Privacy Policy

This page informs you of the policies regarding the collection, use, and disclosure of your personal and other information (“Information”) when you access or use the website located at https://truesnaps.com ("Site"). By using the Site, you agree to the collection and use of your Information in accordance with this Privacy Policy (the “Policy”). Unless otherwise defined in this Policy, capitalized terms used herein have the same meaning as given in our Terms of Use. The use of “we” or “us” herein shall refer collectively to the Owner and Operator of the Site as set forth in the Terms of Use. We will not use or share your Information with anyone except as described in this Policy unless we otherwise inform you and give you an opportunity to opt-out of having any of your Information shared.

Information Collected

In connection with your use of the Site, we may collect certain Information that may allow us to determine your actual identity and contact information (i.e. your Snapchat user name and e-mail address) as well as your geolocation information, Internet Protocol (“IP”) address, unique device identifiers, and/or other information unique to you as an individual such as your browser and operating system information, your time spent on the Site, and/or your usage information from Google analytics (see below under “Log Data”).

How and Why Information is Collected

We may collect your Information through your use of the Site, in connection with your accessing the private Snapchat accounts of our models, when you contact us, or through any third-party website or service you use to link to our Site (i.e. a mobile application or another online service). We may also add Information collected on you by third parties.

We may also collect information that your browser sends whenever you visit our Site ("Log Data"). This Log Data may include information such as your computer's IP address, browser type, browser version, the pages that you visit, the time and date of your visit, the time spent on those pages, and other statistics. In addition, we may use third-party services such as Google Analytics that collect, monitor and analyze this type of information to increase our functionality. Analytics companies like these may also use mobile device IDs (used to recognize you, store your preferences, and track your use of the Sites) which we may store and which cannot be deleted like cookies.

Cookies are files with small amounts of data that are stored by a user's web browser on the user's storage drive as records of the user’s past online activities on a webpage (i.e. dates and times of prior visits, purchases, and participation in online training courses or curriculums of a webpage). Cookies record such information to simplify subsequent interactions with that website by the same user, or to streamline the user's transactions on related webpages (i.e. your IP address, device ID, browser type and language, access times, content of undeleted cookies previously accepted, and the referring website address if applicable). Cookies make it easier for a user to move from webpage to webpage and to complete transactions over the Internet. We use cookies to collect information to improve our Site for your benefit.

We may use other standard internet technology, such as web beacons, pixel tags, local storage, and other technologies that facilitate personalization to track your use of our Site. We also may use these technologies in advertisements or email messages to determine whether messages have been opened and acted upon. Finally, we may electronically monitor your access to the Site by collecting dates/times/durations of your use of the Site. The Information we obtain in this manner enables us to customize the Site and the services we offer access to through our Site, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming or other activities.

We may also allow service providers, affiliate companies, advertising companies, ad networks, and other third parties to display advertisements on the Site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. This information allows them to deliver targeted advertisements and gauge their effectiveness.

We also collect and will potentially share certain aggregated (or hashed/encrypted) information about you with our partners and advertisers such as the total number of our users and their overall demographics. This aggregated information is not linked to any personal information that can directly identify you.

How Collected Information is Used

We collect your Information for any of these possible uses:

Whom We Share Information With

We may share your Information with third parties that perform certain services on our behalf. These services may include providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, registration screenings, supporting our Site functionality, and supporting other features offered through our Site (i.e. payment processing, order fulfillment, and bill collection entities). These service providers may have access to Information needed to perform their functions but are not permitted to share or use such Information for any other purposes.

From time to time we may be involved in some form of business transfer, whether it is a merger, acquisition, divestiture, consolidation, or some form of asset sale. In connection with such activity, your Information may be provided to entities and advisors involved in the business transfer (or be transferred as a business asset) subject to an obligation to keep your Information confidential.

We may disclose or share your non-personal information in an aggregated and de-identified form with our business partners and other third parties as we deem appropriate or necessary. Among other things, we may disclose your non-personal information to third parties to help us determine how people use the Site and/or Services and who our users are so we can improve our Site and the availability of our Services.

Some of the Information collected may also be used to autofill third-party websites that are clicked to from the Sites like the third-party payment processor we use. Likewise, your e-mail address(es) may be used to market our Services and we may partner with an e-mail marketing company and sell our e-mail database (which may include your e-mail information) to a third-party.

Protection and Control of Information

The security of your Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. While you should feel confident using our Site and/or accessing the Services made available through the Site, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee that the safeguards we have in place will always ensure absolute security of the Information we have collected. Accordingly, we do not promise, and you should not expect, that your Information, browsing history, or any Information you might make available through your use of the Site or by accessing the Services will always remain secure.

When you provide your e-mail address on the Site for purposes of accessing any of the Services we make accessible, you automatically consent to receive email messages from us including, but not limited to, messages regarding security, privacy, and administrative issues, such as security breaches. You may opt-out of receiving any, or all, of these commercial or promotional emails at any time by following the unsubscribe link or instructions provided in any such email. Please note that opting out of receipt of commercial or promotional email communications will only affect future activities or communications from us. If we have already provided your Information to a third party (such as a service provider) before you have changed your preferences, you may have to change your preferences directly with that third party.

We may allow third-parties, including advertising companies, analytics companies, and ad networks, to display advertisements on our Site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements or our Site. Unless otherwise indicated herein, we do not provide any of your Information to these third parties, but they may collect information about where you, or others who are using your device, saw and/or clicked on the advertisements they deliver and possibly associate this information with your subsequent visits to the advertised websites or other data they have collected. They may also combine this information with additional information they collect from you to provide advertisements about goods and services likely to be of greater interest to you. The collection and use of that information is subject to such third-parties’ privacy policies which we suggest you consult before using such third-party sites or services. We will not be held accountable for your failure to do so.

Again we, along with certain third-party advertisers with which we may have a relationship, use or may use cookies to gather your Information. You may be able to opt-out of the cookies delivered through our website by changing the settings on your Internet browser (the Help feature in most browser settings/toolbars provides information on how to accept/disable cookies or simply get a notification when a cookie is being sent). Depending on your privacy settings, please be aware that opting-out of cookies may disable all cookies delivered to your browser, not just the ones delivered through our website. Additionally, by choosing not to accept cookies, you may not be able to use some features of our Site and/or access the Services made available through the Site and we recommend that you leave them turned on.

You have a legal right to know what data we hold on you and you can contact us at the e-mail or postal address provided below if you would like to correct, amend, or delete such Information.

Additional Information

International Transfer and Processing. Your Information may be transferred to - and maintained on - computers located outside of your state, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. Your consent to this Policy as given by your submission of your Information represents your agreement to that transfer.

Do Not Track Disclosure.Do Not Track ("DNT") is a privacy preference that users can set in their web browsers usually through the preferences or settings page. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the Information we collect, however, we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

Data Retention. You may contact us to delete or otherwise dispose of any Information we have collected on you as discussed above, however, we may still retain certain Information for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Site, the Services made available through the Site, or our Site users, or take other actions otherwise permitted by law. In addition, if certain Information has already been provided to third-parties as described in this Policy, retention of that Information will be subject to those third parties' policies.

Children’s Privacy and CalOPPA. Our Site and the access to the Services provided through the Site are not intended for use by children and we do not knowingly collect any Information from children under 13. If you are a parent or guardian and you learn that your child has provided us with Information, please contact us. If we become aware that we have collected Information from a person under age 13, we shall promptly take steps to remove that Information from our servers. This Policy has been drafted in accordance with the requirements of California’s Online Privacy Protection Act (“CalOPPA”).

No Rights of Third Parties. This Policy does not create rights enforceable by third parties or require disclosure of any information relating to users of the Site to any third parties.

Amendments. We reserve the right to modify, supplement, replace, update, or change this Policy, effective prospectively upon such changes being posted on the Site or our notifying you otherwise. If you do not agree to such changes, you should discontinue your use of the Site and/or Services and cancel your subscription, if any, in the manner set forth in the Terms of Use. Your continued use of the Site and/or Services after we post any modifications to this Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Policy.

Contact

If you have any questions about this Policy, you can contact us at the following e-mail and/or postal addresses:

THE ABOVE POLICY WAS LAST UPDATED ON, AND IS EFFECTIVE AS OF, JUNE 1, 2018. YOUR CONTINUED USE OF THE SITE AND/OR SERVICES OFFERED THROUGH THE SITE CONSTITUTES YOUR ACCEPTANCE OF THE ABOVE POLICY, AS AMENDED FROM TIME TO TIME.