SODA Privacy Policy


Last Modified: Oct 10, 2018


Welcome to SNOW, Inc. ("SNOW" "we," "us" or "our"). Our Privacy Policy explains how we and some of the companies we work with collect, use, share and protect information in relation to our mobile services, and any other services we provide (collectively, the "Services" or "SODA"). By using our Service you understand and agree that we are providing a platform for you to post text, graphics, photos, videos or other materials (collectively referred to as "Content"), to the Service and to share Content publicly. This means that other users may search for, see, use, or share any of your Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms of Use.


1. Information We collect

1) Information you directly provide us

Your username, password, an email address we can contact you at, a phone number. We do not require that you provide us with your user profile (e.g., Real name, picture).

Your activity and the messages you send and receive through our Services. For example, we collect information such as the time, date, sender, recipient of a message, the number of messages you exchange with your friends, which friends you exchange messages with the most, and your interactions with messages (such as when you open a message or capture a screenshot).

2) Information you automatically provide us when you use our services

Because SODA is about sharing moments with people, there is some information we collect when you access our Services, which we use to facilitate the broad range of communications offered through our Services, to provide you cool features and functionality, and to enable all the other purposes described in this privacy policy. We explain all this below:

- Usage Information.

We collect information about your activity and the messages you send and receive through our Services. For example, we collect information such as the time, date, sender, recipient of a message, the number of messages you exchange with your friends, which friends you exchange messages with the most, and your interactions with messages (such as when you open a message or capture a screenshot). We may collect that same basic information when you use message cash, along with the dollar amounts sent and received.

- Content Information.

Please check out the "Message Deletion" section in this privacy policy; it gives you more information about the message content we collect, how long we keep it, and how long third parties may have access to it.

- Device Information.

We collect information about your device, including the hardware model, operating system and version, unique device identifiers (including MAC address and IMEI), browser type and language, mobile device phone number, and mobile network information. We also collect certain device information that will help us diagnose problems in the (hopefully rare) event you experience any crash or other problem while using our Services. So, for example, if we detect a crash or other problematic event, we may collect the list of apps on your device and other information about your device's performance at the time of the event for troubleshooting purposes.

- Device Phonebook.

Because SODA is originated for communications with friends, we may-with your consent-collect information from your device's phonebook. We do this so that we can connect you to your friends quickly and intuitively, enhance the Services with additional functionality, and for any other purpose described in this privacy policy. You can always revoke your consent to our ongoing ability to collect information from your device's phonebook by changing the settings on your device if your device offers that option.

- Camera and Photos.

Many of our services require us to collect images and other information from your device's camera and photos. We'll access your camera and photos only after you give us your consent..

- Location Information.

When you use our services we may collect information about your location. With your consent, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.

3) Information Collected by Cookies and Other Tracking Technologies.

Like most online services, we use cookies, web beacons, and other technologies. Cookies are small data files stored on your hard drive or in device memory that store information about your use of the Services, which can, among other things, help us see which areas and features of the Services are popular and let us count visits. Web beacons are small pieces of software on a webpage or email that help us see how you interact with that webpage or email. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our Services. To learn more about how third parties use such technologies on our Services, be sure to read the "Analytics and Advertising Services Provided by Others" section of our privacy policy.

4) Analytics information. 

We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual User.


2. Information We Collect From Other Sources

If another user allows us to collect information from his or her device phonebook and you're one of that user's contacts we may combine the information we collect from that user's phonebook with other information we have collected about you. We may also obtain information from other sources and combine that with the information we collect through SODA.


3. How We Store Your Information

1) Your account information (e.g., email address, password, and phone number) will be encrypted as soon as you register for the Service, and we store and process such encrypted information in South Korea in which we maintain facilities. We will use commercially reasonable safeguards and take reasonable steps to keep the information encrypted at all times, so that the information will not be decrypted and accessible.

2) You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to the service at all times as we are not able to decrypt and access your encrypted account information.


4. How We Use Information

We provide you with an amazing set of Services that we improve with the information we collect. But we do a lot more as well, such as:

Provide and deliver the products, services, and functionality that you request, process transactions, and send you related information;

Communicate with you. That means just what it says; we may send you marketing communications on behalf of us or other companies; respond to your comments and questions; provide customer service; and send you technical notices, security alerts, and other informational messages;

Monitor and analyze trends and usage;

Develop, improve, and refine products, services, and functionality;

Personalize the Services by providing advertisements, content, or features that match user profiles or interests. For instance, when you set up an account we may pre-populate certain account information based on the information we collect about you from other users;

Verify your identity and prevent fraud or other unauthorized or illegal activity; and

Carry out any other purpose for which the information was collected.


5. How We Share Information

Here's the type of information we may share about you with others and how we do so:

When you send a message, your recipients will see your name and, of course, whatever your message says or shows (whether that's a photo, video, text, or transaction). When you view content that another SODA user has sent you, we will let the sender know that you saw it, and if we detect that you captured a screenshot of the message, we will try to let the sender know that. But you're always able to tell us whether you'd like to receive messages only from users you have added to your friends list or whether you'd prefer to receive messages from all SODA users. We let you do that as well through various settings.

When you let us access your device phonebook, we may share information about you with other users who have your phone number in their device phonebook. For instance, when you use Find Friends, we may share your username and name with other users who use Find Friends and have your phone number in their device phonebook. In these cases, we will not display your phone number to these users, but we will share the fact that your username and name are associated with your phone number.

When other users view your profile, they will be able to view profile information, including your username and name.

We may share information about you with service providers who perform services on our behalf. 

We may share your contact information with companies such as Infobip, Infobank, and Nexmo for sending SMS in which for certification.

With respect to jointly offered Services or functionality or services offered separately by other companies through our Services, we may share information about you with business partners to provide the Services and functionality you request and to communicate with you about those Services;

We may share information about you in response to legal process or a request for information if we believe disclosure is consistent with, or required by, any applicable law, rule, or regulation; to investigate or remedy potential violations of our user agreements or policies, or to protect the rights, property, and safety of us, our users, or others; or in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We may share information about you with your consent or at your direction, or as otherwise provided in this privacy policy.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. Here's just one example of how this could work: Because it's not always clear whether a new friend request comes from someone you actually know, we may share whether you and the requestor have SODA friends in common without disclosing the usernames of those common friends.

The Services may also contain third-party links or be a co-branded or third-party-branded Service that's being provided jointly with or by another company. By going to those links or by using a co-branded or third-party-branded Service, you may be providing personal information directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. As always, we encourage you to review the privacy policies of every third-party website or service that you visit or use, including those third parties you interact with through our Services.


6. Message Deletion

Delete is our default. That means that most messages sent through our Services will be automatically deleted once they have been viewed or have expired. But -and this is important- you should understand that users who see your messages can always save them, either by taking a screenshot or by using some other image-capture technology (whether that be software or even something as old-fashioned as a camera to take a photo of your device's screen). If we're able to detect that a recipient took a screenshot of a message you sent, we'll try to notify you. But the same common sense that applies to the Internet at large applies to SODA as well: Don't send messages that you wouldn't want someone to save or share.

In most cases, once we detect that all recipients have viewed a message, we automatically delete it from our servers. And again in most cases, the Services are programmed to delete the message from the recipients' device as well. There is, however, an exception to this general rule:

Infinity timer: Senders can choose an infinity timer option to prevent deleting their messages from recipient's device.

A few final words on deletion: We can't guarantee that messages will be deleted within a specific timeframe. And even after we've deleted message data from our servers, that same data may remain in backup for a limited period of time. We also sometimes receive requests from law enforcement requiring us by law to suspend our ordinary server-deletion practices for specific information. Finally, of course, as with any digital information, there may be ways to access messages while still in temporary storage on recipients' devices or, forensically, even after they are deleted.


7. Children's Privacy

SODA respect the privacy of children under the terms of COPPA. We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us via support@snow.me.


8. Your Rights

We always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.

8. 1. Right to Access your information

You may be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format.

8. 2. Right to rectification of inaccuracy or incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you.

8. 3. Right to Erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide our services to you, you can request that we erase your personal information and close your account.

8. 4. Right to restriction of processing

You have the right to obtain from the controller restriction of processing one of the following appliers:

(i) you contest the accuracy of your personal information;

(ii) the processing is unlawful and you oppose the erasure of your personal information;

(iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; 

(iv) you have objected to the processing pursuant to Section 6.6 pending the verification whether the legitimate grounds of our override your own.

8. 5. Right to data portability

You may be entitled to request us to transmit this information to another service provider (where technically feasible).

8. 6. Right to object

You have the right to object, on grounds relating your particular situation, at any time to processing of personal data which is based on point (e) or (f) of GDPR Article 6(1), including based on those provisions. 

8. 7. Contact Details

You may exercise any of the rights described in this section by sending an email to support@snow.me. Please note that we may provide you with a form that you can fill out, and ask you to verify your identity before taking further action.


9. Change to Our Privacy Policy

SODA may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of SODA or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.


10. Legal matters

If any court or other competent authority finds any of the terms of this Privacy Policy to be invalid or unenforceable, the other terms of this Privacy Policy will not be affected. This Privacy Policy is governed by and interpreted in accordance with the laws of South Korea. Any dispute arising in connection with this Privacy Policy will be subject to the exclusive jurisdiction of the courts of South Korea unless you choose the courts of your home country.


11. Contact Information

Contact : support@snow.me

SNOW, Inc.
Attn: Copyright Agent
575 High Street,
Suite 110 Palo Alto, CA 94301