SNAP21 PRIVACY POLICY

Team VMS, Inc. d/b/a "Snap21" and its affiliates and subsidiaries (collectively "SNAP21") is committed to the protection of its customers' privacy and the security of any personal information provided to SNAP21.

This Website and our associated Snap21 software application (collectively "Application") is owned and operated by SNAP21 (referred to herein as "we," "us," or "our"). The purpose of our privacy policy ("Privacy Policy") is to inform you about the types of personally identifiable information we gather about you when you access or use our Application, how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of, and your ability to correct the information. The phrases "personally identifiable information" or "personal information" mean any information by which you can be identified, such as your name, address, telephone number, picture, etc. Personal information may also include other information about you, such as gender, date of birth, or other demographic information, or about your use of the Application, such as IP address or cookies, if that other information is linked to your personal information. Please read our complete Privacy Policy. By using any part of the Application, you agree with the terms of this Privacy Policy, which is part of, and governed by SNAP21'S End User License Agreement. Whenever you submit information via the Application, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy. If you do not agree to the terms of our Privacy Policy or the Terms of Use, please do not use the Application.

HOW WE COLLECT INFORMATION

We collect personal information that you provide to us. Some functions of the Application require that you provide personal information to contact us, to obtain product information from SNAP21, or to use functions of the Application. This information may include, but is not limited to: user name, password, first name, last name, company name, title, phone number, fax number, and email address.

We may also collect personal information to deliver products and services, administer individual accounts, provide customer support, meet government regulatory requirements, provide Application security and internally analyze the collected data. SNAP21 will not use your personal information in a way that is incompatible with these stated purposes, unless we obtain your prior consent.

As you navigate through the Application, certain information can be passively collected using various technologies, such as navigational data collection. We, or third parties authorized by us, may transparently collect information that is not personally-identifiable, such as what browser or device is being used (e.g., Internet Explorer), the operating system of the device you use to access the Application or the domain name from which you entered a site (e.g., google.com). This Application may use Internet Protocol (IP) addresses. An IP address is a number automatically assigned to your computer by your internet service provider. We, or third parties authorized by us, may collect IP addresses for the purposes of system administration and to audit the use of parts of the Application. Each time you use the Application and each time you request one of our pages, our server logs your IP address.

This Application may use "cookies." A "cookie" is a small file stored by your Web browser to help a particular system recognize you and the pages you visit in a website. Cookies allow this Application to recognize you more quickly. We use cookies to help us measure the number of visits, average time spent, page views, and other statistics relating to parts of the Application. The information we gather through the use of cookies is not sold to vendors, advertisers, direct mail concerns, email list services, etc. If you disable cookies, certain functions of the Application may not work properly or be available to you.

We may use third party analytical applications to analyze our Application traffic and collect non-personally identifiable information about the use of our Application by individual users and users in the aggregate. We do not change our information-collection practices or use of cookies based on the do not track settings in your browser.

THIRD PARTY WEBSITES

Our Application may contain links to other websites. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors or other sites to which we provide links from our Application. SNAP21 does not endorse, approve or certify these other websites, and we do not guarantee the accuracy, completeness, efficacy, or timeliness of the information contained on these sites. This Privacy Policy applies to information collected by our Application, and you should check the applicable privacy policy of the website sponsor when linking to other websites.

SECURITY AND YOUR ACCOUNT

SNAP21 will take reasonable steps to protect your personally identifiable information that you transmit to SNAP21 and to the Application and to protect such information from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, no Internet transmission is ever fully secure, and SNAP21 cannot guarantee that information transmitted via the Application will remain confidential at all times. When we collect other information from our users, it is stored in an area to which the general public does not have access. We maintain physical, electronic and procedural safeguards to ensure that personal information is stored and treated responsibly.

Please bear in mind that anyone you provide with your log-in information will also have access to your account and personally identifiable information. If you use the Application you are responsible for maintaining the confidentiality of your account and password and for restricting access to your device.

HOW WE USE AND SHARE INFORMATION

Except for our dissemination of your photograph as further described below, which may constitute personally identifiable information about you if you can be identified from it, SNAP21 does not sell, rent, loan, share, or otherwise disclose any personally identifiable information, including your full name, address or email address to any third parties except for the licensees of our Application when you create an account or otherwise use features of the Application that communicate with our licensees. While you may use our Application without providing any personally identifiable information, you will not be able to receive informational emails from SNAP21 if you do not provide that information. You understand that the purpose of the Application is to collect your customer feedback and review of a transaction involving the purchase of goods or services such as a vehicle. Therefore you acknowledge that any information you provide in connection with the use of the Application for that purpose, including your name and photograph, may be displayed to others on the Application or other websites OR PROMOTIONAL MATERIALS INCLUDING WEBSITES OWNED/OPERATED BY LICENSEES OF OUR SOFTWARE AND THOSE OWNED/OPERATED BY THE LICENSEES OF OUR CONTENT. fOR EXAMPLE, IN THE CASE OF A VEHICLE TRANSACTION, your PHOTOGRAPH AND THE CONTENT YOU SUBMIT TO US MAY BE DISPLAYED ON a vehicle dealer's AND/OR THE VEHICLE MANUFACTURER’S website if you authorize such use of your information.

SNAP21 may provide certain aggregate information we collect from users of the Application (e.g., statistics, sales, traffic patterns and services) to third parties who can assist SNAP21 in analyzing and understanding the information and help us to better provide online products and services. Should SNAP21 share this aggregate information with third parties, it will not include any personally identifiable information except to the extent you have consented to the dissemination of your personally identifiable information (such as your photo) to the third parties we share it with.

SNAP21 or its Application licensees are the sole owners of all information collected by the Application. In addition, as we develop our business we may sell our business or buy another business. In such transactions, customer information is generally one of the transferred business assets. In the event that SNAP21 or its Application licensee's or substantially all of their assets are acquired, your personal information may be one of the transferred assets.

SNAP21 will disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or comply with a legal process served on SNAP21 on the site; (b) protect and defend the rights or property of SNAP21, or (c) act in urgent circumstances to protect the personal safety of users of the SNAP21 Application or the public.

DATA RETENTION

We keep your personal information for as long as needed to fulfill the particular purpose for which it is collected. We may also retain your records if legally required or to fulfill a legitimate interest.

EDITING, UPDATING, CORRECTING AND DELETING USER INFORMATION

You have the right to access personal information about you that we have collected through the Application by sending a request for access to info@snap21.com. You can also request that we correct any such information by sending an email to the same address. To verify that the request is authentic, we may require that such request be sent from the email address associated with your personal information. While we will comply reasonably and promptly with your request, we may need to retain some of your information for our own recordkeeping or to fulfill a legal obligation. If you delete, or ask us to delete, certain information, you may not be able to continue to access certain portions of the Application without entering additional information.

CHILDREN (UNDER THE AGE OF 13)

SNAP21 takes children's privacy seriously. We do not seek to collect personal information about children through our Application. If we become aware that a person submitting information to us through any part of our Application is a child, we delete the information as soon as we discover it and do not use it for any purpose, nor do we disclose it to third parties. Since we do not seek to collect any personal information about children, and we delete information collected inadvertently as soon as we discover that a child has submitted it, we typically retain no information about children that could be reviewed or deleted. If a parent requests review or deletion of information about their child before we have discovered and deleted the information, we will of course honor that request.

CHANGES TO PRIVACY POLICY

SNAP21 reserves the right to change this Privacy Policy at any time by posting a new version thereof on the Application. Please check this page periodically for changes. When changes are made we will update the effective date of this Policy

Effective Date: Aug 3, 2018