Privacy Policy
Last modified: February 2025
Last modified: December 2024
**I. INTRODUCTION. REGIONAL PATTERNS (CALIFORNIA)**
Mykola Makarevych (“I,” “me,” or “my”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains my data protection policy and describes the types of information I may process when you install and/or use the “Snap Drive” software application for mobile devices (the “App,” “my App”).
When I refer to personal data (or personal information), I mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data. It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social status.
This Privacy policy applies to all users and others who access the App (“Users”).
For the purposes of the GDPR, I am the data controller, unless otherwise stated.
PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW YOUR PERSONAL INFORMATION MAY BE PROCESSED. WHEN YOU USE THE APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.
**IF YOU ARE A CALIFORNIA RESIDENT, PLEASE READ THE FOLLOWING IMPORTANT NOTICE**
Under the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request:
- The categories of personal information that are processed;
- The categories of sources from which personal information is obtained;
- The purpose for processing user personal data;
- The categories of third parties with whom I may share your personal information;
- The specific pieces of personal information that I might have obtained about a particular user, provided that the data given in the request is reliable enough and allows me to identify the user.
Please use the navigation links through this Privacy policy:
**PERSONAL INFORMATION**
All about the categories of information, its sources, and purposes of processing >>
Please note that according to the CCPA, personal information does not include de-identified or aggregated consumer information.
**SHARING**
How your information can be shared >>
Please note that all third parties that are engaged in processing user data are service providers that use such information on the basis of an agreement and pursuant to a business purpose.
**OPT-OUT OPTIONS**
If you don’t want me to process your personal information anymore, please contact me through **welcome@absofttech.com**. In most cases, there is no way to maintain the App’s further operation without functional data; therefore, you will be advised to remove the App from your device.
If you don’t want me to share device identifiers and geolocation data with service providers, please check your device settings to opt out as described below >>
**REQUESTS**
To submit a verifiable consumer request for access, portability, or deletion of personal data, please contact me through **welcome@absofttech.com**. Please include in the text of your appeal the wording "Your rights to maintain confidentiality in the state of California.”
When submitting a verifiable request, you should be ready to:
- Provide sufficient information that allows me to reasonably verify you are the person about whom I collected personal information or an authorized representative, which may include: name, address, city, state, zip code, and email address. I may use this information to surface a series of security questions to verify your identity. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization or a power of attorney signed by you.
- Describe your request with sufficient detail that allows me to properly understand, evaluate, and respond to it.
I will not be able to respond to your request or provide you with personal information if I cannot:
(i) verify your identity or authority to make the request; or
(ii) confirm that the personal information relates to you. I may ask you for additional information or documents to verify your identity. I may also carry out checks, including with third-party identity verification services, to verify your identity before taking any action with your personal information. This is regarded as a safeguard measure to prevent disclosure of your personal information under a fake or scam request.
I ensure that personal information provided in a verifiable consumer request will be used only to verify the requestor’s identity or authority to make the request and not for any other purpose. I will keep it for the adequate term reasonably needed for the purpose described above and delete it after the purpose is fulfilled.
I try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If I require more time, I will inform you of the reason and extension period in writing. Please note that I am only required to respond to two requests per customer each year.
**EQUAL RIGHTS**
Nothing in the way I deal with your request shall be interpreted as discrimination, which means that I will not set up different pricing or products, or different levels or quality of services for you, if you choose to exercise your rights. However, in some circumstances, I may not be able to provide services if you choose to delete your personal information from my records.
**SALE OF DATA**
I do not sell any of your personal data to third parties.
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**II. INFORMATION I PROCESS**
There are several categories of information that can be processed.
**Functional Information**
I ask for and process the following personal information when you use the App. This information is necessary for the adequate performance of the contract between you and me. Without such information, it is impossible to provide complete functionality of the App and perform the requested services. The following categories of data may be processed:
- **Activity Information** directly related to your use of the App. After you set the relevant settings on your device, I may have technical access to your camera or Photos to analyze the picture(s) that you take or upload through the App. However, I cannot collect, store, or use the files contained in your Photos unless you upload such files to the App or otherwise share them.
- **Information associated with your account within the App.** If you register within the App by linking your account within the App to your Apple ID, Google, or Facebook account, the following categories of data may be processed: method of your registration within the App (sign in with Apple/Google/Facebook), email address associated with your account.
- **User Content** which can be uploaded to the App due to its basic or extended functions, including using the App’s Snap Drive identification feature. Along with this Privacy policy, User Content is governed by my Terms of Use. Please note that it is prohibited to upload or submit to the App any User Content that contains your personal data and/or protected personal data of other individuals (first and last names, addresses, phone numbers, email addresses, etc.).
- **Contact Information** (name, email address, as well as any other content included in the email) which you may fill in by yourself when you contact me via email or support form. I collect, store, and process it using my cloud storage provider (Amazon.com, Inc.). I use such information to respond effectively to your inquiry, fulfill your requests, send you communications that you request, and perform the requested services.
**Information That Is Processed Automatically**
On the basis of your permission, I use third-party automatic data processing technologies (advertising or analytics tools) to analyze certain information sent by your device via my App (Identity for Advertisers). Some integrated advertising or analytics tools (check Section IV to see the list of them) launch automated processing of your personal data, including profiling, which means any form of automated processing of personal data used to evaluate certain personal aspects relating to you, in particular to analyze or predict aspects concerning your personal preferences, interests, behavior, location, or movements (see the list of data described below). Processing information through automatic data processing technologies starts automatically once you allow my App to track your activity. You can withdraw your permission at any time—please check opt-out options in Section VIII below.
I may process some information about your device and your user behavior on the grounds of my legitimate interest. This information falls within categories of data described above in the subsection “Information That Is Processed Automatically.” It is generally non-personal, i.e., it does not, on its own, permit direct association with any specific individual, and I may access it only in aggregated form. I use this information for improving my App and giving my users the best experience.
- **Device Details.** When you use a mobile device (tablet/phone/smartwatch) to access my App, some details about your device are reported, including “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device (but not your personality). Device identifiers enable generalized reporting or personalized content and ads by third parties.
- **What data can be processed:**
- Information about the device itself: type of your device, type of operating system and its version, model and manufacturer, screen size, screen density, orientation, audio volume and battery, battery life, loading time, latency, framerate, device memory usage.
- Information about the internet connection: mobile carrier, network provider, network type, IP address, timestamp and duration of sessions, speed, browser.
- Location-related information: IP address, the country code/region/state/city associated with your SIM card or your device, language setting, time zone, neighboring commercial points of interest (e.g., “coffee shop”).
- Other device identifiers: e.g., user identifiers (if they are set up by the App’s developer).
**Information about the applications.** Name, API key (identifier for application), version, properties of my App can be reported for automated processing and analysis. Some services also record the list of applications and/or processes which are installed or run on your device.
**Cookies and similar technologies.** When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information which is downloaded to your device when you access the App. The text file is then sent back to the server each time you use the App. This enables me to operate the App more effectively. For example, I will know how many users access specific areas or features within my App and which links or ads they clicked on. I use this aggregated information to understand and optimize how my App is used, improve my marketing efforts, and provide content and features that are of interest to you. I may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
**Log file information.** Log file information is automatically reported each time you make a request to access the App. It can also be provided when the App is installed on your device. When you use my App, analytics tools automatically record certain log file information, including time and date when you start and stop using the App, and how you interact with the App.
**Ad-related information.** The following data might be reported about the ads you can view: the date and time a particular ad is served; a record if that ad was “clicked” or if it was shown as a “conversion” event; what the ad offer is about; what type of ad it is (e.g., text, image, or video); which ad placement is involved (where the ad offer is displayed within the App); whether you respond to the ad.
**In-app events.** When you use my App, analytics tools automatically record your activity information (taps, scrolls, screens you visited in the App, tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, method of limiting the processing of user data).
Information provided automatically to advertising or analytics tools does not generally come under my control; therefore, I cannot be responsible for processing such information. Please note that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to my scope of responsibility. In cases where your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data that were already recorded in its databases (e.g., your age, gender, or other demographic indication). I do not control, supervise, or stand surety for how third parties process your personal data that might be collected by their own means (not through my App). Any information request regarding the disclosure of your personal information should be directed to such third parties (see Section IV).
**Payment Information**
My e-commerce provider (Apple) is responsible for billing, processing, and charging for in-app purchases, handles your personal information, and keeps it absolutely safe and secure. This information is processed as part of the performance of the contract between you and me. I cannot access or use your credit or debit card information.
You may access the applicable “in-app” purchase rules and policies directly from the app stores.
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**III. THE PURPOSES OF PROCESSING YOUR PERSONAL DATA**
My mission is to constantly improve my App and provide you with new experiences. As part of this mission, I use your information for the following purposes:
(a) To make my service available. I use functional information and information that is processed automatically to provide you with all requested services.
(b) To improve, test, and monitor the effectiveness of my App. I use the information that is processed automatically to better understand user behavior and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize my App.
(c) To provide you with interest-based (behavioral) advertising or other targeted content. I may use the information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). I provide personalized content and information to you, which can include online ads or other forms of marketing.
(d) To communicate with you. I use the information I have to communicate with you through newsletters, i.e., to send you marketing notifications, receive your feedback about my App experience, and let you know about my policies and terms. I also use your information to respond to you when you contact me.
(e) To prevent fraud and spam, to enforce the law. I really want my App to be free of spam and fraudulent content so that you feel safe and free. I may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect my trademarks, and enforce my Terms of Use.
If any new purposes for processing your personal data arise, I will let you know before I start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.
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**IV. SHARING OF YOUR INFORMATION**
I will share your information with third parties only in the ways that are described in this Privacy policy. I adhere to the U.S. Digital Advertising Alliance's Self-Regulatory Principles for the Mobile Environment.
Please note that while I partner solely with third parties that have given me assurance of the application of necessary technical and organizational measures to protect your personal data, I cannot guarantee the security of any information transmitted from the App directly to any such third party. I am not responsible for any accidental loss or unauthorized access to your personal data through the fault of third parties.
I will not rent or sell your personal data to any third parties, but I may share your information from tools like log files, device identifiers, and location data with third-party organizations that provide automatic data processing technologies for the App. I do not control or influence these third parties’ tracking technologies or how they may be used.
I may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.
I may engage the following third-party service providers in order to provide me with the necessary infrastructure for the delivery and improvement of my services:
**Entity name**
**Services performed**
**Entity location**
**Link to Privacy Policy**
Amplitude Inc.
Analytics service provider
U.S.A.
https://amplitude.com/privacy
AppsFlyer Inc.
Analytics service provider
U.S.A.
https://www.appsflyer.com/legal/services-privacy-policy/
Facebook (Meta Platforms, Inc.)
Analytics / ad management service provider
U.S.A.
https://www.facebook.com/privacy/explanation
Firebase (Google LLC)
Analytics and marketing service provider
U.S.A.
https://policies.google.com/privacy
https://firebase.google.com/support/privacy
Qonversion Inc.
In-App subscription implementation and revenue analytics service
U.S.A.
https://qonversion.io/page/privacy
Tableau Software LLC
Analytics service provider
U.S.A.
https://www.salesforce.com/company/privacy/
YouTube LLC (subsidiary of Google LLC)
API Services that enable the App to access certain YouTube content and features
U.S.A.
https://policies.google.com/privacy
https://policies.google.com/technologies/partner-sites?hl=en (how Google uses information from sites or apps that use its services)
In case you want to learn more about these services and their privacy options (including opt-out), please consult the corresponding websites and privacy policies. I am not responsible for any usage of your personal data by the abovementioned third parties in violation of my instructions.
My App may contain links to third-party websites/services, or you may access the App from a third-party site. I am not responsible for the privacy practices of these third-party sites or services linked to or from my App, including the information or content contained within them.
YouTube Data API Service as well as the IFrame Player API are used in order to add certain YouTube content and features to the App. Inter alia, certain audiovisual and other YouTube Content is available for viewing via the App. By using my App, you are automatically agreeing to be bound by the YouTube Terms of Service, available at: https://www.youtube.com/t/terms. As my App integrates some YouTube API Services, I may share your information with Google. For more details about the categories of information that may be collected and used by Google, as well as about the legal grounds for such collection and use, check Google Privacy Policy, available at: https://policies.google.com/privacy. For further clarifications on how Google can use information shared by your device when you use my App and how you can manage such information, please visit this link: https://policies.google.com/technologies/partner-sites?hl=en.
I may disclose your personal information if it is needed for objective reasons, due to the public interest, or in other unforeseen circumstances:
- As required by law;
- When I believe, in good faith, that disclosure is necessary to protect my rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- If I am involved in a merger, acquisition, or sale of all or a portion of my assets, you will be notified via email and/or a prominent notice in my App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
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**V. INTERNATIONAL DATA TRANSFERS**
I work in the cross-border area and provide my App to my Users around the world.
I and third-party organizations that provide automatic data processing technologies for the App or my third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that I may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.
This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.
I try to make sure that the recipient of any personal data provides proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that I may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.
For the purposes of data storage, I use the services of hosting organizations. I take your privacy seriously and, therefore, encrypt your personal data—if possible—before sending it to the hosting organizations for the purposes of its storage. Please note that I cooperate only with those hosting organizations that have passed my security and reliability check.
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**VI. HOW LONG I USE YOUR PERSONAL DATA**
I generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with my legal obligations. If you no longer want me to use your information that I physically access and store, you can request that I erase your personal information and close your account.
However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligations (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud, or other malicious acts.
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**VII. EXERCISING YOUR RIGHTS**
Applicable data protection laws give you certain rights regarding your personal information. You have the following options in relation to your personal information that was collected:
- **Data Access and Portability.** You can request copies of your personal information.
- **Change or Correct Data.** Where you cannot update data by yourself through your account, you have the right to ask to correct, change, update, or rectify your data.
- **Data Retention and Deletion.** The user data is generally retained for as long as your user profile is in existence or as it is needed to provide the relevant services. However, specific retention times can vary based on the context of the processing performed. You have the right to ask to delete all or some of the personal data that is held about you.
- **Restriction of Processing.** Under certain circumstances, you may have the right to limit the ways in which your personal information is used.
- **Exercising the right to know about data sharing.** You have the right to know whether your data is shared with third parties. Detailed information on this issue is contained in Section IV of this Privacy policy; however, if you have further questions in this regard, you can contact me at any time.
To exercise any of the rights described above, you can contact me through **welcome@absofttech.com**. Please bear in mind that I ensure the above-mentioned rights only with respect to the information that I physically access and store.
You also have the right to lodge a complaint with your local data protection or a supervisory authority if you reasonably believe that your rights under applicable data protection laws have been breached.
Please note that when you exercise your right to lodge a complaint with your local data protection or a supervisory authority, you may be required to provide additional information and support your complaint with sufficient objective evidence. By lodging a complaint, you agree to provide sufficient explanation as to what you believe impaired your rights. Additionally, in some cases, prior to lodging a complaint with your local data protection or a supervisory authority, you may be required to send your initial claim directly to me and ask for clarifications if necessary.
When your personal information is processed automatically, you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing of your data for these direct marketing purposes. In order to exercise your right, please contact the third-party services listed in Section IV of this Privacy policy to learn how you can object to the processing of your data. Most of them have clear instructions on their privacy pages, functional API, or other options.
If you are located in the European Union, you may address my representative when you have questions on privacy issues: **welcome@absofttech.com**.
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**VIII. HOW TO OPT OUT**
**Opt-out of marketing tracking**
You can manage your activity tracking permissions. Inter alia, if you don’t want third-party service providers to use personalized ads on the basis of your interests, please follow the instructions below:
- Go to **Settings > Privacy & Security** (or “Privacy” in earlier versions of iOS) > **Tracking**, then tap to turn off or turn on permission to track for a specific app. You can also control whether apps can ask for permission to track your activity. If you don’t want to be asked for your permission, or do not want apps to access your device’s Advertising Identifier, go to **Settings > Privacy & Security** (or “Privacy” in earlier versions of iOS) > **Tracking** and then disable the “Allow Apps to Request to Track” switch. If you turn off "Allow Apps to Request to Track", you won't get prompts from apps that want to track your activity. Each app that asks for permission to track while this setting is turned off will be treated as if you tapped “Ask App Not to Track”. Please find additional information here: https://support.apple.com/en-us/HT212025 or in the **Settings > Privacy & Security** (or “Privacy” in earlier versions of iOS) > **Tracking** section on your device. If you want to disable Apple’s ad targeting, go to **Settings > Privacy & Security** (or “Privacy” in earlier versions of iOS) > **Apple Advertising**, then set the “Personalized Ads” switch to the “off” position. Please find additional information here: https://support.apple.com/en-us/HT202074.
You can also visit https://youradchoices.com for the same purpose.
Please note that when you opt out of certain interest-based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.
**Opt-out of Location Data Processing**
If you don't want third-party service providers to use your precise location data or street-level location information about you, please follow the instructions below:
- **iOS 11 or later:** Turn Location Services off for the applicable Product via the menu **Settings > Privacy & Security** (or “Privacy” in earlier versions of iOS) > **Location Services**. Then select the applicable App and set the “Share My Location” status to “Never”. Please see additional information here: https://support.apple.com/en-us/HT203033.
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**IX. SECURITY**
The security of your personal information is highly important to me. I follow generally accepted industry standards to protect the personal information submitted to me, both during transmission and once I receive it.
I take reasonable and appropriate measures to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.
I implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. I seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.
Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. I do my best to protect your personal data; nevertheless, I cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, I will promptly notify you in compliance with applicable law.
If you have any questions about the security of my App, you can contact me through the email displayed below.
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**X. CHILDREN'S PRIVACY**
My App is not intended for children. Therefore, I do not knowingly or intentionally collect or solicit any personal information from children. For the purposes of this Section X, the terms “child” and/or “children” in the context of data processing activities may be interpreted on a case-by-case basis as prescribed by applicable data protection laws. No one who is considered a “child” under applicable data protection laws is allowed to directly provide any personal information to the App.
As a general rule, I consider a person under the age of 16 to be regarded as “a child” until I have legal grounds to conclude that a person under 16 should be treated as an adult as per provisions of local data protection rules or based on parental authorization provided to me directly.
Solely the holders of parental responsibility are liable for preventing their children from providing personal information via the App without relevant verifiable parental consent. If I learn that I have collected personal information from a child without verification of parental consent, I will erase that information as quickly as possible. If you reasonably believe that I might have any information from or about a child, or a child has directly provided me with personal information via the App without verifiable parental consent, please contact me.
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**XI. CHANGES TO THE PRIVACY POLICY**
This Privacy policy is updated regularly.
Whenever I change this Privacy policy, I will post those changes to this Privacy policy and other places that I consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.
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**XII. HOW TO CONTACT ME**
If you have any questions about this Privacy policy, please feel free to contact me via **welcome@absofttech.com**.
Copyright © 2025 Mykola Makarevych