Privacy Policy
This English translation is provided for convenience only. The Czech version is legally binding; in case of any discrepancy, the Czech version prevails.
Effective as of June 25, 2026 · Last updated October 19, 2026
This Privacy Policy describes how we process personal data in the Snaprime service (snaprime.com, app.snaprime.com) in accordance with Regulation (EU) 2016/679 (GDPR). The controller of personal data is snaprime s.r.o. (“we” or “us”), whose identification details are set out below. Contact: info@snaprime.com.
Controller
snaprime s.r.o.
Registered office: Plynární 1617/10, Holešovice, 170 00 Praha 7, Czech Republic
Company ID (IČO): 29815487
Registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, File 452847
Managing Director: Matěj Procházka
E-mail: info@snaprime.com
Are you a Snaprime customer? Your leads belong to you.
This Privacy Policy covers processing for which we are the controller: data about you as a customer and about visitors to our website. The leads (enquiries) that Snaprime collects for you belong to you. You are their controller, and we hold and process them on your behalf and on your instructions, i.e. as a processor. The rules are set out in the Data Processing Agreement (Annex No. 1 to the Terms of Service), which you enter into together with the Terms of Service.
1. What data we process
- Contact and identification data: name, e-mail, phone number, company name and industry. You provide them in a form (for example when requesting a video or a consultation) or when creating an account.
- Data from your use of the Service: profile content and materials for ads, campaign settings and data about your connected accounts (Meta, payments).
- Payment data: processed by the Stripe payment gateway. We do not store card numbers.
- Technical data: IP address, device type, data from cookies and measurement tools (Meta Pixel, Google Ads, PostHog) and attribution parameters (UTM, fbclid, gclid).
2. Why we process it and on what legal basis
- Provision of the Service (creating and managing ads, collecting leads): performance of a contract.
- Communication and support, handling your enquiry or consultation: performance of a contract or, where applicable, legitimate interest.
- Marketing and commercial communications (for example e-mails with videos): your consent. You can unsubscribe at any time.
- Measurement and improvement through analytics and marketing tools (in particular Meta Pixel, Google Ads and PostHog): your consent.
- Basic operational statistics, security logs and similar processing that does not require the use of non-technical cookies: legitimate interest in the secure, reliable and efficient operation, protection and further development of the Service.
- Development and improvement of the Service, including internal training, fine-tuning and evaluation of our own models and algorithms on Campaign Data to the extent set out in the Terms of Service: legitimate interest in developing and improving the Service, unless, in the specific case, the rights and freedoms of the data subjects concerned override that interest. We do not use the personal data of individual enquirers (leads) for this purpose.
- Compliance with legal obligations (accounting, taxes): legal obligation.
3. Who we share data with
Processors: acting on our instructions
To operate the Service, we use providers that process data on our behalf and on our instructions. These are, in particular:
- eLead.agency s.r.o.: operation of advertising accounts on Meta. Its Business Manager holds the system access credentials through which we launch and manage campaigns and receive leads from lead forms.
- Cloudflare: hosting and delivery of the website and the application.
- Neon: the database in which the data is stored.
- Scaleway: data storage in the EU.
- Google Workspace: Google Sheets to which we send leads for customers who enable this option.
- Klaviyo: e-mail communication and automation.
- OpenAI, Anthropic and Google: generating suggested ad copy and visuals. We provide them with information about the customer’s business (name and company name, industry, a summary of the website content, location and the campaign brief). Personal data of prospects from leads is not passed to the models, and these providers do not use data received via the API to train their models.
Meta and Google for measurement on our website
Meta Platforms Ireland Ltd. (Facebook, Instagram, Meta Pixel) is not our processor for measurement on our own website. To the extent set out in Meta’s Business Tools Terms, we and Meta act as joint controllers under Article 26 GDPR for the collection and transmission of data via the Meta Pixel. This does not apply to personal data from lead forms and other leads of our customers: for those, the relevant customer is the controller and Snaprime processes them on the customer’s behalf under the data processing agreement.
Similarly, Google Ireland Ltd. (Google Ads) processes data from ad conversion measurement as an independent controller under its data protection terms for advertising products. Google’s measurement code is loaded only after you consent to marketing cookies.
- What we are responsible for: informing you about the processing and obtaining your consent where required. We only activate the measurement tools on our website once consent has been given.
- What Meta is responsible for: the processing on its side and enabling you to exercise your rights against it. How Meta uses data is described in the Meta Privacy Policy.
- You can exercise your rights against either party: with us at info@snaprime.com, or directly with Meta.
Independent controllers
Stripe acts as an independent controller for payment processing. It fulfils its own obligations under payment services and anti-money laundering legislation.
A complete and continuously updated list of all providers (what we use them for, which data is concerned, where they process the data and which legal instrument safeguards the transfer) can be found on the List of Sub-processors page. That list is decisive for the scope of data transfers.
Some providers also process data outside the EU. Such transfers are safeguarded by standard contractual clauses or another appropriate instrument. The instrument we use for each provider is stated in the list of sub-processors.
4. How long we retain data
We retain data for the duration of the contractual relationship and thereafter for the period necessary to protect our legitimate interests and to comply with legal obligations (for example, accounting records for the period required by law). Data processed on the basis of consent is retained until consent is withdrawn. What happens to data after an account is closed is described on the Data Deletion page.
5. Your rights
You have the right of access to your data, the right to rectification or erasure, the right to restriction of processing, the right to data portability, the right to object and the right to withdraw your consent at any time. You can also submit a request for erasure of your data via the Data Deletion page. You also have the right to lodge a complaint with the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů).
6. Cookies and measurement tools
The website uses cookies and measurement tools (Meta Pixel, Google Ads, PostHog) for operation, analytics, conversion measurement and remarketing. We activate marketing and analytics cookies and similar technologies only after you allow them in the cookie banner. You can change your choice or withdraw your consent at any time, just as easily, in the cookie settings.
7. Advertising outputs and their promotional use
Rights to ads and other outputs created through Snaprime, including permission for any promotional use of them, are governed by the Terms of Service. This Privacy Policy governs only the processing of personal data that may take place in the course of such use.
Where a testimonial, case study or other marketing material contains personal data by which a specific natural person can be identified (for example a name or likeness), we will use it for this purpose only with that person’s prior consent, unless another appropriate legal basis applies in the specific case.
You can withdraw your consent to further promotional use of personal data at any time by writing to info@snaprime.com. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
8. Changes
We may update this Privacy Policy. The current version is always available on this page, and the date of the last change is shown at the top.
