SnapClose

Privacy Policy

THIS PRIVACY POLICY CONTAINS IMPORTANT INFORMATION PERTAINING TO THE PRIVACY POLICY AND PRACTICES OF CORNERSTONE MANAGEMENT SOLUTIONS INC (“SnapClose”, “we” or “us”). THIS PRIVACY POLICY SUPPLEMENTS SnapClose’s PRIVACY POLICY AND APPLIES ONLY TO THE WWW.SNAPCLOSE.COM WEBSITE (“WEBSITE”). IN THE EVENT OF ANY CONFLICT BETWEEN THIS PRIVACY POLICY AND THE PRIVACY POLICY, THE PROVISIONS OF THIS NOTICE SHALL CONTROL.  THIS PRIVACY POLICY DOES NOT APPLY TO ANY OTHER THIRD PARTY WEBSITES THAT MAY BE ACCESSIBLE OR THAT MAY BE LINKED FROM THE WEBSITE.

Please be sure to read this Privacy Policy before using this Website or submitting information to us through this Website.

This Privacy Policy contains important information on how and why SnapClose collects, stores, uses, and shares your personal information. It also explains your rights in relation to your personal information and how to contact SnapClose or supervisory authorities in the event you have a complaint.

Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) name, email address, and Internet Protocol Address 
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. name, telephone number 
Characteristics of protected classifications under state or federal law. Age, sex and gender
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) None.
Biometric information None
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) Time of visit, pages visted, time spent on webpages, referring site details, type of web browser, type of operating system, flash version, javascript support, screen resolution and screen color processing ability, network location and IP address
Geolocation data approximate location (e.g., city, country, continent) based on IP address
Audio, electronic, visual, thermal, olfactory, or similar information None
Professional or employment-related information None
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) None
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes None

We may also collect such other information you voluntarily provide to us when you contact us.  You are responsible for providing SnapClose with accurate and complete information, and for contacting SnapClose if correction of the information is required. 

This personal information is required to respond to your inquiries and to provide products and/or services to you. If you do not provide personal information SnapClose asks for, it may delay or prevent SnapClose from responding to your inquiries or providing products and/or services to you.

Use of cookies and other tracking systems

Cookies, log files, and pixel-tags (Web beacons) are technologies used by the SnapClose Website for various purposes. Your browser allows us to place some information (session-based IDs and/or persistent cookies) on your computer’s hard drive to identify information about the browser you are using to tailor web page display. SnapClose may also use these cookies to connect the information collected to the personal information you may voluntarily provide, improve the quality of its Website, identify user preferences, improve search results, and track user browsing trends. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. Please note that cookies are not required to access and use our Website, however, if your browser is set to reject cookies some Website functionality may be lost. The Help section of your browser will tell you how to prevent your browser from accepting cookies or to delete cookies that are already on your computer (persistent cookies).

Information gathered by third party cookies and similar technologies is subject to the privacy policies of such third parties.

We gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  While not all of the information that we collect from visitors is personally identifiable, it may be associated with personal information that visitors provide to us through our Website.

Google Analytics. We use Google Analytics for website traffic data collection and analysis. In order to track your session usage, Google drops a cookie with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. Google also collects your IP Address, but does not disclose it to us. We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long as described in this Privacy Policy. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have (or ask us to delete any Google Analytics data) please delete your Google Analytics cookies, contact us (see How to Contact Us below) and/or install the Google Analytics Opt-Out Browser Add-On.

Google Remarketing.  We use Google AdWords Remarketing to advertise SnapClose across the Internet, in particular on the Google Display Network.  AdWords remarketing will display ads to you based on what parts of the Website you have viewed by placing a cookie on your web browser.  This cookie does not in any way identify you or give access to your computer or mobile device.  The cookie is used to indicate to other websites that you have visted a particular webpage which information is used to display ads related to that page.  Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.

If you do not wish to see ads from SnapClose you can opt out by:

  1. Opting out of Google’s use of cookies by visiting Google’s Ads Settings; or
  2. Opting out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Do Not Track. We and third parties who place cookies on your browser also may use technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We and such third parties may not honor web browser “do not track” signals and other comparable mechanisms that enable consumers to exercise choice about behavioral tracking.

Right to Opt-Out.  You have the right to opt-out of receiving promotional communications from us at any time by updating your email preferences by using the “Unsubscribe” link found in the emails.  You may also update, modify or correct the information or request that such information be removed from our databases by contacting us (see How to Contact Us below).  

If you would like to opt-out of allowing Google Analytics data to be collected, delete your Google Analytics cookies and/or install the Google Analytics Opt-Out Browser Add-On.  We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

Other than the right to opt-out of as described above, the only way to opt-out of the terms of this Privacy Policy is to not use the Website and not to request products and/or services from SnapClose.

Who We Share Your Personal Information With. We routinely share personal information with:

  • Our affiliates;
  • Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses and delivery companies;
  • Other third parties we use to help us run our business, such as Google (via use of Google Analytics), marketing agencies or website hosts; and
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have not sold to third parties any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties (see Who We Share Your Personal Information With above) the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household: 

  • Identifiers (e.g., a real name, unique personal identifier, online identifier, Internet Protocol address, email address,or other similar identifiers);
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number.
  • Characteristics of protected classifications under state or federal law;
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement); and
  • Geolocation data.

Sale of Personal Information. Except as set forth in this privacy policy, we do not sell or disclose personal information to third parties.  We may disclose such personally identifiable information when we believe in good faith that it is required to be disclosed to protect our rights, protect your safety or the safety of others, investigate fraud, by law or by an appropriate law enforcement or governmental authority.

Links to Other Websites. Our Website includes links to other websites whose privacy practices may differ from those of SnapClose.  If you submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

How We Use the Information We Collect.  

We use the information we collect in order to improve the content and usability of the Website.

We also use such information to respond to your inquiries and to provide you with products or services you request.

We may also periodically send promotional emails about our products and services to visitors who provide their email information. SnapClose uses an agent to assist with its marketing campaigns. The agent is bound by a contractual agreement which covers security and limits the use of your personal information to the intended SnapClose communications. You may elect to be removed from any future communications by confirming your preferences via a link at the bottom of the communication or by contacting us (See How to Contact Us below).

Information Security. SnapClose takes various security measures to protect information received online. Except as otherwise provided in this Privacy Policy, access to information stored on our servers is restricted to SnapClose employees or third parties who need to know such information to perform a specific job on SnapClose’s behalf.

Although SnapClose makes a genuine effort to ensure the security of activities conducted on this Website, no transmission over the Internet, or method of electronic storage, is completely secure. Accordingly, SnapClose cannot and does not guarantee that any activities conducted on this Website will be absolutely secure.

Information storage.  Information may be copied, stored, and retained on our database servers or as part of our normal backup processes. Servers and backup information is subject to physical, electronic, and managerial security measures and access is restricted to authorized IT associates.

Social Media Widgets.  Our Website includes social media widgets, such as the share this button or interactive mini-programs that run on our Website. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

Children Under the Age of 18.  The Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect information from children under 18.  If you are under 18, do not provide any information on or through this Website. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us (see How to Contact Us below).

Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You You have the right to know:
• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information, if any; and
• The specific pieces of personal information we have collected about you.
Please note that we are not required to:
• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
• Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. If we change this Privacy Policy to allow for the sale of personal information in the future, we will provide you to opt-out of the sale of your personal information, by visiting our homepage and clicking on a Do Not Sell My Personal Information link to which we will provide the URL here.  If you would like to opt-out of the disclosure of your personal information, please contact us (see How to Contact Us below).  
Right to Deletion Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy or if you have any questions about this Privacy Policy or the information we hold about you, please contact us (see How to Contact Us below).  

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email, phone or in writing, you will need to provide us with:

  • Enough information to identify you; and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Changes to This Privacy Policy. This Privacy Policy was published on 12/15/2020 and last updated on 12/15/2020. We may change this Privacy Policy from time to time–when we do, we will inform you via our website or other means of contact such as email.

How to Contact Us. Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.  You can find contact information for SnapClose at https://snapclose.com/contact-us/.

Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see How to Contact Us above).