A.  The data we collect

Snag-Zilla collects personal data:

 
• • • provided by users to Snag-Zilla, such as during account creation
    • created during use of our services, such as location, app usage, and device data
    • from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities
   

The following personal data is collected by or on behalf of Snag-Zilla:

 
1. 1. Data provided by users. This includes:

 

• • • User profile: We collect data when users create or update their Snag-Zilla This may include their name, email, phone number, login name, address, profile picture, payment or banking information (including related payment verification information), driver’s license, and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of drivers and delivery persons, emergency contact information, user settings, and evidence of health or fitness to provide services using Snag-Zilla apps.
    • We may use the photos submitted by users to verify their identities, such as through facial verification technologies. For more information, please see the section titled “How we use personal data.”
    • Background check and identity verification: In order to verify drivers’ and delivery persons’ eligibility to provide services through the Snag-Zilla apps, we may collect information such as driver history or criminal record (where permitted by law), license status, known aliases and prior addresses, and right to This information may be collected by an authorized vendor on Snag-Zilla’s behalf.
    • User content: We collect the data submitted by users when they contact Snag-Zilla customer support (including via videoconferencing tools), provide ratings or compliments for other users, merchants, or otherwise contact Snag-Zilla. This may include feedback, photographs or other recordings collected by users, including audio or video recordings (such as from dashcams) submitted by users in connection with customer support. This also includes metadata relating to the method you use to communicate with Snag-Zilla.
   

2. 2. 2. Data created during the use of our services. This includes:
    

• Location data (driver and delivery person): We collect drivers’ and delivery persons’ precise or approximate location data, including to enable rides and deliveries, to enable ride/delivery tracking and safety features, to prevent and detect fraud, and to satisfy legal requirements. Snag-Zilla collects this data when the Snag-Zilla app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.

• Location data (users and delivery recipients). We collect users’ and delivery recipients’ precise or approximate location data to enable and enhance the use of our apps, including to improve pick-ups, facilitate deliveries, enable safety features, and prevent and detect fraud. Please see our How Snag-Zilla Uses Location Information page for detailed information on how we use this data.
• We collect such data from users’ mobile devices if they enable us to do so. (See “Choice and transparency” below for information on how users and delivery recipients can enable location data collection). Snag-Zilla collects such data from the time a ride or delivery is requested until it is finished (and may indicate such collection via an icon or notification on your mobile device depending on your device’s operating system), and any time the app is running in the foreground (app open and on-screen) of their mobile device.
• Users and delivery recipients may use the Snag-Zilla apps without enabling Snag-Zilla to collect precise location data from their mobile devices. However, this may affect features in the Snag-Zilla apps. For example, a user who has not enabled location data collection will have to manually enter their pick-up address. In addition, the location data collected from a driver and delivery person during a trip will be linked to the user’s account, even if the user has not enabled location data to be collected from their device, including for purposes of receipt generation, customer support, fraud detection, insurance, and litigation.

• Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, payment transaction information (such as a restaurant’s or merchant’s name and location and amount of transaction), delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing. (Please see “How We Use Data” below for more information on how we market our services to users).
• In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.

• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.

• Communications data: We enable users to communicate with each other and Snag-Zilla through Snag-Zilla’s mobile apps and websites. For example, we enable users and delivery persons, and delivery recipients, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, Snag-Zilla receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Snag-Zilla may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics.

• • • Safety recordings: In certain jurisdictions, and where permitted by law, users can record the audio and/or video of their trips through an in-app feature or using a dashcam. In-app recordings are encrypted and stored on user’s devices, and are only shared with Snag-Zilla if submitted to customer support by the users in connection with safety incidents.
   

3. 3. 3. Data from other sources. These include:
    

• Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user.
• Snag-Zilla account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their This includes owners of Snag-Zilla for Business accounts.

• users or others providing information in connection with claims or disputes.
• Snag-Zilla business partners through which users create or access their Snag-Zilla account, such as payment providers, social media services, or apps or websites that use Snag-Zilla’s APIs or whose APIs Snag-Zilla uses.

• • Snag-Zilla business partners in connection with debit or credit cards issued by a financial institution in partnership with Snag-Zilla to the extent disclosed in the terms and conditions for the card.
  • vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements
  • insurance, vehicle, or financial services providers for drivers and delivery persons
  • partner transportation companies (for drivers and delivery persons who use our services through an account associated with such a company)
  • publicly available sources
  • marketing service providers or data resellers whose data Snag-Zilla uses for marketing or research
  • law enforcement officials, public health officials, and other government authorities

Snag-Zilla may combine the data collected from these sources with other data in its possession.

B.  How we use personal data

Snag-Zilla uses personal data to enable reliable and convenient transportation, delivery, and other products and services. We also use such data:

• • to enhance the safety and security of our users and services
  • for customer support
  • for research and development
  • to enable communications between users
  • to send marketing and non-marketing communications to users
  • in connection with legal proceedings
   

Snag-Zilla does not sell or share user personal data with third parties for their direct marketing, except with users’ consent. We use personal data we collect:

1. 1. To provide our Snag-Zilla uses data to provide, personalize, maintain, and improve our services.

  This includes using data to:

• • create/update accounts
  • enable delivery services (such as using location data to facilitate a delivery or pick up), features that involve data sharing (such as fare splitting, ETA sharing, and ratings and compliments)
  • process payments
  • track and share the progress of rides or deliveries
  • personalize users’ accounts. We may, for example, present a Snag-Zilla user with personalized recommendations based on their prior orders. Please see the section of this notice titled “Choice and transparency” to learn how to object to this use of personal data.
  • facilitate insurance, vehicle, invoicing, or financing solutions
  • perform necessary operations to maintain our services, including troubleshooting software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

Snag-Zilla performs the above activities, including the collection and use of location data for purposes of these activities, on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users.

2. 2. Safety and We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

• verifying users’ identity and eligibility to provide transportation or deliveries, including thorough reviews of background checks, where permitted by law, to help prevent the use of our services by unsafe delivery persons and/or users.
• using data from delivery persons’ devices to detect unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery persons’ devices to verify the type of vehicles they used to provide deliveries.

• using the device, location, user profile, usage, and other data to prevent, detect, and combat This includes identifying fraudulent accounts or uses of our services, preventing the use of our services by unauthorized drivers and delivery persons, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts.
• using user ratings, reported incidents, and other feedback to encourage compliance with our Community Guidelines and as grounds for deactivating users with low ratings or who otherwise violated such guidelines in certain countries.
• sharing information regarding serious driver and delivery person safety incidents or compliance with local regulations with third parties, including other companies who enable users to request or provide rides or delivery services, or intermediaries who collect and report such information for multiple companies, to prevent drivers or delivery persons who may pose a safety risk to the platform or its users from using Snag-Zilla’s or those other companies’ services. We may also share with third parties, including those affected by such incidents, whether the incidents result in account deactivation.

• • using ratings, usage, and other data to prevent matching of users and delivery persons for whom there is a higher risk of conflict (for instance, because one user previously gave the other a one-star rating).

Snag-Zilla performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, and/or for purposes of the legitimate safety and security interests of Snag-Zilla or other parties, including users and members of the general public.

3. 3. Customer support. Snag-Zilla uses the information we collect (which may include call recordings) to provide customer support, including investigating and addressing user concerns and monitoring and improving our customer support responses and processes. Snag-Zilla performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users.
   4. Research and development. We may use personal data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy to use, enhance the safety and security of our services, and develop new services and features. Snag-Zilla performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users in improving our existing services and features, or for purposes of Snag-Zilla’s legitimate interests in developing new services and features.
   5. Enabling communications between users. For example, a delivery person may message or call a user to confirm a pickup location, a user may contact a delivery person to retrieve a lost item, or a delivery person may call a delivery recipient with information about their order. Snag-Zilla performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users.
   6. Marketing. Snag-Zilla may use personal data to market our services to our users. This includes sending users communications about Snag-Zilla services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in-app communications and ads, and ads on third-party platforms.We may also inform users about products and services offered by Snag-Zilla partners. For example, we may provide recommendations, promotions, or ads for Snag-Zilla partners based on users’ past delivery orders. Although we inform users about products and services offered by Snag-Zilla partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.We may use the data we collect, including in combination with advertising partners’ data, to personalize and improve the marketing communications (including ads) that we send on and off Snag-Zilla’s apps and websites, including based on user location, use of Snag-Zilla’s services, and user preferences and settings. For example, we share user data (such as hashed email address, usage information, and device or user identifiers) with Facebook and TikTok to personalize and improve our ads for Snag-Zilla’s services. For information about how to opt-out of certain marketing communications (including ads) from Snag-Zilla and its advertising partners, please see the section titled “Marketing choices.”We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, Snag-Zilla has notified some users by email of ballot measures or pending legislation relating to Snag-Zilla’s services in those users’ areas. Snag-Zilla performs the above activities on the grounds that they are necessary for purposes of Snag-Zilla’s legitimate interests in informing users about Snag-Zilla services and features or those offered by Snag-Zilla partners, or on the basis of user consent. See the sections titled “Choice and transparency” and “Marketing choices” for information on your choices regarding Snag-Zilla’s use of your data for marketing.
   7. Non-marketing communications. Snag-Zilla may use personal data to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Snag-Zilla or its partners. Snag-Zilla performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, or for purposes of Snag-Zilla’s and its users legitimate interests in informing users about events that may have an impact on how they can use Snag-Zilla services.
   8. Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to the use of Snag-Zilla’s services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement. Snag-Zilla performs the above activities on the grounds that they are necessary for purposes of Snag-Zilla’s legitimate interests in investigating and responding to claims and disputes relating to the use of Snag-Zilla’s services and features, and/or necessary for compliance with applicable legal requirements.
   9. Automated decision-making

We use personal data to make automated decisions relating to the use of our services. This includes:

• • enabling dynamic pricing, in which the price of a delivery fee for Snag-Zilla is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic at a given moment.
  • matching available delivery persons to users requesting services. Users can be matched based on availability, proximity, and other factors such as the likelihood to accept an offer based on their past behavior or preferences.
  • determining user ratings, and deactivating users with low ratings. In the European Union or where otherwise required by law, such deactivation occurs only after human review and/or the possibility to appeal.
  • flagging users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm Snag-Zilla, its users, and others. In some cases, such as when a user is determined to be abusing Snag-Zilla’s referral program or has submitted fraudulent documents, such behavior may result in automatic deactivation, or in the European Union or where otherwise required by law.
  • using delivery persons location information, and communications between users and delivery persons, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a delivery person is delaying a user’s delivery and/or pickup in order to induce a cancellation, we will not charge the user a cancellation fee and will adjust the amounts paid to the driver to omit such a fee. To object to such an adjustment, please contact Snag-Zilla customer support.
  • Using driver data (such as location, rating, and gender) and delivery person data (such as rating, origin, and destination) to help avoid pairings of users that may result in an increased risk of conflict.

To object to a deactivation resulting from these processes, please contact Snag-Zilla Customer Support.Snag-Zilla performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, or on the grounds that they are necessary for purposes of the legitimate interests of Snag-Zilla, its users, and others.

C. Cookies and third-party technologies

Snag-Zilla and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and Snag-Zilla’s Cookie Policy. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Snag-Zilla uses cookies and similar technologies for purposes such as:

 
• • authenticating users
  • remembering user preferences and settings
  • determining the popularity of content
  • delivering and measuring the effectiveness of advertising campaigns
  • analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services
   

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services. Please see our Cookie Policy for more information regarding the use of cookies and other technologies described in this section.

D. Data sharing and disclosure

Some of Snag-Zilla’s services and features require that we share personal data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes. Snag-Zilla may share personal data:

1. 1. With other users

This includes sharing:

• • users’ first name and last name, rating, and pick up and/or drop off locations with drivers and delivery persons
  • delivery recipients’ first name, delivery address, and order information with their delivery person and/or merchant. We may also share ratings and feedback, or other information to the extent required by law, with the delivery person.
  • for delivery persons, we may share data with the users, delivery recipient(s), or merchants, including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a delivery person; contact information (if permitted by applicable laws); and driver or delivery person profile, including compliments and other feedback submitted by past users. We also provide users and delivery recipients with receipts containing information such as a breakdown of amounts charged, delivery person’s first name, photo, and route map. We also include other information on those receipts if required by law.
  • for those who participate in Snag-Zilla’s referral program, we share certain personal data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.

2. At the user’s request This includes sharing data with:

• • Snag-Zilla business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Snag-Zilla may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or merchants or other Snag-Zilla business partners and their users in connection with promotions, contests, or specialized services.

3. With the general public Questions or comments from users submitted through public forums such as Snag-Zilla blogs and Snag-Zilla social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user. 4. With the Snag-Zilla account owner If a user requests delivery services using an account owned by another party, we may share their order or trip information, including location data, with the owner of that account. This occurs, for example, when:

• a user or delivery person uses their employer’s Snag-Zilla for Business profile
• a delivery person uses an account owned by or associated with a Snag-Zilla partner transportation company
• a user requests delivery services arranged by a friend or under a Family Profile
• a delivery person acts as a substitute (UK only)

5. With Snag-Zilla subsidiaries and affiliates We share personal data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Snag-Zilla processes and stores such data in the United States on behalf of its international subsidiaries and affiliates. 6. With Snag-Zilla service providers and business partners, Snag-Zilla provides personal data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

• payment processors and facilitators
• background check and identity verification providers
• cloud storage providers
• Google, in connection with the use of Google Maps in Snag-Zilla’s apps (see Google’s privacy policy for information on their collection and use of data)
• social media companies, including Facebook, TikTok, YouTube, Gettr in connection with Snag-Zilla’s use of their tools in Snag-Zilla’s apps and websites (see Facebook’s, TikTok’s, YouTube’s, Getter’s privacy policies for information on their collection and use of data)
• Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness
• research partners, including those performing surveys or research projects in partnership with Snag-Zilla or on Snag-Zilla’s behalf
• vendors that assist Snag-Zilla to enhance the safety and security of its apps
• consultants, lawyers, accountants, and other professional service providers
• insurance and financing partners
• airports
• merchants from whom delivery recipients place orders, as well as partners and/or their point of sale providers, including for order fulfillment, delivery, communications and marketing purposes
• third-party vehicle suppliers, including fleet and rental partners

7. For legal reasons or in the event of a dispute Snag-Zilla may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Snag-Zilla’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to the use of another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card. This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company. 8. With consent Snag-Zilla may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion

Snag-Zilla retains user data for as long as necessary for the purposes described above. Users may request deletion of their accounts at any time. Snag-Zilla may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy. Snag-Zilla retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data. Users may request deletion of their account at any time through the Account > Manager Your Privacy menus in the Snag-Zilla app. Following an account deletion request, Snag-Zilla deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and delivery persons, this generally means that we retain their account and data for a minimum of 7 years after a deletion request. For users and delivery recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.