Privacy Policy

Last Updated: April 27, 2025

At Snap.photo, your privacy and the protection of your data is our top priority. All data collected, both personal and non-personal, is protected with high standards.

Snap.photo is operated by Nexobe Inc DBA Snap.photo.

As we believe your personal data is and should always remain yours, we have a strong privacy policy in place. This policy aims to comply with relevant data protection regulations, including principles reflected in the European General Data Protection Regulation (GDPR) and applicable laws in Illinois, USA.

The contents of this privacy policy are applicable to the website app.snap.photo and use of the services provided by this site to the user (the "Service").

1. Notice

Whenever we request information that can be used to personally identify you, you will explicitly be asked to provide it and/or give us permission to use it. This information is requested by our system whenever confirmation of your permission is required to continue (e.g., asking for permission for the use of cookies when you visit our site, asking for your payment information when you sign up).

2. Your Consent

You will always have the choice whether to give us permission to process your information or not.

With data that is not essential to the core functionality of our services (e.g., cookies for marketing purposes, optional profile information) you are able to decline permission without any consequences to your access to Snap.photo.

If you choose to decline the use of essential information for the use of our services (e.g., essential cookies, payment information, email address), we may be unable to give you access to aspects of Snap.photo that require such information to function. Whether any given information is essential to our services or not will be indicated when you are asked to provide or give permission for us to use such information.

By agreeing to this privacy policy and providing us with your personal information you consent to us processing said information as described in this privacy policy and our Terms of Service.

3. Usage

3.1. Data We Collect

We collect various forms of information you provide to us. This includes:

Personally Identifiable Information (PII): Information which could directly be used to identify you, such as your name (if provided), email address, and payment information (processed via our secure third-party payment processor).
Uploaded Photos: Images you upload for the purpose of generating AI Headshots, as defined in our Terms of Service.
Account Information: Information related to your account settings and preferences.
Usage Data (Optional): We may collect data based on your usage of our platform via optional cookies, if you consent. This data is typically aggregated and anonymized, meaning it cannot reasonably be traced back to you.

3.2. How We Use Your Data

We use your information for the following purposes:

Provide you with access to Snap.photo's features, including generating AI Headshots from your Uploaded Photos.
Process your payments securely.
Communicate with you about important information regarding Snap.photo (e.g., service updates, security notices), as well as any other information you choose to opt-in to receive (e.g., newsletters).
Contact you regarding the status of your orders, support requests, or for other reasons necessary to provide the Service.
Analyze anonymized usage data (if consent is given via cookies) to improve our services and user experience.
Comply with legal obligations and enforce our Terms of Service.

3.3. Sharing Your Data

We do not sell your personal information. We may share your information only in the following limited circumstances:

With Service Providers: We may share necessary information with third-party partners who help us operate the Service (e.g., payment processors like Stripe, hosting providers, email service providers). These partners are only provided with the information absolutely necessary to perform their function and are obligated to protect your data.
For AI Headshot Generation: Your Uploaded Photos are processed by our AI Headshot Generator to create your AI Headshots. As stated in our Terms (Section 8.3), we do not use your Uploaded Photos to train our AI models without your explicit consent.
Anonymized Data: We may share aggregated and anonymized usage data with third parties for analysis or marketing purposes. This data does not identify you personally.
Legal Requirements: If required by law, subpoena, court order, or other legal process, we may disclose your information to law enforcement or other government entities. We may do so without your permission or notice if legally required or permitted.
Business Transfers: In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of the transaction, subject to the commitments made in this Privacy Policy.

Outside of these circumstances, we will not share your personally identifiable information with any third party without your explicit permission.

4. Retention of Information

We retain your information only as long as necessary to provide you with our services, comply with legal obligations, and resolve disputes.

Account Information & PII: Retained while your account is active. Will be deleted upon account deletion request or after a period of inactivity as required by law, subject to legal holds.
Uploaded Photos: As per our Terms (Section 8.3), Uploaded Photos are typically deleted from our active servers within 7 days of upload. You may have the option to delete them sooner via your account settings.
Generated AI Headshots: Retained to allow you access via your account. You can typically manage and delete these through your account interface.
Payment Information: We do not directly store your full credit card details. Our payment processor (e.g., Stripe) handles this and retains information according to their own policies and legal requirements.

Once deletion is requested and confirmed (e.g., via account deletion), your personally identifiable information will be removed from our active systems within a reasonable timeframe (e.g., 14-30 days), unless retention is required for legal reasons (e.g., tax records, legal holds). Anonymized data may be retained indefinitely for analytical purposes.

5. Your Rights

Depending on your location and applicable laws (like GDPR), you may have certain rights regarding your personal information. We aim to honor these rights for all users. These rights may include:

Right of Access: You may be entitled to request a copy of the personally identifiable information we hold about you.
Right to Rectification: You may be entitled to have inaccurate personal information corrected.
Right to Erasure ('Right to be Forgotten'): You may be entitled to request the deletion of your personal information under certain conditions.
Right to Restriction of Processing: You may be entitled to request that we limit the processing of your personal information under certain conditions.
Right to Data Portability: You may be entitled to receive your personal information in a structured, commonly used, and machine-readable format, or have it transferred to another party, under certain conditions.
Right to Object: You may have the right to object to the processing of your personal information, particularly for direct marketing purposes. If you object to processing for direct marketing, we will stop processing your data for that purpose.

If you would like to exercise any of these rights, please contact us via the email address provided at the end of this policy. We will respond to your request in accordance with applicable laws. We may need to verify your identity before processing your request.

6. Opting Out

In addition to our core services, we may offer optional communications like newsletters or surveys. You can opt-out of these communications at any time. For emails, use the unsubscribe link typically found at the bottom. You may also be able to manage communication preferences in your account settings. Note that you cannot opt-out of essential service-related communications (e.g., account security alerts, purchase confirmations).

7. Security of Your Information

We take the security of your data seriously and implement reasonable administrative, technical, and physical measures to protect it from unauthorized access, loss, misuse, alteration, or destruction. These measures may include:

Using security software and monitoring tools.
Employing TLS (Transport Layer Security) encryption for data transmission between your device and our servers.
Implementing email security standards like DKIM, SPF, and DMARC where applicable.
Regular security assessments and updates.

However, please note that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

8. Changes to This Policy

We reserve the right to make changes to our privacy policy. When we make material changes, we will notify you, either through the Service interface, in an email notification, or through other reasonable means, typically at least 14-30 days before the changes take effect. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Service after the effective date of the revised policy constitutes your acceptance of the changes. If you do not agree with the new policy, you should stop using the Service and may request deletion of your account.

9. Contact

If you have any questions about this Privacy Policy, wish to exercise your rights, or need to contact us for any other privacy-related reason, please reach out to us via the following email address: [email protected].