DATA PROTECTION AND PRIVACY POLICY 

Snaaap Pte. Ltd. (referred to as “SNAAAP”, “we” or “us” in this Data Protection and Privacy Policy) is the consumer empowerment platform that allows users to Snaaap, Shop, and Share. As part of our services, we have partnered with various organisations and developed a revolutionary app that allows you to empower your life’s interactions. Snaaap is committed to respecting and protecting your privacy online. This Data Protection and Privacy Policy explains our practices regarding the collection, use, disclosure and transfer of your personal data. 

This Data Protection and Privacy Policy is designed to assist you in understanding how we collect, use and/or disclose the personal data you provide to us for the use of the App, as well as to assist you in making an informed decision before providing us with any of your personal data. You also acknowledge and agree that your access to and use of the App is subject to this Data Protection and Privacy Policy and the App Terms of Use. The Terms of Use are expressly made a part of this Data Protection and Privacy Policy. This Data Protection and Privacy Policy does not apply to personal data we collect when you purchase products through our partner organisations or otherwise. 

By accessing and using the App, you hereby agree to be bound by the terms of this Data Protection and Privacy Policy. We may revise or update this Privacy Policy at any time by posting a revised/an updated version on the Platform. Unless stated otherwise, any revision or update takes effect immediately. Your continued access and/or use of our Platform and/or Service or dealing with us after a revision or update to this Privacy Policy constitutes your binding acceptance of the revised or updated Privacy Policy. 

If you, at any time, have any queries on this Data Protection and Privacy Policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (whose contact details are set out below). 

It is necessary for us to collect and process your personal data. If you do not provide us with the data required, or do not consent to this Data Protection and Privacy Policy or any amendments to this Policy, we may not be able to render all services to you and you may be required to terminate your relevant agreement and/or stop accessing or using the Snaaap platform. 

1. Information We Collect

If you wish to use or access the App, we will require you to provide us with your personal data and/or we will collect your personal data from independent databases and platforms operated by third parties (including but not limited to Facebook, Google, and other available sources.). Such personal data will include but is not limited to your name, identity card/passport number, address, email address, contact number and information relating to Your Social Profile. 

2. Purposes for Collection, Use & Disclosure of Personal Data

2.1. We will need to collect, use, disclose and/or process your personal data and other information relating to Your Social Profile for one or more of the following purposes: 

(a) to process, administer and/or manage your App account with us and the use of the App; 

(b) operating, maintaining and updating the App; 

(c) providing you with updates and information relating to your interactions with our partner organisations; 

(d) providing you with information and/or updates on products, services and promotions offered by us and selected third parties which may be of interest and benefit to you, including personalised content and information such as online advertisements in the App or other forms of marketing from time to time. 

(collectively, the “Purposes”) 

2.2. Your personal data may be disclosed to our affiliates and third-party service providers, whether sited in the countries we operate or outside of such countries, for one or more of the Purposes. 

2.3. For the avoidance of doubt, in the event that the local jurisdiction personal data protection law permits us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply. 

2.4 We may also use and process your personal data for marketing and promotional purposes, such as to send you information on any products, services, events, or campaigns which may be of interest to you. This includes sending of seasonal messages, notification and invitation to activities organised by us and/or our selected third parties, processing of your registration for our services, and to share your personal data within our organisation and to our selected third parties who may communicate with you with regards to specific products, services, events, or campaigns. 

2.5 You have the right at any time to request us to stop sending you any marketing and promotional materials. If you unsubscribe from such materials, we may still send you non-marketing and promotional communications, such as those about your account, about the platform, or our ongoing business partnerships. 

2.6 If you are a Snaaap member, your user profile information such as your username will be used to identify you when using the platform. Your username may be displayed in various areas such as reviews, ratings, leaderboards, and other social networking features. We will not disclose or share your email address and other information without your consent. 

2.7 We may also use, process and share non personally identifiable aggregated data with third parties for data analytics and to further improve and enhance our offerings. 

3. Request for Access and/or Correction of Personal Data

You may request to access and/or correct your personal data currently in our possession or under our control at any time by submitting your request to the contact details listed below at section 6.2: 

4. Request to Withdraw Consent

4.1. You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control at any time by submitting your request to the contact details listed below.  

4.2. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated in your request. 

5. Administration and Management of Personal Data

5.1. We will take appropriate measures to keep your personal data accurate, complete and updated. 

5.2. We will also take commercially reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control. 

5.3. We will also take commercially reasonable efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes. 

5.4 To the extent that the prevailing Data Protection and Privacy Laws of the countries allow, you have the right to request for access to, a copy of, or to update or correct your personal data held by us. We may charge a small fee (as permitted under the applicable law) to cover the administration costs involved in processing your request.  

6. Complaint Process

6.1. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the Singapore Personal Data Protection Act 2012 (“PDPA”), we welcome you to contact us with your complaint or grievance. 

6.2. Please contact us through one of the following methods with your complaint or grievance: 

(a) Email address : info@snaaap.com
(Attention it to the ‘Data Protection Officer’) 

(b) Office address : 7 Lorong 4/48A, 46050 Petaling Jaya, Selangor, Malaysia.
(Attention it to the ‘Data Protection Officer’) 

6.3. Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff to handle. For example, you could title the subject header as “PDPA Complaint”.

6.4. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly. 

7. Updates on Data Protection and Privacy Policy 

7.1. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

7.2. We reserve the right to amend the terms of this Data Protection and Privacy Policy at our sole and absolute discretion from time to time. By continuing to use and access the App, you hereby agree to be bound by the terms of such amended Data Protection and Privacy Policy. 

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