expected of you to use the Software as directed by the representative of the End User. By using the Software you confirm that you have no objections to us processing your Personal Data when providing the Software. Furthermore, we respect the value and integrity of Personal Data – therefore, we have implemented technical and organizational security measures to ensure the integrity and confidentiality of the Personal Data. The number of employees that processes Personal Data at SnapSurv is kept to a minimum, they are trained to process the Personal Data in accordance with our internal data protection policies, and they are subject to confidentiality undertakings. The types and amount of Personal Data that is processed, is the minimum data possible to enable us to fulfil our interests. The Personal Data will not be used for any other purposes than what is set out in this Privacy Policy and will not be used for additional purposes in the future. In light of this, we consider that the processing of Personal Data conducted by us does not infringe your rights and freedoms, and that our legitimate interests set out above are not incompatible with your interests. Please note that the End User’s processing of your Personal Data may be based on other legal grounds than what we have set out here.

DISCLOSURE OF PERSONAL DATA

We may share and disclose your Personal Data to our sub-contractors.

Your e-mail address and phone number may be disclosed to other users of the Software that you choose to connect with within the Software.

RETENTION OF PERSONAL DATA

The Personal Data is processed for the period during which the Software is provided to you. Upon termination of a user account, the Personal Data relating to such an account will be deleted within 3 months after the termination of the applicable customer agreement or within reasonable time after the 3 months period.

RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM

We can access, preserve and share your information in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations, if we have a good faith belief that the applicable law require us to do so.

This includes responding to legal requests from jurisdictions outside of the EU/EEA when we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

Information that we receive about you when you use our Software, can be accessed, preserved and retained for an extended period of time when it is the subject of a legal request or obligation, government investigation, or investigations concerning possible violations of our EULA or policies, or otherwise to prevent harm.

SOME OTHER THINGS YOU NEED TO KNOW

Change of Control

If the ownership of our business changes, we will transfer your information to the new owners so they can continue deliver our solution for remote guidance, including the Software. The new owner will still have to honour the commitments we have made in this Privacy Policy.

Notice of changes

If we make changes to this Privacy Policy, we will notify you by publication here. If the changes are material, we will provide you additional, prominent notice as appropriate under the circumstances and, where required under applicable law, ask for your consent.

Your Privacy Rights under Applicable Data Protection Laws

Applicable Data Protection Laws permits residents of the Member States to request details about what Personal Data is stored with us, the source of the data and the identity of parties to whom the data has been provided free of charge, as well as other information, without indicating any reasons.

You can object to the use of your Personal Data at any time. Nevertheless, please note that the End User’s processing of your Personal Data may be on other legal grounds than what we have set out in this Privacy Policy. In addition, you can request rectification, erasure or blocking at any time of any Personal Data. However, if we are under legal obligation to save the data, such data can only be blocked. Furthermore, we will assess all requests on a case by case basis and might in some cases not be able to adhere to your request.

To exercise the aforementioned rights in relation to us, or if you have any questions about our sharing practices, your rights under Applicable Data Protection Laws, or wish to have your Personal Data removed, please contact us at the following address: SnapSurv Ltd 2d, Station Yard, Thame, England, OX9 3UH. In order to ensure that you receive a swift response, please state in your letter your full name and, if applicable, your address and user name. Please note that you should sign the request in order to receive information of the processing of your Personal Data, and that you may be asked to verify your identity before any Personal Data is disclosed or information given.