EU-US PRIVACY SHIELD POLICY - SNAPCOMMS

SnapComms provides solutions that solve Internal Communication Challenges with SnapComms  Employee Communications Platform. The data collected by SnapComms is used to ensure the best outcomes and esperiences are realised by its customers and their end-users (Customers). Customers provide some of this data directly when engaging with the SnapComms website to download a trial or request a demonstration of the SnapComms Solution, install the SnapComms App through Google Play or the App Store or when contacting SnapComms for operational and technical support.

SnapComms complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and the United Kingdom transferred to the United States pursuant to Privacy Shield. SnapComms has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view SnapComms certification page, please visit https://www.privacyshield.gov/    

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, SnapComms is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

The privacy and protection of Customer data is important to SnapComms, accordingly, SnapComms respects individual privacy and values the confidence of its Customers and its service providers and business partners who are associated with the delivery of the SnapComms Solution such e.g. Microsoft Azure and SnapComms approved resellers. Not only does SnapComms store Personal Identifiable Information in a manner consistent with the laws of the countries in which SnapComms conducts business, SnapComms also has a tradition of adhering to the highest ethical standards possible in its business operations. SnapComms is subject to the investigatory and enforcement policies of the Federal Trade Commission, an independent agency of the United States government head-quartered in Washington DC. This EU-US Privacy Shield Privacy Policy Document sets forth the privacy principles that SnapComms follows with respect to the collection and transfer of Personally Identifiable Information from the European Economic Area (EEA) or the United Kingdom to the United States (US).

EU-US PRIVACY SHIELD

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable US companies to satisfy requirements under European Union law that adequate protection be given to Personally Identifiable Information transferred from the EEA to the US (EU-US Privacy Shield). The EEA has also recognized the EU-US Privacy Shield as providing adequate data protection (EU Data Protection Directive 95/46/EC). Consistent with SnapComms commitment to protect personal privacy, SnapComms adheres to the principles set forth in the EU-US Privacy Shield, specifically the 7 EU-US Privacy Shield Principles.


SCOPE

This EU-US Privacy Shield Privacy Policy Document (Policy) applies to all Personally Identifiable Information received by SnapComms in the US from the EEA or UK, in any format, including electronic, paper or verbal mediums.

DEFINITIONS

For the purposes of this Policy, the following definitions shall apply:

Agents means any third party that collects or uses Personally Identifiable Information under the instructions of and solely for the puposes of deliver the SnapComms Solution in the manner intended by SnapComms.

Customer means any online visitors, employees, customers, customers end-users, partners and any other entity or individual coming into contact with SnapComms, located in the EEA, for whom SnapComms hosts published content on infrastructure provisioned by SnapComms within Microsoft Azure environments in the United States.

Personally Identifiable Information, otherwise abbrevaited to PII, means any information or set of information that identifies or could be used by or on behalf of SnapComms to identify an individual. Personally Indentifiable Information does not include information that is encoded or anonymized, or is publicly available information that has not been combined with non-public Personally Identifiable Information.

SnapComms means SnapComms Inc a duly incorporate Delaware corporation (CN 3480043 / EIN 45-5352649) with registered office located at 601 South Figueroa Street, Suite 4050, Los Angeles, CA 90017, United States of America.


PRIVACY PRINCIPLES

NOTICE:

Through this EU-US Privacy Shield Privacy Policy Document, SnapComms provides notice to online visitors, employees, customers, customers end-users, partners and any other entity or individual coming into contact with SnapComms (Customers) with clear and accurate information about SnapComms policies, practices and procedures that pertain to the collection, use, retention, transfer, disclosure and handling (Use) of Personally Identifiable Information, and SnapComms compliance with relevant privacy and data protection acts including the United Kingdoms Data Protection Act 2018 .

SnapComms believes and recognizes that Customers have the right to be informed about any Personally Identifiable Information being collected about them and about the intended Use of that Personally Identifiable Information. SnapComms believes and recognizes that Customers have the right to determine whether they will allow the collection or other Use of their Personally Identifiable Information, to know the purpose of that collection and Use, and to unsubscribe or otherwise opt-out if they do not wish, or no longer wish, to have some or all of their Personally Identifiable Information collected, used at all, or used for a particular purpose (other than as expressly set forth herein, such as when necessary in connection with a transaction, employment or legal compliance obligations). SnapComms also believes and recognizes that Customers have the right to review individually-identifiable Personally Identifiable Information about them that SnapComms collects, retains or otherwise uses, and Customers have the right to have a means to update, correct and/or obtain a deletion of such Personally Identifiable Information (except to the extent SnapComms is required by law to maintain it).

Notice Of What SnapComms Does. SnapComms provides solutions to solve Internal Communication Challenges with SnapComms Employee Communication Platform (SnapComms Solution). SnapComms offers a range of digital communications channels to get employee attention, with the right message, to the right person at the right time. These channels include alerts (including desktop, mobile and video alerts), desktop wallpaper, lock screen, screensavers (and digital signage), desktop tickers, quizzes, surveys, and newsletters.

SnapComms has a presence on the web that includes www.snapcomms.com

SnapComms social media links include:

- https://www.linkedin.com/company/snapcomms/

- https://twitter.com/snapcomms

- https://www.facebook.com/SnapCommsLtd/

- https://www.youtube.com/channel/UCU-R7tO41Ae8QPhmRTd7zsA

Notice Of Where SnapComms Operates. SnapComms is a made up a of a group of three (3) companies operating out of the United States, the United Kingdon and New Zealand.

Notice About Personally Identifiable Information. For purposes of this EU-US Privacy Shield Policy Document, Personally Identifiable Information means any information relating to an identified or identifiable individual, either alone or in reasonable combination with other information available to SnapComms. It includes all: Personally Identifiable Information regarding Customers; Personally Identifiable Information regarding and identifiable to Customers to the extent it is subject to privacy law or privacy regulation provisions, protections or restrictions; and, non-public information regarding and identifiable to individuals to the extent it is subject to privacy or confidentiality provisions, protections or restrictions in, or incorporated into, written or electronic contracts entered into by or for SnapComms.

Notice About Collection And Use Of Personally Identifiable Information. As set forth in more detail below, SnapComms collects data to ensure the best outcomes and experiences are realised by its Customers when using the SnapComms Solution or engaging with the SnapComms website. Customers provide some of this data directly when engaging with the SnapComms website to download a trial of the SnapComms Solution, install the SnapComms App through Google Play or the App Store, when contacting SnapComms for operational and technical support, signing up to the SnapComms blog and/or other types of marketing communications or by completing a form on the SnapComms website.

SnapComms may also collect names, job titles, company names and contact details. SnapComms also records tracking behavior as to how Customers interact with the SnapComms website, by for example, using technologies like cookies which helps SnapComms identify which content is most relevant to Customers by measuring click-through rates and time-on-page to determine interest levels (marketing potential) of the website.

Customers have choices about the data SnapComms collect. When Customers are asked to provide personal data, such as name, job title and email address, they have the option to decline. If Customers choose not to provide this data, they may not, for example, be able to download a white paper, use a product or feature or access other collateral that may help them solve their internal communications challenges. 

CHOICE:

SnapComms provides its Customers with the opportunity to choose (opt-out) whether their Personally Identifiable Information is to (i) be disclosed to a third party, or (ii) be used for a purpose other than the purpose for which it was originally collected or authorized for use by the individual. SnapComms will provide its Customers with reasonable mechanisms to exercise their choices.

It is SnapComms policy that all Customers (and their data subjects) have opted-in to receive marketing related content and collateral.

SnapComms makes it easy for all Customers (and their data subjects) to withdraw their consent at any time and accordingly all marketing emails, include the option, in the footer, to unsubscribe from SnapComms marketing content and collateral.

SnapComms will provide an individual opt-out choice, or opt-in for sensitive data, before SnapComms shares Customer data with third parties other than SnapComms agents, or before SnapComms uses it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of any personal information that SnapComms may collect, please submit a written request to privacy@snapcomms.com.

ACCOUNTABILITY FOR ONWARD TRANSFER:

The EU-U.S. Privacy Shield Framework, HIPAA and other laws typically allow transfer of Personally Identifiable Information to a third party who is acting as a service provider, agent or Data Processor if the ultimate Data Controller takes the necessary steps to ensure privacy and security protections are assured. SnapComms may disclose Personally Identifiable Information to other persons, for example, in the following circumstances:

SnapComms may share and disclose Personally Identifiable Information when necessary for the purposes previously stated in this Policy to the following entities:

  • SnapComms Employees. When necessary for troubleshooting and technical support, SnapComms may disclose Personally Identifiable Information to its employees.
  • Customer Access. If required for business operations, SnapComms may disclose Personally Identifiable Information to authorized users of its Customers that have permission to access, modify or restrict access to Personally Identifiable Information.
  • Approved Suppliers And Third Party Services. Data is processed by HubSpot and Salesforce. You can view HubSpot’s security and data protection policy here. You can view Salesforce privacy policy here.
  • Business Partners who need to access Personally Identifiable Information in connection with the performance of requested services or solutions, or as otherwise appropriate in connection with a legitimate business need;
  • Service Providers who host or facilitate the delivery of online apps, training, seminars and webinars;
  • E-mail-Delivery Services and other technology providers;
  • Authorized Resellers / Distributors / Marketing Partners so they may follow up with Customers regarding products and/or services;

Examples of appropriate assurances that may be provided by Agents include contracts obligating Agents to provide at least the same level of protection as is required by the relevant EU-US Privacy Shield Principles, being subject to EU Data Protection Directive 95/46/EC, being EU-US Privacy Shield Certification, or being subject to another relevant European Commission standard (e.g. safe habour data hosting companies may be located in Canada). Agents will also be required to notify SnapComms if they make a determination that they cannot provide the same level of protection as stated above. Where SnapComms has knowledge that Agents are using or disclosing Personally Identifiable Information in a manner contrary to this Policy, SnapComms will take reasonable steps to prevent or stop its use or disclosure.

SnapComm's accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, SnapComms remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless SnapComms proves that it is not responsible for the event giving rise to the damage.

Please be aware that SnapComms may be required to disclose an individual's Personally Identifiable Information in response to a lawful request by public authorities, which includes complying with national security or law enforcement requirements.

Trans-Border Data Transfers / Flows. SnapComms is a Software as a Service company with technical systems and processes that cross various national and other jurisdictional borders. Personally Identifiable Information collected by SnapComms may be transferred across country, state, provincial and other jurisdictional borders, and stored, transported or processed in the US or any other country in which SnapComms operates for the purposes of data consolidation, storage, information management or any other relevant Use. Trans-border data transfers of Personally Identifiable Information are performed only if and as permissible by applicable law and, where required by applicable law, with the consent of Customers and their data subjects. SnapComms will handle all Personally Identifiable Information collected by SnapComms in a consistent manner, as described in this EU-US Privacy Shield Privacy Policy Document and in any applicable Supplemental Privacy Terms with Customers affirmative consent, even if the laws in some relevant countries or jurisdictions provide less protection for Customers Personally Identifiable Information. SnapComms privacy practices are designed and intended to help to protect Customers Personally Identifiable Information anyhere in the world.

SECURITY:

SnapComms will take reasonable precautions to protect Personally Identifiable Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

The SnapComms Solution include platform and software offerings. Technical and organisational security measures have been implemented to  coverall aspects of the SnapComms Solution in compliance with international regulations and requirements related to information security management system of organizations.

SnapComms Solution provides standardized instances in both Public Cloud and Private Cloud environments (Cloud Services) for which SnapComms manages the administration, deployment, operation, maintenance and security. including the processing of Personally Identifiable Information pursuant the terms contained within SnapComms Services Delivery Agreement. Customers utlizing Cloud Services in relation to the SnapComms Solution are responsible for assessing the suitability of the data security and privacy measures that SnapComms has implemented.

SnapComms specific management responsibilities for Cloud Services are set out in the relevant SnapComms Service Delivery Agreement. The data security and privacy measures utilized by SnapComms are designed to defend SnapComms Cloud Services against various risks including un-authorised access and un-authorised use of Customers data by incorporating configurable options and/or other services that restrict or block access and/or anonymizes or inhibits the collection of Personally Identifiable Information.

SnapComms security policies are reviewed as part of SnapComms Information Security Management System and refined as necessary to ensure current threats are sufficiently mitigated in accordance with updates of standards such as ISO 27001, ISO 27002, ISO 27017 and ISO 27018.

SnapComms employees are required to complete specific training related to information security and data privacy as part of the SnapComms Information Security Management System which is necessary for SnapComms in terms of retaining its compliance with data privacy, confidentiality and security standard and attestations.

Access Control. SnapComms limits access to Personally Identifiable Information to only those individuals who have an authorized purpose for accessing such information. SnapComms terminates access privileges and credentials following an individials change in role or termination of employment.

Data Encryption. SnapComms policies and procedures require that wherever practicable SnapComms uses encrypted connections for all electronic transfers of Personally Identifiable Information.

DATA INTEGRITY AND PURPOSE LIMITATION:

SnapComms will limit the collection and other use of Personally Identifiable Information to that which is reasonably needed for valid/legitimate business purposes or to comply with applicable laws. Any such data will be obtained by SnapComms only through lawful and fair means. When Customes use the SnapComms Solution, SnapComms want Customers to be assured that SnapComms is unequivocally respecting their privacy.

The Personally Identifiable Information SnapComms collects aboutCustomers when they use the SnapComms Solution is restricted to information Customers choose to provide through mechanisims that operate in accordance with this EU-US Privacy Shield Policy Document and any applicable Supplemental Privacy Terms. When SnapComms receives any Personally Identifiable Information from Customers , SnapComms will not share it other than for the purposes, and with other parties, as permitted through this EU US Privacy Shield Policy Document and applicable Supplemental Privacy Terms or if consent has been granted directly by its Customers.

Cookies. SnapComms use cookies to help SnapComms understand how website visitors are engaging with SnapComms website in order to improve the relevance of SnapComms marketing campaigns, collateral, webpages and call-to-action conversion tracking. SnapComms uses both session cookies and persistent cookies on the SnapComms website. This helps SnapComms optimize the content SnapComms produces for its Customers.  

Session cookies are temporary meaning they are not stored on within computer browsers once the session has ended. Session cookies are typically used as part of the login, authentication and session management flows of Software as a Service websites. Session cookies are also used to determine if website visitors are first-time visitors or are returning visitors.

Persistent cookies install on the computer within the web browser profile for a predetermined length of time. Persistant cookies are used to better understand vistor behaviours when using the SnapComms website and/or Customer behaviours when using the SnapComms Solution, including determining which areas of the SnapComms website and/or SnapComms Solution are favored, and how webpages are engaged with. Third party vendors who provide persistant cookie technologies include, but are not limited to, platforms such as Google Analytics and Hubspot.

SnapComms may also use cookies from these third-party vendors, (Google and Hubspot), for the purposes of marketing and promoting relevant offers and/or information to visitors through other websites and social media mediums after visitors have previoulsy engaged with the SnapComms  website.

SnapComms also displays some videos embedded on SnapComms website pages which use cookies to anonymously gather statistics on how visitors got to those pages and which videos were viewed.

While enabling these cookies is not strictly necessary for the SnapComms website to display content, it does provide visitors with a better browsing experience. Visitors have the option to delete or block these cookies, but in doing so may disable some features of the website so that it may not function as intended.

Cookie-related information is not used to identify Customers individually and the pattern data related to a visitors navigation through the website is fully under SnapComms control. Cookies are not used for any purpose other than those described above.

Note: If visitors entered the SnapComms website via hyperlinks from other websites, it is possible the other websites may use cookies to collect browsing history including the tracking of other websites that may have been previoulsy or subsequenly visited. SnapComms has no control over other websites use of cookies or the information they may collect.

If visitors do not wish cookies to catpture information when browsing websites, the visitors can apply browser settings to manage cookie policies and even disable cookies completely. Changing default cookie policies may disable some website functionality.

In connection with the SnapComms website (including e-mails and other electronic / digital communications), SnapComms may also use or allow analytics or third-party tracking services which use cookies, flash-cookies, web beacons or other tracking technologies to track legally-permissible non-individually identifiable Personally Identifiable Information about online visitors to the SnapComms website. When these services and related cookies, flash cookies, web beacons or other tracking technologies are used, the usage and volume statstics that are captured is persisted in aggregate form only and is used to manage website content and not for any other purpose.

The above policy covers the use of such tracking and analytics technologies by and for SnapComms only, and it does not cover or apply to the use of tracking or analytic technologies by any third party.

SnapComms may also use Personally Identifiable Information to help SnapComms to prevent and detect security threats, fraud or other malicious activity, and to ensure the proper functioning of the SnapComms solution and other services SnapComms may provide.

Web Beacons. A web beacon, which is a small image file on a web page that can be used to collect certain information from visitors computers, such as IP addresses, the date/time webpage content was viewed, and browser types as well as the presence of cookies applied previously by the originating server. The web beacon images, often transparent, are embedded as part of web pages. SnapComms uses web beacons to allow SnapComms to count the number of visitors who have navigated to certain pages and to generate statistics about how the SnapComms site is used. SnapComms only uses web beacons in accordance with applicable laws and does not use web beacons to access Personally Identifiable Information.

Unlike cookies, it is not possible to manage or disable web beacons. However, applying browser settings to manage cookies, or to prompt visitors to submit a response upon detection of a cookie, will inhibit web beacons from tracking web browser activity. Web beacons may still anonymously record visits from IP addresses but information tracked by cookies will not be recorded.

In some of the Customer newsletters dessimnated by SnapComms and other related Customer communications, SnapComms may monitor recipient actions such as email open rates through embedded links within the body of the communication. SnaComms collects this information to gauge Customers interest in the communication and to enhance Customers future experiences.

How SnapComms Use Personally Identifiable Information. SnapComms may use Personally Identifiable Information for the following purposes:

To Respond To Customer Requests. These requests may include the scheduling of a product demostration, attendance of a webinar, the provision of a quote and use of the SnapComms Solution during a trial period.

To Maintain Or Upgrade A System. SnapComms technical staff may require periodic access to services data to monitor system performance, test systems, run support diagnostics, verify configurations and usage levels, and develop and implement updates, upgrades and patches to systems. This may include providing technical support which may be facilitated through the use of a customer support portal. Any temporary copies of services data created as a necessary part of this process are maintained only for periods of time relevant to and necessary for purposes of support.

To Address Performance And Fix Issues. On occasion, SnapComms may develop new versions, patches, updates and other fixes to the SnapComms Solution such as security patches to address newly discovered vulnerabilities. In accordance with the terms of SnapComms Service Delivery Agreement or in order for such services to be performed, SnapComms may require remote access to Customers computers, as permitted under the terms of the applicable SnapComms Service Delivery Agreement, to troubleshoot and solve performance related issues.

To Meet Legal Requirements. SnapComms may be required to provide certain Personally Identifable Information to comply with legally-mandated reporting, disclosure, or other legal process requirements, which satisfy requirements to disclose Personally Identifiable Information in response to lawful requests by public authorities, which may include meeting national security or law enforcement requirements.

ACCESS AND RECOURSE

The architecture of SnapComms Cloud Services maintains logical separation of Customer data through internal rules and measures which separate data processing such as inserting, modifying, deleting and transferring of data. Access to Customer data, including any Personally Identifiable Information, is retsricted to authorized employees of SnapComms only and then only in accordance with principles of segregation of duties, strictly controlled under identity and access management policies and monitored in accordance with SnapComms internal privileged user monitoring and auditing programs.

SnapComms privileged access authorisation is individual, role based and subject to regular validation. Access to Customer data including any Personally Identifiable Information is restricted to the level required to deliver services and support to Customers.

Transfer of data within SnapComms internal network takes place on wired infrastructure and behind firewalls.

Upon request or service termination, in accordance with the terms of SnapComms Service Delivery Agreements, Customers data including any Personally Identifiable Information is rendered unrecoverable in conformity with National Institute of Standards and Technology (NIST) guidelines for media sanitization unless other overriding legal requirements apply.

Pursuant to the Privacy Shield Frameworks, EU and UK individuals have the right to obtain SnapComms confirmation of whether SnapComms maintains personal information relating to its Customers in the United States. Upon request, SnapComms will provide individuals with access to the personal information that SnapComms holds about them. Individuals may also correct, amend, or delete the personal information SnapComms holds about them. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@snapcomms.com. If requested to remove data, SnapComms will respond within a reasonable timeframe.

ENFORCEMENT AND LIABILITY:

SnapComms will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any SnapComms employee that SnapComms determines to be in violation of this Policy will be subject to disciplinary action up to and including termination of employment.

SnapComms agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles.  SnapComms acknowledges that its failure to provide an annual self-certification to the US Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

DISPUTE RESOLUTION:

In compliance with the Privacy Shield Principles, SnapComms commits to resolve complaints about individuials privacy and SnapComms collection or use of their personal information transferred to the United States pursuant to Privacy Shield. European Union and United Kingdom individuals with Privacy Shield inquiries or complaints should first contact SnapComms by email at privacy@SnapComms.com

SnapComms will investigate and attempt to resolve complaints and disputes regarding Use and disclosure of Personally Identifiable Information by reference to the principles contained in this Policy. For complaints that cannot be resolved between SnapComms and the complainant, SnapComms has agreed to participate in the following dispute resolution processes pertaining to the investigation and resolution of complaints to resolve disputes pursuant to the EU-US Privacy Shield Principles:

SnapComms has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If individuals do not receive timely acknowledgment of their complaint, or if an individuial complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to any individual who requires it.

If an individuals Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, the individual may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

LIMITATION ON APPLICATION OF PRINCIPLES:

Adherence by SnapComms to the EU-US Privacy Shield Principles may be limited to (i) the extent required to respond to a legal or ethical obligation; (ii) the extent necessary to meet national security, public interest or law enforcement obligations; (iii) the extent expressly permitted by an applicable law, rule or regulation; and (iv) the extent that SnapComms has limited or no control over the actions of its Customers regarding the use of Personally Identifiable Information that SnapComms has collected.

PRIVACY

SnapComms recognizes the importance of maintaining the privacy of information collected through the SnapComms Solution and has created its own specific Privacy Policy governing the treatment of Personal Identifiable Information that SnapComms has collected. SnapComms Privacy Policy can be found at: https://www.snapcomms.com/privacy-policy#privacy. This EU-US Privacy Shield Policy Document is a privacy template to be used by SnapComms Customers. With respect to Personally Identifiable Information that is transferred out of the European Economic Area and the United Kingdom into the United States, the Privacy Policy is subordinate to this EU US Privacy Shield Policy Document.


CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the SnapComms by mail to:

SnapComms Inc.

601 South Figueroa Street,

Suite 4050

Los Angeles, CA 90017

Tel: +1 805 715 0300

Or by e-mail to privacy@snapcomms.com

CHANGES TO THIS EU-US PRIVACY SHIELD PRIVACY POLICY DOCUMENT

This Policy may be amended from time to time, consistent with the requirements of the EU-US Privacy Shield Principles. A notice will be posted on the SnapComms web page (www.snapcomms.com) for 60 days whenever this EU-US Privacy Shield Privacy Policy Document is changed in a material way.

EFFECTIVE DATE: November 13, 2019