Privacy Policy for Snap360App
(Last updated – September 10, 2026)
In compliance with international data protection regulations (including Regulation (EU) 2016/679, the GDPR, and the UK GDPR, Spanish Organic Law 3/2018 (LOPDGDD), the Spanish Information Society Services and Electronic Commerce Act (LSSI-CE), the California Consumer Privacy Act (CCPA), the Brazilian Lei Geral de Proteção de Dados (LGPD-BR), the Mexican Federal Law on the Protection of Personal Data Held by Private Parties and any other applicable legislation in the jurisdictions where we operate), Snap360 (hereinafter “Snap360” or “the Application”) guarantees the protection and confidentiality of the personal data provided by users.
1. Identification of the Parties
| Party | Main role | Contact details |
|---|---|---|
| Snap360 | • Processor with respect to the audiovisual content generated and managed through the App. • Controller with respect to the registration, billing and support data of App users. | Tax ID (NIF): B13744396 Address: C/ Correa de Araujo 2, 41702 Dos Hermanas (Seville), Spain Email: support@snap360app.com |
| User / Event organizer | Controller of the personal data contained in the 360 videos/photos and in the information uploaded to or generated in the App for their event. | Identification details provided during sign-up. |
1 bis. Roles, Responsibilities and Warranties
Snap360 acts as Processor with respect to the audiovisual content (360 videos and photos), processing it exclusively on behalf of and under the instructions of the User/Organizer, who is the Controller under Article 28 GDPR and equivalent regulations.
The User/Organizer, as Controller, determines the purposes and means of the processing, controls the data and obtains the relevant legal basis and/or consents from the people who appear in the material.
Indemnity (limited)
The User/Organizer shall hold Snap360 harmless and, where applicable, reimburse it for all costs, damages, penalties and expenses (including reasonable attorneys' fees) arising from a breach of data protection regulations attributable to the User/Organizer, up to an aggregate maximum equal to the greater of:
(i) the fees paid to Snap360 in the twelve (12) months prior to the event, or
(ii) €500,000.No proactive verification
Snap360 does not proactively review the lawfulness, accuracy or suitability of the data provided; any review will be reactive and does not imply any assumption of liability.Disclaimer of warranties
Except where mandatory by law, Snap360 gives no express or implied warranties as to the suitability of the data supplied or the fitness of the App for purposes other than those described.Terminological equivalence: “Controller/Responsable” and “Processor/Encargado” are used interchangeably depending on the jurisdiction.
2. What the Subscription Includes
By subscribing to Snap360, whether during a trial period or as a paying subscriber (“Snapper”), the User agrees to:
2.1 Acceptance of commercial communications
Receive, by email, SMS or push notification, information about:
Snap360 services, updates and features.
Promotional offers or personalized discounts.
Surveys and improvement activities.
News about partnerships, collaborations or expansions.
The same applies to anyone who joins a waitlist on the website, such as the SNAPPHOTO for Windows one: by ticking its box they accept these commercial communications.
The User may withdraw their consent at any time (see Section 6).
2.2 International legal compliance
Snap360 facilitates compliance with:
GDPR and UK GDPR (EEA and United Kingdom).
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 SCCs), the 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 personalized links.
Customization, download and analytics.
Commercial Communications
Sending promotions, news and usage studies.
Administrative and Legal Management
Billing, support and handling of data subject rights.
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 Relating to Photos and Videos
4.1 Consent and use of visual material
The User warrants that they have the necessary legal basis and consent and that they comply with the applicable image rights and data protection regulations.
4.2 Exclusion of Snap360's liability
Snap360 shall not be liable for:
Unlawful or unauthorized use of images/videos by the User or third parties.
Claims for lack of consent or infringement 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 removal of content
The data subject may request removal; Snap360 will notify the User. In the event of unjustified inaction, Snap360 may block or remove the content.
5. Data Retention
| Type of data | Standard period | Deletion criterion |
|---|---|---|
| Account and billing data | Active account + 5 years | Blocking/deletion in line with tax rules |
| Visual material (360 videos/photos) | 30 days from last activity or according to the User's instructions | Automatic destruction/anonymization |
| Data for commercial communications | Until consent is withdrawn | Deletion ≤ 30 days after the request |
6. Rights of Users / Data Subjects
| Jurisdiction | Rights | How to exercise them |
|---|---|---|
| EU / UK (GDPR) | Access, Rectification, Erasure, Objection, Portability, Restriction | Write to support@snap360app.com |
| USA – CCPA/CPRA | Know, Delete, Correct, Opt-out of sale/sharing, Non-discrimination | Web form or email |
| Brazil – LGPD | Confirmation, Access, Correction, Anonymization, Revocation, Portability | Web form or email |
Snap360, as Processor, will forward any request concerning audiovisual content to the User/Controller and will cooperate diligently (Art. 28 GDPR).
6.1 Response times and assistance
– Where Snap360 acts as Controller (account, billing and commercial communications data), 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 complex cases, we may extend this period by up to 2 additional months, notifying the data subject before the first month expires.
– Where Snap360 acts as Processor (audiovisual content managed by the User/Organizer), we will forward the request to the Controller within a maximum of 3 business days and assist them in handling it within no more than 10 business days, unless the Controller sets a different period in writing.
These periods do not affect the data subject's right 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 the first 24 hours of becoming aware of the security breach. In any event, notification will be made before 72 hours have elapsed from 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:
• Main infrastructure on Google Cloud Firebase (multi-zone EU regions), with AES-256 encryption at rest.
• European Commission SCCs.
• EU-US DPF for certified providers in the USA.
• Other valid mechanisms (adequacy decisions, BCRs, UK IDTA addenda).
8.1 Sub-processors
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 registered Controllers of any addition or replacement of a sub-processor. The User/Controller may object, in writing and stating its reasons, before the new sub-processor begins processing. If the objection is reasonable and cannot be resolved in a commercially viable way, the User may:
1. Request an equivalent processing alternative, or
2. Suspend the affected operations, or
3. Terminate the service with respect to the affected functions, without penalty.
Each sub-processor will be bound by a contract that meets the requirements of Article 28 GDPR or equivalent regulations.
8.2 Confidentiality and Staff Training
- Confidentiality obligation
All staff, collaborators and third parties involved in processing personal data for Snap360 sign specific confidentiality agreements or are subject to equivalent legal obligations. These obligations remain in force even after their employment or contractual relationship ends.
- “Need-to-know” principle
Access to personal data is strictly limited to the staff who need it to perform their duties, applying role-based permission controls.
- Ongoing training
Snap360 provides training in data protection and information security at least once a year. The program covers:
- GDPR/CCPA/LGPD principles.
- Incident and breach management.
- Good security practices (phishing, passwords, encryption).
- Internal procedures for handling data subject rights.
- Evidence of compliance
Signed confidentiality records and training certificates are kept securely and will be provided to the Controller or to the competent authority only when legally required and under a confidentiality agreement.
8.3 Record of Processing Activities
Snap360 maintains an internal Record of Processing Activities that complies with Article 30(2) GDPR and equivalent regulations in other jurisdictions. This record describes, at a minimum:
The categories of processing carried out by Snap360 as Processor.
The categories of personal data and of data subjects concerned.
The purposes of the processing.
The international transfers carried out and the safeguards applied.
A general description of the technical and organizational security measures.
In addition, Snap360 will assist the User/Controller in carrying out data protection impact assessments (DPIA, Art. 35 GDPR) and will cooperate with any competent supervisory authority in investigations or inspections relating to the services provided.
9. Updates and Amendments
Snap360 may amend this policy to reflect legal or service changes. The updated version will be published on the website and notified to registered users; substantial changes will require, where appropriate, new explicit acceptance.
Contact
Snap360
C/ Correa de Araujo 2, 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 (e.g., 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 frequency varies. 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.
10. Minors
Use of the App as a User/Organizer is reserved for persons over 18 years of age with legal 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, first communions, family or school celebrations), it is common for minors to appear in the audiovisual material. In that case:
- The User/Organizer, as Controller, is solely responsible for obtaining and keeping the express consent of the holders of parental authority or guardianship of each minor who appears, to the extent required by the applicable regulations in the country of the event.
- Snap360 does not and cannot verify the age of the people who appear in the material or the existence of such consents, and accepts no liability whatsoever for their absence or insufficiency.
- If Snap360 becomes aware that material involving minors is being processed without the required legal basis, it may block or delete that content immediately, without 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 periods set out in Section 6.1.
11. No Biometric Processing
Snap360 does not carry out biometric identification. In particular, the App does not generate face templates, voiceprints, face 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 US biometric privacy legislation (including, 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 recognize specific individuals or to create profiles.
If the User/Organizer integrates, on their own initiative, third-party tools that do carry out biometric processing on the material generated with the App, they will act as Controller of that processing for all purposes, must obtain the legal basis and the specific consents required by the regulations and will 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 Processor under the terms of Article 28(3)(h) GDPR, subject to the following conditions, which seek a reasonable balance between oversight and continuity of service:
- In the first instance, Snap360 will respond to the verification by providing the available documentation: current certifications, third-party audit reports and the summary of technical and organizational measures.
- If that documentation proves objectively insufficient, an on-site or remote audit may be carried out, with at least thirty (30) calendar days' prior notice, during business hours, without interrupting the provision of the service and no more than once (1) every twelve (12) months, unless expressly required by a supervisory authority or in the event of a proven security incident.
- The audit will 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 will be limited to the processing carried out on behalf of that Controller.
- The costs of the audit are borne by the Controller requesting it, including the reasonable costs of the time spent by Snap360 staff, unless the audit reveals a material breach attributable to Snap360.
13. Inactive Accounts and Automatic Deletion
In addition to the periods in Section 5, the following data hygiene rules apply, which reduce the exposure of stored material:
- After twenty-four (24) months of inactivity in an account without an active subscription, Snap360 may irreversibly delete or anonymize the associated audiovisual material, after giving notice to the User's email address at least thirty (30) days in advance.
- After the subscription is cancelled, the material will remain available for the period indicated in Section 5 and will then be destroyed or anonymized, unless there is a legal obligation to retain it.
- Deletion is final and irreversible. It is the User/Organizer's responsibility to download and keep their own copies of any material they need to keep; 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 agencies where there is an enforceable legal obligation or a valid and reasoned request addressed to Snap360.
- Before responding to the request, Snap360 will check its formal validity and 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 can exercise their rights, unless notification is legally prohibited or would compromise an ongoing investigation.
- Snap360 does not access the audiovisual content of events unless this is essential to provide support requested by the User, to comply with a legal obligation or to handle a security incident, and always under the principle of minimum necessary 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 of interpretation between versions, the Spanish version published on snap360app.com shall prevail, as it is the only legally binding version.
If any clause of this policy is declared null or unenforceable by a competent authority or court, such declaration shall not affect the validity of the remainder, which shall remain in full force and effect, and the affected clause shall be replaced by a valid one with equivalent economic and legal effect.
Failure by Snap360 to exercise any right provided for in this policy shall not constitute a waiver of that right or prevent its subsequent exercise.
16. Artificial Intelligence
The App includes generative artificial intelligence features, in particular the creation of frames and graphic elements from descriptions written by the User. With respect to these features:
- Nature of the output. AI-generated material is delivered as is, without any guarantee of originality, accuracy, availability or fitness for a particular purpose. Different generative models may produce similar results from similar descriptions, so 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 output. It is expressly prohibited to request content that reproduces third-party trademarks, logos, characters or works, the image 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 showing or delivering it to the attendees of an event. Snap360 does not review the output in advance and is not responsible 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 under the terms of Section 8.1. The User undertakes not to include personal data, special category data or confidential information in such descriptions.
- Model training. Snap360 does not use the audiovisual material of events or its Users' descriptions to train its own or third-party models, except with the express, specific and revocable consent of the Controller.
- Transparency. Where required by applicable law, including Regulation (EU) 2024/1689 on Artificial Intelligence, it is the User's responsibility to inform attendees that the material delivered includes artificially generated elements.
- No automated decisions. These features do not create profiles or make automated decisions with legal or similarly significant effects on individuals, within the meaning of Article 22 GDPR.
The temporary unavailability or withdrawal of an artificial intelligence feature, due to a decision by the model provider or a regulatory change, shall not give rise to a refund or constitute a breach of contract, provided that the rest of the service continues to be provided.
17. Refund Requests in the App Stores
When a User asks the Apple App Store or the Google Play Store for a refund of a purchase made within the App, the store may ask Snap360 for information about the use of the service in order to resolve that request, and grants a very short response time. Snap360 handles these requests on the following terms.
| Data processed | Account age, actual delivery of what was purchased, extent of use of the service since the purchase, history of previous purchases and refunds in the App, and availability of a trial version before the purchase. These are aggregated usage data, not content. |
|---|---|
| Data excluded | The audiovisual material of the events, the content of the galleries and any attendee data are excluded: they are never disclosed to the store. |
| 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 to manage purchases and subscriptions, which act as processors on behalf of Snap360. The data is not disclosed to any other recipient. |
| Purpose | Resolving the refund request with accurate information and preventing fraudulent use of refunds. |
| Legal basis | Snap360's legitimate interest in managing financial disputes and preventing fraud, under 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 any additional record with it beyond the general periods in Section 5. |
| Decision | The store decides. No automated decisions with legal or similarly significant effects on the User are made, within the meaning of Article 22 GDPR. |
The User may object to this processing at any time by writing to support@snap360app.com, without affecting their right to request a refund from the store or the other rights recognized in Section 6.