Privacy Policy

Salesnap Pte Ltd (“us”, or “we”) are the “data controller” in respect of your Personal Data. This privacy policy sets out the basis on which we will process your Personal Data that we collect in the provision of our products and services (“Services”), through our website or which you otherwise provide to us. For the avoidance of doubt, this privacy policy applies to https://salesnap.com, all subpages, our blog (together, the “Website”) and all software and Services that we offer through our Website.

Please note your Personal Data (as defined below) will also be handled by us where we provide our services to our customers’ (the “Merchants”). In these cases, where we handle Personal Data as part of our Services to Merchants (such as online retailers), the Merchant (and not us) will be the ‘data controller’ (as we will be acting as a “Processor”). That means that the Merchants’, and not our, privacy policy will apply to the Processing of your Personal Data. If you have any questions about how the Merchant handles your Personal Data you should direct those questions to the Merchant.

1. Definition

For the purposes of this privacy policy, the following definitions when appearing with their initial letter capitalized, have the meanings indicated below:

a. “Applicable Local Regulation”, refers to any regulation applicable to the context of the Processing of Personal Data carried out by Salesnap, including, but not limited to the General Data Protection Regulation (“GDPR”), and the Data Privacy Act of 2012 and Implementing Rules and Regulations of the Data Privacy Act (“Philippines Data Privacy Act”) and Personal Data Protection Act of Singapore (“PDPA”).

b. “Personal Data”, refers to any and all information related to an identified or identifiable natural person, obtained through online or offline means, including identifying numbers, location data, electronic identifiers, sensitive data, or any data that, when combined with other information, is capable of identifying a natural person, making them identifiable, or individualizing them. In general, we may collect Personal Data such as: your first and last name, your identification numbers, your registered address, your country of residence, your nationality, your marital status, date of birth, date of entry, gender, phone number, corporate or personal email, banking/cards information, and your transactional information.

c. “Processing”, refers to any operation performed with Personal Data, including collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation, or control of information, modification, communication, transfer, dissemination, or extraction.

d. “Sa”, refers to all companies that are part of the Sa economic group, including Sa Pte. Ltd. (our headquarter) and Sa Inc.

2. When We Collect Your Personal Data

We collect your Personal Data from various sources. You may be a website visitor, a user of our Services, or an end-customer of a Merchant. We will collect and process Personal Data when you:

• visit our website (including filling in forms on our site, such as when you sign up for an account);
• contact our customer service team or request information from us in any other way;
• participate in our customer satisfaction surveys or other market research; and/or
• communicate with us, including via email or social media.

We may also collect data about you from third party sources, for example from our related third parties such as our service providers, and the third party providers (such as payment services providers) with whom our service integrates.

3. What Personal Data That We Collect From You

We may collect the following types of Personal Data about you:

• your contact details (such as your name, address, email address and telephone number);
• financial data such as banking information and credit card information. For the avoidance of doubt, we collect your data should you agree to participate in our onboarding process with our partnered payment gateways;
• account information, such as your password and other authentication information;
• any other information we might collect over the course of our business relationship with you such as your transaction history or details of any correspondence between us;
• responses to any surveys or market research; and
• your marketing preferences.

When you visit our website, we and our related third parties may also collect information from you automatically, for example using cookies and other similar technologies. A cookie is a small file of letters and numbers that we may set on your device. You can find more information about the types of cookies we use and the purposes for which we use them below:

• information about your device, operating system and IP address;
• your login information;
• browser type and version;
• information about your visit, including URL, clickstream (i.e. your journey to, through and from our site), length of visits to certain pages, and page interaction information.

4. Why We Collect Your Personal Data

We may process your Personal Data for the following purposes:

• to provide you with the information and Services you have requested;
• to authenticate your access to our website and Services;
• to provide customer support and ensure we provide a good level of customer service;
• to notify you of any changes to our Services;
• for system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to distinguish you from other users (for example to remember your log-in details);
• to monitor your use of our website and Services to improve the user experience;
• to send you marketing and advertising materials where we have the authority to do so;
• to tailor any marketing or advertising so that it is more relevant to you;
• to conduct marketing analysis to allow us to assess trends and the effectiveness of our advertising and marketing campaigns;
• for security and fraud prevention;
• to ensure that our website and Services are safe and secure; and
• to comply with applicable laws and regulations.

5. Legality for Processing Your Personal Data

Where we are acting as a “data controller”, we will only process your Personal Data where we have a legal basis to do so. Where we are acting as a “Processor” and we are Processing the Personal Data on the Merchant’s behalf as part of the provision of our Services – the Merchant is responsible for determining and ensuring there is an appropriate lawful basis. Our legal basis for Processing your Personal Data where we are acting as a controller, will depend on the purposes for which we have collected and use your Personal Data. In almost every case the legal basis will be one of the following:

• Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
• Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate our business effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example we will rely on this legal basis when we conduct certain market analysis to understand our customers in sufficient detail so we can create new services and improve the profile of our brand.

Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have created an account for our Services, we will need to use your contact details in order to provide the Services to you. Compliance with law: Where we are subject to a legal obligation and need to use your Personal Data in order to comply with that obligation.

By accepting this Privacy Policy, you hereby provide your general authorisation for us, agreed and accepted that Salesnap exclusively own all Personal Data provided by you to Salesnap through our Website and/or other platforms. You also unconditionally agree to release, indemnify in full and hold harmless Salesnap against any and all losses, costs, penalties, fees, expenses (including but not limited to any litigation and legal consultant expenses) which have been, is, or suffered by, incurred by or expended by or threatened against Salesnap arising directly or indirectly out of or in connection with the usage of your Personal Data by Salesnap, unless such losses are caused by willful acts, negligence or breaches of this Agreement and the Applicable Local Regulations.

6. Where We Store Your Personal Data

Our services are global and Personal Data may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer Personal Data to countries outside of your country of residence, including the Singapore, Philippines and Indonesia, which may have data protection rules that are different from those of your country.

Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your Personal Data and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms in accordance with the Applicable Local Regulation to ensure your information is subject to adequate safeguards in the recipient country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

7. How We Keep Your Personal Data

We take steps to ensure that the Personal Data that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. For example, where you have created an account with us, we will keep a record of this for the period necessary for any finance and tax purposes.

We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

We always conducts a technical analysis to determine the appropriate retention period for each collected Personal Data, considering its nature, the need for collection and its purpose, as well as any retention requirements for compliance with obligations or the protection of rights.

We will retain Personal Data for the period necessary to fulfil the Data Processing Purposes unless a longer retention period is required or permitted by the Applicable Local Regulation (a period of 5 (five) years under prevailing laws), or upon you sending a written request to us for the deletion and disposal of your Personal Data. We may dispose Personal Data by way of deletion, erasure, sanitization and overwriting (subject to the limitations in our system) followed by a notification of our completion of satisfying your request. Your written request shall be acknowledgement that you will not hold us liable or responsible for our non-ability/non-performance to provide you future Service requests. In any event, we warrant that any Personal Data we dispose of shall be put beyond use for any purpose whatsoever.

8. Children

Our Services and website are not intended for, and should not be used by, children under the age of 18. We do not knowingly collect Personal Data from children under 18.

If we processes special categories of data or data of children or adolescents, you will always be informed about the specific purposes for which such information will be used. In both cases, we will process the data in compliance with the Applicable Local Regulation and always based on the best available information security measures and for the purpose of providing the Services contracted by you or partner commercial establishment.

9. Security and Passwords

You must keep your password and any other authentication information for our website and Services confidential. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us using the contact details below.

We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that you interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please stop using our Services and contact us immediately.

10. Advertising

We may use third-party advertising companies to serve advertisements regarding goods and Services that may be of interest to you when you access our websites, based on Personal Data relating to your access to and use of our Websites on any of your devices, as well as Personal Data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on your browser. They may also use these technologies, along with data they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop, and to make decisions about the advertisements you see.

11. Disclosing Your Information

We may share your Personal Data with any of our group companies from time to time (e.g. subsidiaries or ultimate holding company and its subsidiaries, as defined in Singapore Company Act 1967. We may also share your Personal Data with our suppliers, business partners and service providers, where they are helping us to market and advertise our Services as well as providing our Services to you. Personal Data transfer may be handled by Salesnap to ensure the security of the information during the transfer and compliance with the Applicable Local Regulation.

In addition to the above, we may disclose your Personal Data to other third parties in the following cases:

• for the purposes of research, evaluation, and analysis;
• in the event that we sell any business or assets, in which case we may disclose your Personal Data to the prospective buyer of such business or assets
• if we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers and visitors to our websites will be one of the transferred assets;
• if we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request; or
• to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

12. Your Rights

You have certain rights in relation to your Personal Data. These include the right to object to the Processing of your Personal Data for certain purposes, the right to access and rectify your Personal Data, and the ability to erase, restrict or receive a machine-readable copy of your Personal Data.

We will handle any request to exercise your rights in accordance with Applicable Local Regulation and any relevant legal exemptions. If you wish to exercise any of these rights please conduct us using the contact details below.

You also have the right to Data Portability which allows you to request the portability of your Personal Data, with Salesnap being required to share it with a third party indicated by you.

You may also have the right to complain to a data protection authority if you think we have processed your Personal Data in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate and resolve your concerns.

Our website and Services may, from time to time, contain links to and from third party websites and services such as our business and integration partners. If you follow a link to any of these websites and/or services, please note that they have their own privacy policy and we do not accept any responsibility or liability for them. Please check any such third party privacy policy before you submit any Personal Data to these websites or services.

13. Changes to This Privacy Policy

This privacy policy may be reviewed, updated, and changed annually or at any time, at the sole discretion of Salesnap, whenever any relevant fact or event warrants its early revision. The new privacy policy will be displayed on our website. The date this privacy policy was last updated appears at the bottom.

We may provide you with disclosures and alerts regarding the privacy policy or Personal Data we collected by posting them on our website or, if you are a user, by contacting you through our dashboard, email address and/or the physical address listed in your account, at our discretion. You agree that electronic disclosures and notices have the same meaning and effect as if we had provided you with hard copy disclosures. Disclosures and notices in relation to this privacy policy or Personal Data shall be considered to be received by you within 24 hours of the time they are posted to our website or, in the case of user, sent to through one of means listed in this paragraph.

In the unlikely event of a security incident or personal data breach, we shall manage the incident or the breach in accordance with our internal policies consistent with the applicable data protection laws and regulations, and which may include, among others, sending of timely notifications to you and/or the relevant data protection authority.

14. Consent and Acknowledgement

By accepting the privacy policy, you acknowledge that you have read and understood this privacy policy and you accept all of its terms. In particular, you agree and consent to us in Processing your Personal Data in accordance with this privacy policy. In circumstances where you provide us with Personal Data relating to other individuals (such as Personal Data relating to your spouse, family members, friends, or other parties), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, storage, use, disclosure, processing and disposal of his/her Personal Data by us.

15. Contact Us

Questions and comments regarding this privacy policy should be sent to: [email protected].

Our registered offices are located at 10 Anson Road #33-10 International Plaza Singapore 079903.

This privacy policy was last updated: 22.01.2025