Last Updated: August 17, 2026

We, at Snappy App, Inc., together with our affiliated companies (collectively: “we”, “us” or “our”) put great efforts to make sure that we secure personal data related to you and use it properly.

The term “personal data” refers to any information relating to an identified or identifiable natural person. This notice applies to personal data about you (“you”) that we collect, process, use, and retain in connection with:

• your use of our websites (“Websites”), available at: www.snappy.com and www.snappygifts.com, and any of their sub-domains, including any data you provide through registration and contact pages (“Website Visitor”). See additional details below on the various types of end-users to which this privacy notice applies below;
• our marketing activities, including registrations as part of webinars, conferences, events, demo requests, emails, etc.;
• your use of our gifting platform (“Services”) to facilitate the sending of gifts (“Gift Sender”), either on your own behalf or as an end-user facilitating the sending of gifts on behalf of our customers (each, a “Customer”); and
• your use of our Services when receiving a gift from a Gift Sender (“Gift Recipient”).

We apply a baseline set of privacy standards for all users, regardless of where they use our Services from. However, as privacy laws vary significantly by territory, to ensure alignment with local requirements this notice is divided into 2 parts:

• Our Global Privacy Notice. The first chapters to this notice apply to all recipients and users of our Services worldwide and covers our general privacy practices.
• Processing Under Specific Laws. The last chapter (Processing Under Specific Laws) contains territory-specific supplements that apply only if such territory’s regulatory framework applies to our processing of personal data about you.

The following Summary will provide you with a quick and clear view of our practices.

Please take the time to read our full privacy notice, and if you do not agree with its terms, please do not access or otherwise use the Website and Services.

NOTICE SUMMARY

**What Types of Personal Data Do We Process?** We collect and process personal data related to you as relevant and necessary in connection with the type of interaction you have with us. Depending on the type of your interaction with us, such personal data includes: your name and contact details, usage data, marketing preferences, payment information, work-related information, and other information you provide us.

Why Do We Process Personal Data? We use personal data to provide you with and maintain the Websites and Services, send you related notifications and marketing-related messages, solicit your feedback, provide you with support, and to continue developing and making our Websites and Services better.

Our Use of Artificial Intelligence. We use artificial intelligence (AI) systems to support our business operations and the provision of our services. The use of these systems is subject to this Privacy Notice, including with respect to the purposes of processing, sharing, security, and your rights.

With Whom Do We Share Personal Data? We disclose personal data related to you to certain members of our staff, external consultants, our affiliates, our agents, our service providers acting as processors or sub-processors, or as otherwise instructed by you or our customers. We will also share personal data in connection with a merger, acquisition, or any other structural change, which will require us to disclose personal data related to you to another entity. All such parties are subject to this privacy notice or are contractually bound to keep personal data related to you confidential and appropriately secure.

How Long Will We Retain Personal Data? We retain personal data for different periods of time, depending on the purposes for processing the data, our legitimate business purposes, and pursuant to legal requirements under applicable law.

What Are My Choices and Rights? You have choices and rights over how we use personal data related to you in connection with providing you with the Websites and Services. Such choices and rights include opting out of marketing and service communications, our use of cookies that are not essential to our Websites or Services operation, request deletion of your account, request access to personal data we process about you and its deletion if you find it to be inaccurate, incomplete or outdated. You may also be entitled to additional privacy rights under the laws of specific territories. For additional details, see Processing Under Specific Laws. You can contact us at [email protected] to exercise any of the above choices and rights.

Where Do We Store Personal Data? We use cloud-based services to store, process, and access personal data in the European Economic Area, the United States, and in other regions to support the Website and Services. These service providers provide us adequate privacy, security, and confidentiality commitments.