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Privacy Policy

Date of last revision: December 1, 2014

This privacy policy applies to users of the snapd website (the “Site“) which is a part of SNAPD INC. and the family of companies owned and operated by SNAPD INC. (collectively “SNAPD“). This privacy policy is intended to inform you about the information that is collected from you when you visit the Site; how this information may be used and disclosed; how you can control the use and disclosure of your information; and how your information is protected.

Snapd.com is not just a website. It is also a service for sharing your information on snapd-enhanced applications and websites. You can control how you share information with those third-party applications and websites through your application. You can also limit how your friends share your information with applications through your privacy settings.

Snapd.com is a free service supported primarily by advertising. We will not share your information with advertisers without your consent. We allow advertisers to select characteristics of users they want to show their advertisements to and we use the information users share with us to serve those advertisements.

This Privacy Policy is incorporated into and subject to the terms of our Terms and Conditions. Terms defined in the Terms and Conditions have the same meanings herein. We reserve the right to amend this Privacy Policy at any time, with or without notice. If there are material changes to this Privacy Policy, we will notify you by placing prominent notice on the Site and/or by email. When we post changes to this Privacy Policy, we will also revise the “last updated” date. We encourage you to periodically review this Privacy Policy.

1. Consent

Your knowledge and consent is required for the collection, use or disclosure of personal information, unless a legal exception to consent exists. In determining the appropriate form of consent, we take into account the sensitivity of the personal information and the reasonable expectations of its customers. You may withdraw consent at any time, subject to legal or contractual restrictions and your reasonable notice. We will inform you of the implications of withdrawing consent.

You confirm that any information provided by you to us in accordance with the conditions contained in this statement and our Terms and Conditions is supplied by you voluntarily and you confirm that SNAPD has your express consent to use the information as indicated in our User Agreement including this Privacy Statement, in accordance with applicable laws in your jurisdiction.

By sharing content on our Site or through our Services, you consent to our use of that content in accordance with the Terms and Conditions. By using our websites, you agree to be bound by this statement and our Terms and Conditions. If you do not agree with any of these terms, please do not use our websites. By using or participating in the Site or using its Services, you consent to the data practices described in this Privacy Policy and agree to be bound by this Privacy Policy and to our User Agreement.

2. Scope

This privacy policy applies all of snapd and the Site. It does not apply to information collected through any other website or to the practices of companies that SNAPD does not own or control. Please note that the Site may contain links to other websites. If you click on a link to another website, this privacy policy will not apply to any information collected on that website. We are not responsible for the privacy practices of other websites, and we recommend that you read the privacy policies of each website that you visit.

3. What information the Site collects

We limit the personal information that we collect to what is necessary for the purposes that we have identified. This information may be communicated orally, in writing, or electronically.

No information from children under age 13. If you are under age 13, please do not attempt to register for snapd or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will endeavor to delete that information as quickly as possible. If you believe that we might have any information from or about a child under age 13, please contact us as soon as possible.

Parental participation. We strongly recommend that minors 13 years of age or older ask their parents for permission before sending any information about themselves to anyone over the Internet and we encourage parents to teach their children about safe internet use practices.

The types of information that we collect include:

Information you provide directly to us:

When you sign up for snapd you provide us with your name, email address, postal address, phone number, gender, and birth date. During the registration process we give you the opportunity to provide additional profile information, such as where you went to school and where you work, and to add a picture of yourself, to help your friends connect with you. In some cases we may ask for additional information for security reasons or to provide specific services to you. Once you register you can visit your profile at any time to add or remove or edit personal information about yourself. You can add basic information about yourself, such as information about your hometown, family and relationships. You can also add other information about yourself including your activities, interests, contact information, as well as more information about your education and job history.

When you use certain Site functions, such as when you register for certain services, post comments, access certain content or features, or directly contact the Site, we may ask you to provide information, including:

• Registration and contact information;

• username and password;

• information posted in community discussions and other interactive online features;

• search queries conducted on the Site; and

• correspondence you send to us.

Content . One of the primary reasons people use snapd is to share content with others. Examples include when you upload or take a photo, upload or record a video, share a link, create an event or a group, make a comment, write something on someone’s profile-board, write a note, or send someone a message. If you do not want us to store metadata associated with content you share on our Site or other third party sites (such as photos), please remove the metadata before uploading the content.

Transactional Information . We may retain the details of transactions or payments you make on snapd such as when you purchase or offer for sale event tickets. However, we will only keep your payment source account number with your consent.

Friend Information . We offer contact importer tools to help you upload your friends’ addresses so that you can find your friends on the site, and invite your contacts who do not have snapd accounts to join. If you give us your password to retrieve those contacts, we will not store your password after you have uploaded your contacts’ information. Additionally, the Site may allow you to forward certain items posted on Site or links to Site features by email, mobile phone number or Instant Messenger to other parties who you believe may be interested. If you wish to use this feature, you may provide us with such other party’s email address or Instant Messenger screen name so that we can facilitate your sending of such message to such other party. To do so, any Personal Information you provide in connection with sending such other party the message, such as your name and your email address or Instant Messenger screen name, will, of course, be disclosed to such other party. While, due to technical restrictions, the recipient’s email address or Instant Messenger screen names may be retained in our log files, we do not knowingly share it with third parties and we do not use this Personal Information for any purpose except to send this message (unless the recipient has already consented to such use of his/her Personal Information).

Location Information . When you share your location with others or add a location to something you post, we treat that like any other content you post (for example, it is subject to your privacy settings). If we offer a service that supports this type of location sharing we will present you with an opt-in choice of whether you want to participate.

Information automatically collected when you visit and interact with the Site:

We keep track of the actions you take on the Site, such as adding a friend, becoming a fan of a page or event, joining a group or an event, creating a photo album, messaging another user, indicating you “like” a post, attending an event, or authorizing an application. In some cases you are also taking an action when you provide information or content to us. For example, if you share a video, in addition to storing the actual content you uploaded, we might log the fact you shared it.

Access Device and Browser Information. When you access snapd from a computer, mobile phone or other device, we may collect information from that device automatically, including:

• your mobile device or computer’s location and Internet Protocol (IP) address;

• your browser type and operating system;

• the web pages you were visiting immediately before and after you came to the Site;

• activities within community discussions;

• web pages and advertisements that you view, and links that you click on, within the Site;

• information about the searches you perform on the Site and how you use the results of those searches;

• information about the services that you use on the Site, how frequently you use them; and your responses to the offerings and advertisements presented on the Site, including those available through third party websites

• your bandwidth speed and information about the software programs that are installed on your computer;

• aggregated data about email click-through rates and user video viewing;

• location data and other information about mobile devices used to access and interact with the Site;

• standard server log information;

• information collected through HTML cookies, Flash cookies, pixel tags, web beacons, and similar standard Internet technologies. The information we obtain in this manner enables us to customize the services we offer our website visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, or other activities.

Cookie Information. We use “cookies” (small pieces of data we store for an extended period of time on your computer, mobile phone, or other device) to make the Site easier to use, to make our advertising better, and to protect both you and snapd. For example, we use them to store your login ID (but never your password) to make it easier for you to login whenever you come back to the Site. We also use them to confirm that you are logged into the Site, and to know when you are interacting with snapd platform applications and websites, our widgets and Share buttons, and our advertisements. You can remove or block cookies using the settings in your browser, but in some cases that may impact your ability to use the Site.

Web beacons. These are a small file placed on a web page that allows a website to perform various tasks, including count users who have viewed that page or to access cookies.

Information we collect or receive from other sources:

We may access information about you from third-party sources and platforms (such as social networking sites, databases, online marketing firms, and ad targeting firms), including:

• if you access third-party social networking services through the Site, your username and connection lists for those services;

• demographic data, such as age range, gender, and interests;

• advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular ad;

• unique identifiers, including mobile device identification numbers, that can identify the physical location of such devices in accordance with applicable law; and

• anonymous identification numbers, if you come to our site from an online advertisement displayed on a third-party website (see also “Information from other websites”, below).

Please note that the Site may combine the information that we collect with information we obtain from third- party sources.

Information from other websites. We may institute programs with advertising partners and other websites in which they share information with us. We may ask advertisers to tell us how our users responded to the ads we showed them (and for comparison purposes, how other users who didn’t see the ads acted on their site). This data sharing, commonly known as “conversion tracking,” helps us measure our advertising effectiveness and improve the quality of the advertisements you see. We may receive information about whether or not you’ve seen or interacted with certain ads on other sites in order to measure the effectiveness of those ads.

Information You Share With Third Parties . We take steps to ensure that others use information that you share on the Site in a manner consistent with your privacy settings, but we cannot guarantee that they will follow our rules. Certain categories of information such as your name, profile photo, list of friends and pages you are a fan of, gender, and networks you belong to are considered publicly available, and therefore do not have privacy settings. Some of the content you share and the actions you take will show up on your friends’ profile pages and other pages they visit. Even after you remove information from your profile or delete your account, copies of that information may remain viewable elsewhere to the extent it has been shared with others, or it was copied or stored by other users. You understand that information might be re-shared or copied by other users and that certain types of communications that you send to other users cannot be removed, such as messages.

Exporting Information. You (and those you make your information available to) may use tools like RSS feeds, mobile phone address books, or copy and paste functions to capture and export information from the Site, including your information and information about you.

Advertisements. Sometimes the advertisers who present ads on the Site use technological methods to measure the effectiveness of their ads and to personalize advertising content. You may use your browser cookie settings to limit or prevent the placement of cookies by advertising networks.

Links. When you click on links on the Site you may leave our site. We are not responsible for the privacy practices of other sites, and we encourage you to read their privacy statements.

4. How We Use the Information that We Collect

We collect information for one or more of the following purposes:

To manage the service. We use the information we collect to provide our services and features to you, to measure and improve those services and features, and to provide you with customer support. We use the information to prevent potentially illegal activities. For example, we ask for your date of birth to verify that you are over age 13 and so that we can better limit your access to content and advertisements that are not age appropriate. We also use a variety of technological systems to detect and address anomalous activity and screen content to prevent abuse such as spam. These efforts may on occasion result in a temporary or permanent suspension or termination of some functions for some users.

Email Communications. We may use the information that we collect to send you e-mail communications, such as editorial updates, information about your account or changes to the Site, and promotional messages about our own or our marketing partners’ products and services. If you signed up for one of our email newsletters, we also will send you the newsletter that you requested.

Mobile Communications . With your consent, we may use your mobile number to send you promotions, notifications, or other services.

Advertising. In order to provide our readers with free access to our content, we display advertisements on the Site. To create a more customized online experience for you, some of the ads you may receive are tailored to your preferences using information collected through cookies, web beacons, and other sources, such as ad networks which help us to present customized content and advertisements on the Site. Through this process, advertisers reach Site visitors who are most interested in their products, and you see advertising for products or services in which you may be interested.

We don’t share your information with advertisers without your consent. (An example of consent would be if you asked us to provide your shipping address to an advertiser to receive a free sample.) We do however allow advertisers to choose the characteristics of users who will see their advertisements and we may use any of the non-personally identifiable attributes we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. For example, we might use your interest in football to show you ads for football equipment, but we do not tell the football equipment company who you are. Even though we do not share your information with advertisers without your consent, when you click on or otherwise interact with an advertisement there is a possibility that the advertiser may place a cookie in your browser and note that it meets the criteria they selected. Third-party advertisers and advertising platforms also may serve targeted ads on the Site. Please remember that the information practices of third-party advertisers or platforms collecting data on our site are not covered by this privacy policy.

We occasionally pair advertisements we serve with relevant information we have about you and your friends to make advertisements more interesting and more tailored to you and your friends. For example, if you become a fan of a Page, we may display your name and profile photo next to an advertisement for that Page that is displayed to your friends. We only share the personally identifiable information visible in the social ad with the friend who can see the ad.

Surveys and Contests. From time-to-time our Site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as postal code/zip code, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this Site and such other purposes as may be disclosed to you.

User Accounts. To provide you with and positive, open and civil discussion forum, we track user involvement in our community discussions. For example, we keep track of the ratio of how many liked comments or photos are published to the site in order to produce our snapd monthly community newspapers. We may use information about you that we collect from other Site users to supplement your profile (such as when you are tagged in a photo or mentioned in a status update). In such cases we generally allow you to direct how that information is shared in your privacy settings or give you the ability to remove the content (such as allowing you to remove a photo tag of you) or limit its visibility on the Site.

Request Fulfillment. We may use the information that we collect to fulfill your requests for products, services, and information. For example, we may use your contact information to respond to your customer service requests or to enable you to participate in features on the Site such as surveys, polls, sweepstakes, and message boards, or facilitate purchase of event tickets or services in support of event ticketing and event management.

Financial Information. We may use financial information you supply to process payment for any purchases or sales made on our Site or through call centres or retail outlets, to enroll you in such discount, rebate, and other programs in which you elect to participate, to facilitate your transactions with our third party marketing partners, to protect against or identify possible fraudulent transactions, and otherwise as may be reasonably needed to manage our business in connection with your transaction (for example, to identify you at the box office if you are picking up event tickets, to facilitate refunds for cancelled events, for audit purposes, etc.).

To make Suggestions. We use your profile information, the addresses you import through our contact importers, and other relevant information, to help you connect with your friends, including making suggestions to you and other users that you connect with on Facebook. If you want to limit your visibility in suggestions we make to other people, you can adjust your search visibility privacy setting, as you will only be visible in our suggestions to the extent you choose to be visible in public search listings. You may also block specific individual users from being suggested to you and you from being suggested to them.

Downloadable Software. Certain downloadable software applications and applets that we offer, such as our browser toolbars and photo uploaders, transmit data to us. We may not make a formal disclosure if we believe our collection of and use of the information is the obvious purpose of the application, such as the fact that we receive photos when you use our photo uploader. If we believe it is not obvious that we are collecting or using such information, we will make a disclosure to you the first time you provide the information to us so that you can decide whether you want to use that feature.

Statistical Analysis. In order to learn more about how our Site is used, we aggregate and analyze the data that we collect. We may use this information, for example, to monitor and analyze use of the Site, to increase our Site’s functionality, and to better tailor our content and design to suit our visitors’ needs.

Anonymous and aggregated information . We may combine anonymous information and/or aggregate information we collect with additional anonymous information collected from other sources. We may share anonymous information (including aggregate information) we collect regarding our users with third parties (such as advisors, advertisers and investors) for various business purposes including developing and delivering targeted advertising on our websites and on websites of third parties, conducting general business analysis, and developing website content and services.

Enforcement. We may use the information that we collect to meet legal and regulatory requirements, to prevent illegal activities, to enforce the Site’s Terms and Conditions, and to otherwise protect our rights and the rights of our users.

5. Information Sharing

The Site is about sharing information with others — friends and people in your networks and in your community —while providing you with privacy settings that you can use to restrict other users from accessing your information. Please be aware that when you disclose Personal Information through a chat room, forum, message board, news group or Facebook feature on the Site, the information may become public and accessible to all or a part of the Site community, so it is important for you to exercise discretion and appropriate caution when deciding to reveal Personal Information in these areas. In addition, when you choose to make a posting on such services, certain Personal Information may be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH THE SITE VIA THESE FORUMS AND OTHER INTERACTIVE FEATURES. We share your information with third parties when we believe the sharing is permitted by you, reasonably necessary to offer our services, or when legally required to do so. For example:

• We may share aggregated information or information that does not directly identify you with third parties to help us develop content, services, and advertising that we hope you will find of interest. Please note that we do not share contact information with third parties that advertise on the Site.

• We may share your personal information with our authorized service providers that perform certain services on our behalf. These services include fulfilling orders, processing credit card payments, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our website. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes. We require all of our service providers to comply with the safeguards described in this policy.

• We may employ third parties to perform Site-related services, including database management, maintenance services, analytics, marketing, data processing, and email and text message distribution. These third parties have access to your information only to perform these tasks on our behalf.

• If you choose to engage in public activities on the Site, such as uploading or otherwise sharing content or posting comments on community message boards, any information you submit can be read, collected, or used by others. Please exercise caution when deciding to disclose any personal information in public activities or submissions.

• We may share information about you in the event that the Site is acquired by or merged with another company or a similar corporate transaction takes place. However, the Site will notify you by placing a prominent notice on our site or sending a notice to the primary email address specified in your account before your information is transferred and becomes subject to a different privacy policy.

• We may share information about you to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, violations of the Site’s Terms and Conditions, or as otherwise required by law.

• We may share information about you to respond to court orders, search warrants, judicial proceedings, subpoenas, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims.

• In addition to the scenarios identified above, we may share information about you for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Information collected by third-party advertising companies. We may allow third-party advertising companies, including ad networks, to display advertisements on our site. These companies may use tracking technologies, such as cookies, to collect anonymous information about users who view or interact with their advertisements. Our website does not provide any personal information to these third parties, but they may collect information about where you, or others who are using your computer, saw and/or clicked on the advertisements they deliver, and possibly associate this information with your subsequent visits to the advertised websites. They also may combine this information with personal information they collect from you. The collection and use of that information is subject to the third-party’s privacy policy. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

When you make a payment. When you enter into transactions with others or make payments on the Site, we will only share transaction information with those third parties necessary to complete the transaction and will require those third parties to agree to respect the privacy of your information.

When you purchase Event Tickets. We may, as an Agent, sell event tickets on behalf of third parties, including venues, clubs, associations, artists, teams, leagues, and others who are involved in producing or bringing you events (“Providers” or “Organizers”). We do not produce or otherwise bring you events. Providers and venus supply us with details about events they wish to present, including quantities and prices of tickets they desire to sell, and may authorize us to sell some or all of those tickets. We charge the customer’s credit card for the ticket price, and remit the ticket price proceeds to the Provider. We may communicate with the Provider such information as may be required by the Provider for the purpose of providing ticketing related services for you for such events. We will use secure connections if supplying personal information. Providers may use your information to issue a ticket, provide with you with important event-related communications (such as a notice of cancellation or of any change in the time or content of the event), or to provide you with assistance if you lose your tickets and for other ticketing related purposes. We and the Provider collect the information needed to provide you with these important notices and to address customer service problems. If you have provided your express consent during the purchase process, the Provider may also contact you regarding future events and special offers. Providers are subject to applicable privacy legislation, which may include the Personal Information Protection and Electronic Documents Act, the Personal Information Protection Act of British Columbia and Alberta and Quebec’s Act respecting the protection of personal information in the private sector. Providers are required to comply with their obligations under laws applicable to their operations, including privacy legislation. In addition, Providers may have their own privacy policies that govern their use of your personal information. If you want to learn about a particular event Provider’s privacy policy, or if you do not want to receive any further communications from a Provider, or if you have other questions for a Provider, you should contact that Provider directly.

Our Business Partners. With your consent, we may also share your personal information with businesses with which we partner to offer you products, services, promotions, contests and/or sweepstakes through our Site or our Services, such as discounted hotel stays or special dining offers. If you are interested in these offers, the business partners will be identified to you at the time you purchase or decide to participate in an offer or program being offered through them. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address, billing and other information relevant to the offer or program to that merchant. These businesses may use your personal information in accordance with their own privacy policies. If you want to learn about a particular merchant’s privacy policies, or you do not want to receive communications from a particular merchant, then you must contact that merchant directly. Your personal information is only provided to those businesses whose offers you elect to participate in and not to other businesses advertising on our Site.

When you invite a friend to join. You are permitted to invite any of the following categories of people to join the Site: any individual with whom you have an existing business relationship, an existing non-business relationship, a family relationship or a personal relationship. When you ask any of those people to join the Site, we will send that person with the person who sends the message as well as any of those relationships with the individual to whom the message is sent and that discloses the full name of the individual or individuals who made the referral and states that the message is sent as a result of the referral. If that individual does not want us to keep their information, we will remove it at their request on this help page.

“family relationship” means the relationship between an individual who sends a message and the individual to whom the message is sent if those individuals are related to one another through a marriage, common-law

partnership or any legal parent-child relationship and those individuals have had direct, voluntary, two-way communication; and

“personal relationship” means the relationship between an individual who sends a message and the individual to whom the message is sent, if those individuals have had direct, voluntary, two-way communications and it would be reasonable to conclude that they have a personal relationship, taking into consideration any relevant factors such as the sharing of interests, experiences, opinions and information evidenced in the communications, the frequency of communication, the length of time since the parties communicated or whether the parties have met in person.

“existing business relationship” means a business relationship between the person to whom the message is sent and the person who sends the message, the person who causes it to be sent, or the person who permits it to be sent arising from:

(a) the purchase or lease of a product, goods, a service, land or an interest or right in land, within the two-year period immediately before the day on which the message was sent, by the person to whom the message is sent from any of those other persons;

(b) the acceptance by the person to whom the message is sent, within the period referred to in paragraph (a), of a business, investment or gaming opportunity offered by any of those other persons;

(c) the bartering of anything mentioned in paragraph (a) between the person to whom the message is sent and any of those other persons within the period referred to in that paragraph;

(d) a written contract entered into between the person to whom the message is sent and any of those other persons in respect of a matter not referred to in any of paragraphs (a) to (c), if the contract is currently in existence or expired within the period referred to in paragraph (a); or

(e) an inquiry or application, within the six-month period immediately before the day on which the message was sent, made by the person to whom the message is sent to any of those other persons, in respect of anything mentioned in any of paragraphs (a) to (c)

“existing non-business relationship” means a non-business relationship between the person to whom the message is sent and the person who sends the message, the person who causes it to be sent, or the person who permits it to be sent arising from:

(a) a donation or gift made by the person to whom the message is sent to any of those other persons within the two-year period immediately before the day on which the message was sent, where that other person is a registered charity as defined in subsection 248(1) of the Income Tax Act, a political party or organization, or a person who is a candidate — as defined in an Act of Parliament or of the legislature of a province — for publicly elected office;

(b) volunteer work performed by the person to whom the message is sent for any of those other persons, or attendance at a meeting organized by that other person, within the two-year period immediately before the day on which the message was sent, where that other person is a registered charity as defined in subsection 248(1) of the Income Tax Act, a political party or organization or a person who is a candidate — as defined in an Act of Parliament or of the legislature of a province — for publicly elected office; or

(c) membership, as defined in the regulations, by the person to whom the message is sent, in any of those other persons, within the two-year period immediately before the day on which the message was sent, where that other person is a club, association or voluntary organization, as defined in the regulations.

When you ask us to invite a friend to join snapd, we will send your friend a message on your behalf using your name. We may also send up to two reminders to them in your name. If your friend does not want us to keep their information, we will remove it at their request on this help page.

To help your friends find you . By default, we make certain information you have posted to your profile available in search results on the Site to help your friends find you. However, you can control who has access to this information, as well as who can find you in searches, through your privacy settings. We also partner with email and instant messaging providers to help their users identify which of their contacts are snapd users, so that we can promote snapd to those users.

To help improve or promote our service. Sometimes we share aggregated information with third parties to help improve or promote our service. But we only do so in such a way that no individual user can be identified or linked to any specific action or information.

To provide you with services . We may provide information to service providers that help us bring you the services we offer. For example, we may use third parties to help host our website, send out email updates about the Site, remove repetitive information from our user lists, process payments, or provide search results or links (including sponsored links). These service providers may have access to your personal information for use for a limited time, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

To advertise our services . We may ask advertisers outside of the Site to display ads promoting our services. We may ask them to deliver those ads based on the presence of a cookie, but in doing so will not share any other information with the advertiser.

To offer joint services. We may provide services jointly with other companies, such as the classifieds service in the Facebook Marketplace. If you use these services, we may share your information to facilitate that service. However, we will identify the partner and present the joint service provider’s privacy policy to you before you use that service.

To respond to legal requests and prevent harm. We may disclose information pursuant to subpoenas, court orders, or other requests (including criminal and civil matters) if we have a good faith belief that the response is required by law, or to establish or exercise our legal rights, or to defend against legal claims. This may include respecting requests from jurisdictions outside of the Canada where we have a good faith belief that the response is required by law under the local laws in that jurisdiction, apply to users from that jurisdiction, and are consistent with generally accepted international standards. We may also share information when we have a good faith belief it is necessary to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating our Policies, Terms and Conditions, and to protect us and other visitors to our Site or users of our Services or event Providers. This may include sharing information with other companies, lawyers, courts or other government entities.

In connection with a substantial corporate transaction , such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. Any third parties to whom we may disclose personal information may only use and disclose your personal information as described in this Privacy Policy unless you otherwise consent.

In addition to the scenarios identified above, we may share information about you for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Please note that third parties may independently collect data about you, including your IP address and information about the websites you visit and the links you click, through cookies, clicks on links, or other means when you visit or view ads on the Site. For more information, see our section on cookies and other technologies and third party advertising. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy” link typically located at the bottom of the webpage you are visiting.

Your use of other user’s information:

As a user of our Site, you may have access to other user’s usernames, and you might gain access to other contact information of other users through the regular use of the Site. By accepting this Privacy Policy, you agree that, with respect to other users’ personally identifiable information that you obtain through the Site or the Services, we hereby grant to you a license to use such information only for: (a) snapd related communications that are not unsolicited commercial messages, and (b) any other purpose to which such member expressly agrees after complete disclosure of the purpose. Furthermore, under no circumstances may you disclose personally identifiable information about another user to any third party without the consent of such other member after adequate disclosure. You also agree that we shall have the right to grant other users the same licenses to your information. Spam will not be tolerated. Accordingly, without limiting the foregoing, you are not licensed to add a snapd user to your mail list (email or physical mail or text messaging) without their express consent after adequate disclosure. To report spam from or by another snapd user, please contact our privacy officer at: snapdprivacyInfo@snapd.com

6. Third-party Services

To customize your experience on the Site and to simplify the Site’s registration process, we provide you with the opportunity to access or interact with third-party services, such as Facebook and Twitter. When you connect to the Site through these third-party services, we may share information about you with these third- party service providers and they may share data about you with us.

When you allow us to access your data through a third-party service to create a Site profile, we may use this data for several purposes, including:

• Creating relationships automatically within our system. For example, if you connect to us via a service with a public friend list, like Twitter, we may check to see if any people you follow on Twitter are also Site members. If we find a match, we will replicate your Twitter relationship with those members, setting them to be fans, followers, or friends on our Site.

• Suggesting relationships. For example, if you connect via a service that has a private contact list (like Google and Yahoo!), we check for people in your contacts who are Site members and suggest that you become a fan of these users. This process is not automatic; you must affirmatively choose to become a fan of these suggested users.

• Populating a list of potential friends to whom you can send emails. When users share content with their friends using, for example, the forward-to-a-friend feature on the Site, we may use friend lists from third- party services to create a list of contacts to whom you may choose to send the email message.

• Populating a list of potential friends to whom you can send service-specific messages. For example, we may use friend lists from a third-party service to create a list of contacts to whom you may choose to send an invitation to view an interactive slideshow.

• To enhance and personalize your experience on the Site. When you are connected via a third-party service, we may access certain account information, such as your profile picture, what stories are popular in your network, and what your friends are saying about certain articles or blog posts, in order to enhance and personalize your experience on the Site.

In addition, if you login to a personal account on our Site, your experience on the Site may be personalized. For example, you may automatically see what stories are popular in your network, and what your friends are saying about particular stories.

Please remember that we do not control the privacy practices of these third-party services. We encourage you to read the privacy policies of all third-party service providers.

7. Your Choices

We are committed to offering you meaningful privacy choices regarding the collection, use, and disclosure of your personal information. This includes the opportunity to:

Opt Out

At any time, you can choose to no longer receive commercial or promotional emails from us by clicking on My Account and following the instructions to “manage your email alerts.” You may modify your choices at any time in your account preferences. Also, in any commercial email we send, you will be given the opportunity to opt out of receiving such messages in the future by clicking on the link at the bottom of the email that says “unsubscribe.” It may take up to 10 days for us to process an opt-out request.

Even if you have unsubscribed from receiving promotional emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements, administrative notices and surveys. Please note that changing information in your account settings or opting out of receiving promotional email communications will affect only future communications from us. If we already provided your information to a third party (such as an event provider) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party as well.

Deactivate your account

You can deactivate your account at any time by visiting the settings page for your profile. When you deactivate your account, your user profile will be disabled, but your public comments will remain on the site. The Site has no responsibility to take down, remove, or edit any of your public activities or any submissions that are a result of your public activities. We save your profile information (friends, photos, interests, etc.) in case you later decide to reactivate your account. Many users deactivate their accounts for temporary reasons and in doing so are asking us to maintain their information until they return to the Site. You will still have the ability to reactivate your account and restore your profile in its entirety.

Even after you remove information from your profile or delete your account, copies of that information may remain viewable elsewhere to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users. However, your name will no longer be associated with that information on snapd. (For example, if you post something to another user’s profile, and then you delete your account, that post may remain, but be attributed to an “Anonymous snapd User.”) Additionally, we may retain certain information to prevent identity theft and other misconduct even if deletion has been requested.

Please note that removed and deleted information may persist in backup copies for up to 90 days, but will not be available to others.

Cookies and Other Technologies

As discussed in the sections on cookies and other technologies and third party advertising, some information is collected about you automatically through cookies and other technologies to customize your online experience. You can opt out of the use of your information for targeting purposes through the following procedures:

• Cookies. You can change your browser settings to reject all cookies, accept only certain cookies, or notify you when a cookie is set. Please note that you may need to renew these settings if you delete your cookies after these preferences are made. These settings also may not apply if you are using a different computer or Internet browser. In addition, many third-party advertising networks are members of the Network Advertising Initiative (“NAI”). To opt out of having information collected by NAI member companies used for behavioral advertising, to obtain information about the technologies these ad networks might use, and to view information regarding their privacy policies, please visithttp://networkadvertising.org/managing/opt_out.asp.

• Flash Cookies. You can control how Flash cookies are used by visiting the Adobe Macromedia site, located here. Adobe enables you to allow some Flash cookies from certain websites, limit Flash cookies’ storage capacity, and disallow Flash cookies altogether. In addition, if you use Mozilla Firefox for your Internet browser, you can download the BetterPrivacy add-on to automatically delete your Flash cookies every time you close your browser.

If you opt out of these technologies, you will continue to see advertising displayed on the Site, but the advertising may not be targeted to your interests.

Please remember that we do not have access to, or control over, advertisers’ or service providers’ cookies, and the information practices of third parties are not covered by this privacy policy.

8. Access

We will make available to you any of your personal information that we have collected, used or disclosed upon request. Please contact us at snapdprivacyInfo@snapd.com.

9. Accuracy

We make reasonable efforts to keep your personal information as accurate, complete and up-to-date as is necessary to fulfill the purposes for which the information is to be used. However, we rely upon our customers to ensure accuracy of the personal information provided to us. You can challenge the accuracy of the information and request amendments as appropriate by contacting us at snapdprivacyInfo@snapd.com.

10. Confidentiality and Security – Limiting Use, Disclosure, and Retention of Personal Information

We have privacy and security practices in place to safeguard your personal information.

To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the correct use of information, we have established and maintained appropriate physical, electronic, and managerial procedures reasonably designed to safeguard and secure the information we collect online. Personnel who have access to our database are trained to maintain and secure all information. The safeguards in place are reviewed regularly to ensure that the risks introduced by new security threats are minimized.

We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When sensitive personal information (such as address and phone number) is transmitted over the Internet, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. The presence of SSL means you can rest assured that communications (e.g. credit card numbers) between your browser and this site’s web servers are private and secure when the SSL session is activated.

We retain personal information only as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. We also limit access to information about you to employees or service providers who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. Moreover, we have adopted commercially reasonable technical, physical, and administrative procedures to help protect your personal information from loss or theft and unauthorized access, disclosure, copying, use, or modification.

Although we allow you to set privacy options that limit access to your information, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you share your information. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the Site will not become publicly available. We are not responsible for third party circumvention of any privacy settings or security measures on the Site. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

If you are visiting our website or using one of our software applications from outside of Canada, please be aware that you are sending information (including Personal Data) to Canada where our servers are located. We will hold and process your Personal Data and Non-Personal Data in accordance with privacy laws in Canada and this Privacy Policy. Please note that privacy laws in Canada may not be the same as, and in some cases may be less protective than, the privacy laws in your country.

Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the Site, but we cannot ensure or warrant the security of any information you transmit to us.

11. Information May Be Collected, Transferred, Stored, or Processed Outside of Canada

SNAPD and its third party partners to whom we disclose information under this policy may perform activities outside of Canada and potentially collect, transfer, store, and process your personal information in other countries. As a result, your information may be subject to the laws of those countries. These laws may not be equivalent to the privacy and data protection laws in Canada. Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries. By using this Site or providing us with your information, you consent to the potential collection, transfer, storage, and processing of information in other countries.

12. Children’s Guidelines

We do not knowingly collect personal information from children under 13. If we learn that we have collected any personal information from a child under the age of 13 without verifiable parental consent, we will endeavor to delete that information from our database as quickly as possible. If you believe that we may have collected information from a child under 13, please contact us at snapdprivacyInfo@snapd.com.

13. Changes to the Privacy Policy

We may update this privacy policy at any time to reflect changes in our practices and service offerings. If we modify this privacy policy, we will update the “Effective Date.” We will also notify you of any substantive changes in the way we treat your information by placing a prominent notice on our site or sending a notice to the primary email address specified in your account. Your continued use of the account following notice of a change means that you agree to and accept the new terms of the privacy policy. If you do not agree with any changes made or with the new terms of the policy, you must immediately stop using the account and deactivate it.

14. Openness We are committed to providing you with understandable and easily available information about our policy and practices related to management of your personal information. This policy and any related information is available at all times on our websites. Upon request of our customers (and the public where applicable law requires), we will make readily available the name, title and address of our Privacy Officer(s) to whom inquiries or complaints can be forwarded; the means of gaining access to personal information held by us; a description of the type of personal information held by us, including a general account of its uses; a copy of any brochures or other information that explains our policies or information handling practices; and the types of personal information made available to related organizations such as subsidiaries or other suppliers of services. 15. Addressing Your Concerns

We have implemented policies and practices to give effect to this Privacy Policy, including training and communicating with our employees the importance of privacy. We regularly monitor our procedures and security measures to ensure that they remain effective and that they are being properly administered.

If you have questions about this Privacy Policy, please contact our privacy team as follows:

By Email:snapdprivacyInfo@snapd.com In Writing:

Chief Privacy Officer snapd Inc.

505 Queen Street

Newmarket, ON, L3Y 2H3

Your California Privacy Rights. If you are a California resident, you have the right to request information about how we share certain categories of personal information with third parties. California law gives you the right to send us a request at a designated address to receive the following information:

• the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;

• the names and addresses of the third parties that received that information; and

• if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

We may provide this information in a standard format that is not specific to you. The designated email address for these requests is snapdprivacyInfo@snapd.com

If you are concerned that we are not complying with the principles set out in this policy, please contact our Chief Privacy Officer at the contact address set out above. We maintain procedures for addressing and responding to all inquiries and complaints by users with regards to our handling of personal information. We will ensure that inquiries, concerns, and complaints regarding personal information receive prompt attention and are resolved in a timely manner, in compliance with applicable laws. We shall have the right to request additional time under the applicable legislation to respond. For disputes in Canada, if the Privacy Officer is unable to satisfy the customer’s concerns, the customer may then refer to the relevant privacy commissioner (Privacy Commissioner of Canada where no provincial personal information protection statute exists, or to the provincial Information and Privacy Commissioner where a provincial personal information protection statute does exist). However, the customer is encouraged to use snapd’s internal information and complaint procedures first. Appropriate contact information for such privacy commissioner will be provided upon request.

BY USING ANY OF OUR WEBSITES, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE OUR WEBSITE. YOUR CONTINUED USE OF ANY OF OUR WEBSITES FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY WILL MEAN THAT YOU ACCEPT THOSE CHANGES.

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