Privacy Policy for Snap App
1. Introduction
This Privacy Policy describes how Snap Global Sdn Bhd ("Snap," "we," "our," or "us") collects, uses, and protects your information when you use the Snap mobile application ("App") - a mobile AI assistant that provides ingredient safety recommendations, product transparency insights, and photo-based AI functionality for health-conscious consumers.
We comply with Malaysia's Personal Data Protection Act 2010 (PDPA), Apple App Store guidelines, Google Play Store policies, and other applicable data protection laws. While Snap is currently offered in Malaysia, we will update this policy if we expand into jurisdictions governed by additional regulations such as the GDPR.
Contact Information:
Company: Snap Global Sdn Bhd
Email: adryz@snaplah.app
2. Information We Collect
2.1 Photos and Visual Content
What We Collect:
Photos you take or upload within the App (with your explicit permission)
Image metadata (file size, type, and timestamps)
Location data embedded in photos (if present and permission is granted)
How We Use Photos:
AI analysis for ingredient extraction and product identification
Improving visual recognition features
Generating anonymized usage insights
Temporarily displaying user-uploaded product photos as placeholder images for products not yet in our system, until replaced with a generic product image
We do not access your entire gallery. The App only accesses the specific photos you select and grants full ownership and control to you. By uploading photos through the "Add Product" function, you grant Snap a limited license to use the image for the above purpose. This limited license allows us to display the photo publicly in the app as a temporary product image, but we do not claim ownership. You can request removal at any time.
2.2 AI Conversation Data
What We Collect:
Messages you send to the AI assistant (text and optional voice-to-text input)
Conversation history stored on-device (with option to delete anytime)
How We Use AI Data:
Responding to your queries and providing product safety information
Improving AI performance using anonymized conversations
2.3 Ingredient Safety Queries
What We Collect:
Ingredient names, keywords, and search preferences
Your alert preferences (e.g., "avoid parabens")
How We Use This Data:
Delivering personalized safety scores and warnings
Anonymized safety trend reporting for internal analysis
2.4 Standard App Data
Account Data:
Email address, name or nickname (if provided)
Age and gender
Skin type, hair type, allergies, sensitivities
Presence of young children (if disclosed)
Device & Technical Info:
Device model, OS version, language
App version, usage logs, feature interactions
Crash logs and diagnostics
IP address and general location (city/country level)
Marketing Preferences:
Email subscriptions and push notification settings
3. How We Use Your Information
3.1 Core App Functions
Product scanning and photo ingredient detection
AI-powered recommendations and chat responses
Ingredient safety evaluations
Displaying temporary placeholder product images (from user uploads)
3.2 App Improvement
Fixing technical issues and debugging
Understanding user patterns to prioritize new features
Training and optimizing AI models (using anonymized data)
3.3 Communication
Customer support and issue resolution
App updates and feature announcements
Optional promotional emails (with opt-in consent)
3.4 Legal and Security Compliance
PDPA and local law compliance
Preventing fraud, abuse, or unauthorized access
Fulfilling legal obligations (e.g., data access requests)
4. Legal Basis for Processing (PDPA Compliance)
We process your personal data under the following lawful grounds:
Consent: Explicit consent for photos, sensitive info, and AI data. Consent is collected through explicit user actions such as checking a consent box, tapping 'Agree' on permission prompts, or adjusting preferences in settings.
Contractual: To provide app functionality and services
Legitimate Interest: Improving service quality and security
Legal Obligation: For statutory or law enforcement requirements
5. Data Sharing and Third Parties
5.1 We Do Not Sell Your Data
We do not sell, rent, or trade your personal information.
5.2 Aggregated Data Sharing
We may share anonymized and aggregated data (e.g., trends in ingredient concerns, usage volumes) with partners, researchers, or brands. This data contains no identifiable information and is used to improve industry awareness and safety.
5.3 Service Providers
We work with vetted third-party providers to:
Store your data securely (e.g., Supabase, DigitalOcean)
Deliver conversational AI responses
Analyze usage (e.g., Google Firebase)
Handle crash diagnostics
All vendors must meet strict security and data protection requirements.
5.4 User-Initiated Sharing
If you choose to share:
Your product scans or safety scores to social platforms
App feedback or testimonials
5.5 Legal Obligations
We may disclose data if required by Malaysian authorities, court orders, or to protect user safety.
6. AI and Safety Disclaimers
6.1 AI Limitations
Our AI is for general product assistance, not professional advice
Responses may contain inaccuracies or omissions
You are responsible for verifying safety claims and product decisions
6.2 Ingredient Safety
Our ratings are educational tools, not medical or legal advice
We cannot guarantee the accuracy or completeness of the ingredient information provided. Our data is aggregated from publicly available sources and intended to simplify access for consumer convenience
Ingredient lists, risk scores, and product recommendations should not be considered exhaustive or definitive
Snap does not validate claims made by product manufacturers
Individual sensitivities may vary - always check product labels
Consumers are ultimately responsible for researching and making informed decisions before using any product
Consult health professionals if uncertain about product usage
Use of this App is at your own risk. Snap disclaims all liability for harm or damages arising from reliance on the ingredient or product information provided
7. Data Security and International Transfers
7.1 Security Measures
Encryption for all data in transit and storage
Role-based access control and authentication
Regular vulnerability testing and security reviews
7.2 Data Location
Servers may be located in Singapore or other countries with adequate protection laws
By using Snap, you consent to the secure overseas processing of your data
8. Data Retention
We retain your data for as long as your account is active or as needed to provide you with personalized AI features, unless you request deletion.
Photos: Stored until you delete them or your account
AI Chats: 90 days unless you delete them
Account Info: Retained until account deletion is requested, then erased within 30 days
Usage Data: Up to 26 months for app optimization
You may request deletion at any time via email or in-app settings. Upon request, we will securely delete your personal data unless retention is required for legal or legitimate business reasons.
9. Your Rights Under PDPA
Access: Request a copy of your data
Correction: Fix inaccurate personal info
Deletion: Close your account and erase your data
Consent Withdrawal: Revoke permission for specific data types
To exercise your rights, email us at [Insert Privacy Contact Email]. We respond within 21 days.
10. Children’s Privacy
Snap is not intended for users under 18. If you are under 18, you must obtain parental or guardian consent.
We do not knowingly collect data from children under 13. Parents may request access or deletion of their child’s data.
If you disclose that you have young children, this information may be used to personalize AI-generated product recommendations, for example, to suggest products that are safe for children. This data is optional and will only be used to enhance the safety and relevance of product suggestions.
11. App Store and Google Play Compliance
11.1 Disclosures
All permissions (e.g., camera, microphone, gallery) require your explicit approval
Apple Privacy Nutrition Label and Google Data Safety disclosures reflect actual practices
11.2 User Controls
iOS: Manage permissions under Settings > Privacy
Android: Manage in device App Settings
In-App: Privacy and consent toggles available under Profile > Settings
12. Updates to This Policy
We may update this Privacy Policy periodically. We’ll notify you:
Via in-app alerts for major changes
By email if applicable
The updated effective date will always be shown at the top.
13. Contact and Complaints
Contact Us:
Privacy Email: adryz@snaplah.app
For PDPA Complaints:
Personal Data Protection Commissioner (Malaysia)
Website: https://www.pdp.gov.my
Address: Aras 6, Kompleks Kementerian Komunikasi dan Multimedia, Lot 4G9, Persiaran Perdana, Presint 4, 62100 Putrajaya
15. Third-Party Products and Listings
Snap may display product names, images, or information sourced from third-party manufacturers, retailers, or public databases. We do not endorse or verify the accuracy of these listings. All product trademarks and copyrights remain with their respective owners. Snap is not responsible for the safety, effectiveness, or labeling of any third-party products shown in the app.
16. No Health or Medical Claims
Snap does not provide health, dermatological, or medical advice. The ingredient safety score is not a health rating and should not be used as a substitute for consulting qualified professionals.
17. Consent and Agreement
By using Snap, you:
Confirm that you have read and understood this Privacy Policy
Consent to the data practices described
Acknowledge the limitations of AI-generated safety information
Agree to independently verify ingredient safety and product decisions
For users under 18: parental or guardian consent is required.
Document Version: 1.0
Governing Law: Malaysia’s Personal Data Protection Act 2010
Languages Available: English, Bahasa Malaysia