Snap360 Privacy Policy

(Last updated – Sep 10, 2026)

In compliance with international data protection regulations (including Regulation (EU) 2016/679, GDPR and UK GDPR,, Organic Law 3/2018 (LOPDGDD), the Law on Information Society Services and Electronic Commerce (LSSI-CE), the California Consumer Privacy Act (CCPA), the Lei Geral de Proteção de Dados (LGPD-BR), the Federal Law on the Protection of Personal Data Held by Private Parties (Mexico) and any other applicable legislation in the jurisdictions where we operate), Snap360 (hereinafter, “Snap360” either “the Application”) guarantees the protection and confidentiality of personal data provided by users.

1. IDENTIFICATION OF THE PARTIES

Part	Main Role	Contact Information
Snap360	• Data Processor with respect to the audiovisual content generated and managed through the App. • Data Controller with respect to the registration, billing and support data of the users of the App.	NIF: B13744396 Address: C/ Correa de Araujo 2, CP 41702 Dos Hermanas (Seville), Spain Email: support@snap360app.com
User/Event Organizer	: Controller of the personal data contained in the 360 videos/photographs and in the information uploaded or generated in the App for your event.	Identification data provided during the registration process.

1 bis. ROLES OF RESPONSIBILITY AND GUARANTEES

Snap360 acts as the Data Processor with respect to the audiovisual content (360 videos and photographs), processing them exclusively on behalf of and under the instructions of the User/Organiser, who holds the status of Data Controller in accordance with Article 28 of the GDPR and equivalent regulations.
The User/Organiser, as the Data Controller, decides the purposes and means of the processing, controls the data and obtains the relevant legal basis and/or consents from the persons appearing in the material.
Indemnity (limited)
The User/Organiser shall indemnify and, where applicable, reimburse Snap360 for all costs, damages, penalties and expenses (including reasonable attorneys’ fees) arising from a breach of data protection regulations attributable to the User/Organiser, up to a maximum aggregate equivalent to the greater of:
(i) the fees paid to Snap360 in the twelve (12) months prior to the fact, or
(ii) €500,000.
Absence of proactive verification
Snap360 does not proactively review the legality, accuracy, or appropriateness of the data provided; Any review will be reactive and does not imply assumption of responsibility.
Disclaimer of Warranties
Unless legally required, Snap360 makes no express or implied warranties about the adequacy of the data provided or the suitability of the App for purposes other than those described.
Terminological equivalence: “Controller” and “Processor” are used interchangeably depending on the jurisdiction.

2. WHAT IS INCLUDED IN THE SUBSCRIPTION

By subscribing to the Snap360 , whether as a trial or paid subscriber ( “Snapper” ), User agrees to:

2.1 Acceptance of commercial communications

Receive, by email, SMS or push , information about:

Snap360 Services, Updates, and Features
Promotional offers or personalized discounts.
Surveys and improvement activities.
News about partnerships, collaborations, or expansions.

The User may revoke consent at any time (see Section 6 ).

2.2 International legal compliance

Snap360 makes it easy to meet:

GDPR and UK GDPR (EEA and UK).
CCPA/CPRA (California) and equivalent state laws.
LGPD-BR (Brazil).
Federal Law on the Protection of Personal Data (Mexico).

Where appropriate, Standard Contractual Clauses (EU SCC) , EU-US Data Privacy Framework (DPF) or other adequacy mechanisms apply.

3. PURPOSE OF DATA PROCESSING

Provision of the Service
- Capture, hosting and management of 360 videos/photos.
- Generation of QR codes and custom links.
- Personalization, download and analytics.
Commercial Communications
- Sending promotions, news, and usage studies.
Administrative and Legal Management
- Billing, support and rights attention.
- Compliance with legal and tax obligations.
- Legal basis: (i) performance of the contract (art. 6 1 b), (ii) consent (art. 6 1 a) for commercial communications, and (iii) compliance with legal obligations (art. 6 1 c)

4. POLICIES RELATED TO PHOTOGRAPHS AND VIDEOS

4.1 Consent and use of visual material

The User guarantees that they have the legal basis and the necessary consent and that they comply with applicable image and data protection regulations.

4.2 Snap360 Disclaimer of Liability

Snap360 will not be responsible for :

Illegal or unauthorized use of images/videos by the User or third parties.
Claims for lack of consent or violation of image rights.
Indirect damages, loss of profits or loss of opportunity arising from the use of the material.

4.3 Withdrawal of consent and deletion of content

The interested party may request removal; Snap360 will notify the user. In the event of unjustified inaction, Snap360 may block or delete the content.

5. CONSERVATION OF DATA

Data type	Standard term	Deletion criterion
Account and billing information	Active account + 5 years	Tax-tax blocking/elimination
Visual material (360 videos/photos)	30 days from last activity or according to User instructions	Automatic destruction/anonymization
Data for commercial communications	Until revocation of consent	Deletion ≤ 30 days after the request

6. RIGHTS OF USERS / INTERESTED PARTIES

Jurisdiction	Rights	Exercise
EU / UK (GDPR)	Access, Rectification, Deletion, Opposition, Portability, Limitation	Write to support@snap360app.com
US – CCPA/CPRA	Know, Delete, Correct, Opt-out sale/sharing, Non-discrimination	Web form or email
Brazil – LGPD	Confirmation, Access, Correction, Anonymization, Revocation, Portability	Web form or email

Snap360, as the Controller, will forward any request for audiovisual content to the User/Controller and will cooperate diligently (Article 28 GDPR).

6.1 Response and support times

– Where Snap360 acts as a Data Controller (account details, billing and commercial communications), we will acknowledge receipt of the request within a maximum of 5 business days and issue a final response within 1 month of receipt, in accordance with Article 12.3 GDPR. In case of complexity, we may extend the term up to 2 additional months, notifying the interested party before the expiration of the first month.

– When Snap360 acts as the Data Processor (audiovisual content managed by the User/Organizer), we will transfer the request to the Controller within a maximum period of 3 business days and assist them in attending to it within a period of no more than 10 business days, unless the Controller establishes a different deadline in writing.

These time limits do not affect the right of the data subject to lodge a complaint with the competent supervisory authority.

7. CANCELLATION POLICY

The User has 7 business days from the initial subscription to cancel without penalty, by sending an email to support@snap360app.com .

8. SECURITY, CONFIDENTIALITY AND INTERNATIONAL TRANSFERS

Technical and organizational measures: TLS/SSL encryption, access control, backups, environment segregation, and periodic audits (ISO/IEC 27001).
Breach Notification
Snap360 will notify the User/Controller without undue delay and, whenever reasonably possible, within 24 hours of becoming aware of the security breach. In any case, the notification will be made within 72 hours of its detection, and will include the information required by Article 33.3 GDPR (nature of the incident, categories of data affected, likely consequences and measures taken or proposed).
International transfers:
• Core infrastructure on Google Cloud Firebase (EU multi-zone regions), with AES-256 at rest encryption.
• SCC of the European Commission.
• EU-US DPF for certified suppliers in the USA
• Other valid mechanisms (adequacy decisions, BCRs, UK IDTA addendum).

8.1 Subprocessors

The up-to-date list of sub-processors is available on request by writing to support@snap360app.com, and is provided within a maximum of ten (10) business days.

Snap360 will notify the Registered Managers of any subprocessor additions or substitutions. The User/Controller may object in writing, in writing, before the new subprocessor starts processing. If the objection is reasonable and cannot be resolved in a commercially viable manner, the User may:

1. Request an equivalent treatment alternative, or

2. Suspend the affected operations, or

3. Resolve the service with respect to the impacted functions, without penalty.

Each sub-processor shall be bound by a contract that meets the requirements of Article 28 GDPR or equivalent regulations.

8.2 CONFIDENTIALITY AND STAFF TRAINING

Obligation of confidentiality
All staff, collaborators and third parties involved in the processing of personal data for Snap360 enter into specific confidentiality agreements or are subject to equivalent legal obligations. These obligations remain in force even after the termination of your employment or contractual relationship.

Need-to-know principle
Access to personal data is strictly limited to personnel who require it to perform their duties, applying role-based permission controls.

Continuous training
Snap360 provides training in data protection and information security at least once a year. The program covers:
1. GDPR/CCPA/LGPD principles.
2. Incident and breach management.
3. Good security practices (phishing, passwords, encryption).
4. Internal procedures to address the rights of the interested parties.

Evidence of compliance
Signed confidentiality records and training records are kept securely and will be provided to the Controller or the competent authority only when legally required and under a confidentiality agreement.

8.3 REGISTRATION OF PROCESSING ACTIVITIES

Snap360 maintains an internal Register of Processing Activities that complies with Article 30.2 of the GDPR and equivalent regulations in other jurisdictions. This register describes, at least:

The categories of processing performed by Snap360 as a Processor.
The categories of personal data and data subjects affected.
The purposes of the processing.
International transfers made and their safeguards applied.
An overview of technical and organizational security measures.

In addition, Snap360 will assist the User/Controller in carrying out impact assessments relating to data protection (DPIA, art. 35 GDPR) and will cooperate with any competent supervisory authority in the framework of investigations or inspections related to the services provided.

9. UPDATES AND MODIFICATIONS

Snap360 may modify this policy to reflect legal or service changes. The updated version will be posted on the website and registered users will be notified; substantial changes will, where appropriate, require explicit acceptance .

10. MINORS

Use of the App as a User/Organiser is reserved for persons over 18 years of age with the capacity to enter into contracts. Snap360 does not knowingly create accounts for or provide services to minors.

At the events covered with the App (weddings, communions, family or school celebrations) it is common for minors to appear in the audiovisual material. In that case:

The User/Organiser, in their capacity as Data Controller, is solely obliged to obtain and retain the express consent of the holders of parental authority or guardianship of each minor who appears, to the extent required by the legislation applicable in the country of the event.
Snap360 does not verify and cannot verify the age of the people appearing in the material, nor the existence of such consents, and accepts no liability whatsoever for their absence or insufficiency.
Should Snap360 become aware that material featuring minors is being processed without the required legal basis, it may block or delete that content immediately, without this giving rise to any right to compensation or refund.

Any holder of parental authority may request the deletion of material relating to a minor by writing to the contact address in this policy; Snap360 will forward the request to the Controller within the time limits in Section 6.1.

11. NO BIOMETRIC PROCESSING

Snap360 does not carry out biometric identification. In particular, the App does not generate facial templates, voiceprints, facial geometry or any other biometric identifier intended to uniquely identify or verify a natural person, within the meaning of Article 4(14) GDPR and of United States biometric privacy legislation (among others, the Illinois Biometric Information Privacy Act, the Texas CUBI and Washington HB 1493).

The motion detection, framing, filter and artificial intelligence frame generation features operate on the image without extracting or storing biometric identifiers, and are not used to recognise specific individuals or to build profiles.

Should the User/Organiser integrate on their own account third-party tools that do carry out biometric processing on the material generated with the App, they shall act as Controller of that processing for all purposes, must obtain the legal basis and the specific consents required by law, and shall hold Snap360 harmless in accordance with Section 1 bis.

12. AUDITS AND COMPLIANCE VERIFICATION

The User/Controller may verify Snap360's compliance with its obligations as Data Processor on the terms of Article 28(3)(h) GDPR, subject to the following conditions, which seek a reasonable balance between oversight and continuity of the service:

In the first instance, Snap360 will address the verification by providing the available documentation: current certifications, third-party audit reports and the summary of technical and organisational measures.
Should that documentation prove objectively insufficient, an on-site or remote audit may be carried out, with a minimum of thirty (30) calendar days' notice, during business hours, without interrupting the provision of the service and no more than once (1) every twelve (12) months, save at the express requirement of a supervisory authority or in the event of a documented security incident.
The audit shall be carried out by the Controller itself or by an independent auditor who is not a competitor of Snap360, subject to a prior confidentiality agreement, and its scope shall be limited to the processing carried out on behalf of that Controller.
The costs of the audit shall be borne by the Controller requesting it, including the reasonable costs of Snap360 staff time, unless the audit reveals a material breach attributable to Snap360.

13. INACTIVE ACCOUNTS AND AUTOMATIC DELETION

In addition to the time limits in Section 5, the following data hygiene rules apply, which reduce the exposure of stored material:

After twenty-four (24) months without activity on an account with no active subscription, Snap360 may irreversibly delete or anonymise the associated audiovisual material, having given notice to the User's email address at least thirty (30) days in advance.
Following cancellation of the subscription, the material will remain available for the period indicated in Section 5 and will thereafter be destroyed or anonymised, save where there is a legal retention obligation.
Deletion is final and irreversible. It is for the User/Organiser to download and keep their own copies of any material they need to retain; Snap360 does not provide a permanent archiving service and does not guarantee the recovery of deleted content.

14. REQUESTS FROM AUTHORITIES AND THIRD-PARTY REQUESTS

Snap360 will only disclose personal data to public authorities, courts or law enforcement bodies where there is an enforceable legal obligation or a valid and reasoned request addressed to Snap360.

Before complying with the request, Snap360 will check its formal validity and its proportionality, and will limit the disclosure to the minimum data strictly required.
Where the request concerns data processed on behalf of a User/Controller, Snap360 will inform them without undue delay so that they may exercise their rights, unless such notification is legally prohibited or would compromise an ongoing investigation.
Snap360 does not access the audiovisual content of events unless this is essential in order to provide support requested by the User, to comply with a legal obligation or to address a security incident, and always under the principle of minimum indispensable access.

15. PREVAILING VERSION AND SUPPLEMENTARY REGIME

This policy is published in several languages to make it easier to read. In the event of any discrepancy, contradiction or doubt as to interpretation between versions, the Spanish version published at snap360app.com shall prevail, and is the only one with legal force.

If any clause of this policy were declared void or unenforceable by a competent authority or court, that declaration shall not affect the validity of the remainder, which shall remain fully in force, and the affected clause shall be replaced by another valid clause of equivalent economic and legal effect.

Snap360's failure to exercise any right provided for in this policy shall not constitute a waiver of that right nor prevent its subsequent exercise.

16. ARTIFICIAL INTELLIGENCE

The App incorporates generative artificial intelligence features, in particular the creation of frames and graphic elements from the descriptions written by the User. In relation to these features:

Nature of the result. Material generated by AI is delivered as is, with no warranty of originality, accuracy, availability or fitness for a particular purpose. Different generative models may produce similar results from similar descriptions, so that Snap360 does not guarantee the exclusivity or uniqueness of any generated frame.
Responsibility for what is requested. The User is solely responsible for the descriptions they enter and for the use they make of the result. It is expressly prohibited to request content that reproduces third-party trade marks, logos, characters or works, the likeness or voice of real people without their consent, or unlawful, violent, sexual or discriminatory material.
Prior human review. The User undertakes to review the generated material before displaying or delivering it to the attendees of an event. Snap360 does not review the result in advance and is not liable for what the User decides to publish or deliver.
Providers. The descriptions entered may be processed on the infrastructure of third-party model providers, which act as sub-processors on the terms of Section 8.1. The User undertakes not to include personal data, special category data or confidential information in those descriptions.
Model training. Snap360 does not use the audiovisual material of events or its Users' descriptions to train its own models or those of third parties, save with the express, specific and revocable consent of the Controller.
Transparency. Where applicable law so requires, including Regulation (EU) 2024/1689 on Artificial Intelligence, it is for the User to inform attendees that the material delivered includes artificially generated elements.
No automated decisions. These features do not build profiles or take automated decisions producing legal or similarly significant effects on individuals, within the meaning of Article 22 GDPR.

The temporary unavailability or withdrawal of an artificial intelligence feature, whether by decision of the model provider or due to a regulatory change, shall not give rise to a refund nor constitute a breach of contract, provided that the rest of the service continues to be supplied.

17. REFUND REQUESTS IN THE APP STORES

Where a User asks the Apple App Store or Google Play Store for a refund of a purchase made within the App, the store may require Snap360 to provide information about the use of the service in order to resolve that request, and allows a very short response deadline. Snap360 addresses those requests on the following terms.

Data processed	Age of the account, actual delivery of what was contracted, extent of use of the service since the purchase, history of previous purchases and refunds in the App, and availability of a trial version prior to the purchase. This is aggregated usage data, not content.
Data excluded	The audiovisual material of events, the content of the galleries and any attendee data are excluded: they are not disclosed to the store under any circumstances.
Recipient	The app store in which the purchase was made (Apple or Google), which acts as an independent controller in resolving the request. The disclosure may be made directly or through the technology providers that Snap360 uses for the management of purchases and subscriptions, which act as processors on Snap360's behalf. It is not disclosed to any other recipient.
Purpose	To resolve the refund request with real information and to prevent the fraudulent use of refunds.
Legal basis	Snap360's legitimate interest in managing financial disputes and in preventing fraud, in accordance with Article 6(1)(f) GDPR, balanced against the User's rights and limited to usage data.
Retention	The information is transmitted in response to each specific request. Snap360 does not create with it any additional record outside the general time limits in Section 5.
Decision	It is resolved by the store. No automated decisions producing legal or similarly significant effects on the User are taken within the meaning of Article 22 GDPR.

The User may object to this processing at any time by writing to support@snap360app.com, without this affecting their right to request the refund from the store or the other rights recognised in Section 6.

CONTACT

Snap360
C/ Correa de Araujo 2, CP 41702, Dos Hermanas (Seville), Spain
✉️ support@snap360app.com

ANNEX – MOBILE TERMS OF SERVICE (SMS)

Mobile Terms of Service – Last updated: September 10, 2026

The Snap360 mobile message service (the “Service”) is operated by Snap360 (“Snap360”, “we”, or “us”). Your use of the Service constitutes your agreement to these terms and conditions (“Mobile Terms”). We may modify or cancel the Service or any of its features without notice. To the extent permitted by applicable law, we may also modify these Mobile Terms at any time and your continued use of the Service following the effective date of any such changes shall constitute your acceptance of such changes.

By consenting to Snap360’s SMS/text messaging service, you agree to receive recurring SMS/text messages from and on behalf of Snap360 through your wireless provider to the mobile number you provided, even if your mobile number is registered on any state or federal Do Not Call list. Text messages may be sent using an automatic telephone dialing system or other technology. Promotional messages may include promotions, specials, and other marketing offers (eg, cart reminders).

You understand that you do not have to sign up for this program in order to make any purchases, and your consent is not a condition of any purchase with Snap360. Your participation in this program is completely voluntary.

We do not charge for the Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message varies frequency. Message and data rates may apply. Check your mobile plan and contact your wireless provider for details. You are solely responsible for all charges related to SMS/text messages, including charges from your wireless provider.

You may opt-out of the Service at any time. Text the single keyword command STOP to Snap360 or click the unsubscribe link (where available) in any text message to cancel. You’ll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other Snap360 mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.

For Service support or assistance, text HELP to Snap360 or email support@snap360app.com .

We may change any short code or telephone number we use to operate the Service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP or HELP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages.

The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. If you get a new mobile number, you will need to sign up for the program with your new number.

To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the Service, any errors in such information, and/or any action you may or may not take in reliance on the information or Service.

We respect your right to privacy. To see how we collect and use your personal information, please see our Privacy Notice.