Our Privacy Policy

Privacy Policy

Effective as of October 24th, 2024.

SND is a social network which enables users to share their content; other users to enjoy content and for some to do both. We refer to those users who share content as “Creators” and those users who pay to view Creators’ content as “Fans”. This Privacy Policy describes the privacy practices of SND, Inc. (“SND” “we”, “us” or “our”) and how we handle your personal data when you visit our site www.trysnd.com (the “Website”), any related sites, pages, services and goods or any other website operated by SND that links to this Privacy Policy (the “Services”). The purpose of this Privacy Policy is to provide you with a clear explanation of what personal data we collect, when, why and how we collect, use and share your personal data and it explains your statutory rights.

We strongly urge you to read this Privacy Policy and make sure you fully understand our practices in relation to personal data before you use our Services.

Personal data we collect

Information you provide to us
Personal data is data that can be used to contact or identify you, such as your name, email address, phone number, etc. Personal data you may provide to us through our Services, or otherwise, includes:

• Contact data, such as your first and last name, alias, email address, billing and mailing addresses, and phone number.

• Profile data, such as the username and password that you may set to establish an online account with us, photographs, biographical information, links to your profiles on social networks, and any other information that you add to or is associated with your account profile.

• Communications data, such as data that we exchange with you, including when you contact us with questions or feedback, through our Services, social media, or otherwise.

• Payment and transactional data, such as data relating to, or needed to complete, your purchases on or through our Services (including payment card information and billing information) or to provide you with the funds from a sale on the platform, digital wallet information, and your purchase history.

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• User-generated content, such as photos, images, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on our Services, as well as associated metadata.

• Government-issued identification numbers, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card or any other data required for ‘Know Your Customer’ checks.

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources.
We may combine personal data we receive from third party vendors and/or other commercially available sources with the personal data we collected. The third-party sources from which we may receive personal data are:

• Public sources, such as social media platforms and other publicly available sources.

• Data providers, such as information services and data licensors that provide demographic and other information.

• Third-party vendors, such as service providers providing talent management services, fraud warnings, KYC or enrichment service providers to enhance and personalize your user experience.

• Marketing partners, such as joint marketing partners and event co-sponsors.

If you choose to activate, access, or connect your account on or to a third-party platform or network, such as Facebook/Google/Twitter we may collect data from that platform or network, the data we collect may include your profile name, avatar, etc.

Automatic data collection.
We may automatically collect data about you, your computer or mobile device while you access, browse, view or otherwise interact with our Services, the data we collect may include:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data on our Website, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked on URLs that led you to our site.

Cookies and similar technologies.
We use cookies and similar technologies (such as web beacons, pixels, tags and scripts) to improve and personalize your experience, provide our Services, analyze website performance and for marketing purposes. To learn more about how we use cookies and your control over these cookies, please see our Cookie Policy.

Data about others.
Users of our Services may have the opportunity to refer friends or other contacts to us and share their contact data with us. Please do not refer someone to us, or share their contact data with us, unless you have their permission to do so.

How we use your personal data

We may use your personal data for the following purposes or as otherwise described at the time of collection:

Service delivery.
We may use your personal data to:

• develop, provide, operate and improve our Services and our business;

• establish, maintain and service your user profile for our Services;

• verify or maintain the quality or safety of the Services;

• conduct Know Your Customer checks and other screens permitted by law when you set up an account;

• facilitate invitations to friends who you want to invite to join our Services;

• enable security features of our Services, such as (for example) by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;

• communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;

• understand your needs and interests, and personalize your experience with our Services and our communications;

• enable communication with other Service users; and

• provide support for our Services, and contact you where requested or respond to your requests, questions and feedback.

Research and development:
We may use your personal data for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified or anonymous data from personal data we collect. We make personal data into anonymous data by removing data that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising.
We may collect and use your personal data for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications about our products, services or promotions that may be of interest to you. Our processing of your personal data for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted by applicable laws. You have the right to prevent direct marketing of any form at any time, this right can be exercised by following the opt-out link attached to each communication or by sending an email to help@trysnd.com.

• Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads on other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Advertising choices section below.

Compliance and protection.
We may use your personal data to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• maintain appropriate business records;

• enforce the terms and conditions that govern our Services; and

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Share Your Personal Data

1. No Sale or Rent for Marketing
   We do not sell or rent your personal data to third parties for their marketing purposes without your explicit consent.

2. Sharing with Third Parties
   We may share your personal data with third parties as follows:

   • Affiliates: We may share your data with our parent company, subsidiaries, and affiliates for purposes consistent with this Privacy Policy.

   • Service Providers: Third-party service providers help us operate our services and business (e.g., hosting, IT support, customer service, email delivery, marketing, website analytics).

   • Payment Processors and Fraud Detection: Data is shared with payment processors and fraud detection providers to facilitate payments, secure services, and protect against fraud and unauthorized transactions.

   • Advertising Partners: We may share your personal data with third-party advertising companies for interest-based advertising, but data obtained through the Passes Messaging short code program will not be shared for marketing purposes.

   • Creators: As a Creator, we may publicly identify you and share information related to your use of our services, including aggregated metrics about your earnings and audience.

   • Third-Party Platforms and Social Media: If you link our services with third-party platforms or social media, we may share personal data authorized by you. These third parties will use your data according to their own privacy policies.

   • Professional Advisors: We may share your data with legal, audit, banking, and insurance professionals where necessary.

   • Government Agencies and Regulators: We may disclose personal data to law enforcement or other authorities in response to legal processes, investigations of fraud, breaches, or violations of law, and to protect our rights or public safety.

   • Corporate Transactions: In cases of mergers, sales, or acquisitions, personal data may be transferred as part of business assets.

   • Other Users: Your personal data, such as profile information, email address, and user-generated content, may be visible to other users. As a Fan, your email and other data may be shared with Creators to whom you subscribe. Where your data is publicly visible, it may be collected, cached, copied, or stored by others, including through search engines. We are not responsible for how others use such data.

Children

Our Services are not intended for children, and we do not collect personal information from them. We define “children” as anyone under 18 years old. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete the information. If you believe we might have any information from or about a child, please contact us via the contact information noted below.

Notwithstanding the foregoing, if you are creating an account as a Creator and you are between the ages of 15 and 17, you may use the Services with SND prior approval and with a parent or guardian’s verified written consent.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Website. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.

How to contact us

To exercise any of your rights in connection with your personal data or to share any questions (or comments) concerning this policy, please contact us at help@trysnd.com.