Last Updated: [DATE]

Data Protection Policy

1. Our Commitment to Data Protection

SnipAPI is committed to protecting the personal data of our users. This policy outlines our comprehensive approach to data protection, security measures, and compliance with international data protection laws.

2. Data Protection Principles

We adhere to the following core principles:

2.1 Lawfulness, Fairness, and Transparency

  • We process data only when we have a legal basis
  • We are transparent about our data collection and use
  • We provide clear information about our data practices

2.2 Purpose Limitation

  • Data is collected for specific, explicit, and legitimate purposes
  • We do not use data for purposes incompatible with the original purpose
  • New purposes require additional consent or legal basis

2.3 Data Minimization

  • We collect only the data necessary for our stated purposes
  • Regular reviews ensure we don't retain unnecessary information
  • Automated systems help minimize data collection

2.4 Accuracy

  • We maintain accurate and up-to-date personal data
  • Users can update their information at any time
  • Inaccurate data is corrected or deleted promptly

2.5 Storage Limitation

  • Data is retained only as long as necessary
  • Clear retention periods are established for different data types
  • Automated deletion processes ensure compliance

2.6 Integrity and Confidentiality

  • Robust security measures protect against unauthorized access
  • Data is encrypted both in transit and at rest
  • Regular security audits and updates maintain protection levels

3. Types of Data We Process

3.1 Personal Data

  • Identity Data: Username, email address
  • Authentication Data: Password hashes, two-factor authentication codes
  • Account Data: Preferences, settings, subscription status

3.2 Usage Data

  • Service Data: Screenshots, API requests, usage statistics
  • Technical Data: IP addresses, browser information, device data
  • Communication Data: Support requests, email correspondence

3.3 Special Categories

  • We do not intentionally collect sensitive personal data
  • If such data is inadvertently collected, it is deleted immediately
  • Users are advised not to include sensitive data in screenshots

4. Security Measures

4.1 Technical Safeguards

  • Encryption: All data encrypted using industry-standard algorithms
  • Access Controls: Multi-factor authentication and role-based access
  • Network Security: Secure connections and firewall protection
  • Regular Updates: Security patches and system updates

4.2 Organizational Measures

  • Staff Training: Regular data protection training for all personnel
  • Access Policies: Strict need-to-know access policies
  • Incident Response: Comprehensive data breach response procedures
  • Regular Audits: Internal and external security assessments

4.3 Storage Security

  • Cloudflare R2: Enterprise-grade secure storage with encryption
  • Backup Systems: Encrypted backups with geographic redundancy
  • Access Logging: All data access is logged and monitored
  • Data Segregation: User data is logically separated and isolated

5. Data Retention

5.1 Retention Periods

  • Account Data: Retained while account is active + 30 days after deletion
  • Screenshots: Retained according to user preferences or account limits
  • Security Logs: 90 days for incident investigation
  • Communication Records: 3 years for support and legal compliance

5.2 Automated Deletion

  • Scheduled deletion processes for expired data
  • User-initiated deletion available through account settings
  • Secure deletion methods ensure data cannot be recovered

6. Data Subject Rights Management

6.1 Rights Implementation

  • Automated Systems: Self-service options for common requests
  • Manual Processing: Human review for complex requests
  • Verification Procedures: Identity verification for sensitive requests
  • Response Tracking: All requests logged and tracked to completion

6.2 Request Processing

  • Standard Timeline: 30 days for most requests
  • Complex Requests: Up to 90 days with user notification
  • Free of Charge: No fees for legitimate requests
  • Regular Reporting: Statistics on rights requests and processing times

7. Third-Party Data Processing

7.1 Processor Selection

  • Due diligence on all third-party processors
  • GDPR compliance requirements in all contracts
  • Regular audits of processor compliance
  • Data Processing Agreements (DPAs) with all processors

7.2 Current Processors

  • Cloudflare R2: File storage and content delivery
  • Email Services: Transactional email delivery
  • Security Providers: Threat detection and prevention
  • Analytics Tools: Service performance monitoring (anonymized data only)

8. International Data Transfers

8.1 Transfer Mechanisms

  • Adequacy Decisions: Transfers to countries with adequate protection
  • Standard Contractual Clauses: For transfers without adequacy decisions
  • Certification Schemes: Processors with recognized certifications
  • Regular Reviews: Ongoing assessment of transfer mechanisms

8.2 Safeguards

  • Encryption of all transferred data
  • Access controls and monitoring
  • Regular compliance audits
  • User notification of transfer destinations

9. Incident Management

9.1 Data Breach Response

  • Detection: 24/7 monitoring for security incidents
  • Assessment: Rapid evaluation of breach scope and impact
  • Containment: Immediate action to prevent further unauthorized access
  • Notification: Timely notification to authorities and affected users

9.2 Incident Documentation

  • All incidents documented and tracked
  • Root cause analysis for all breaches
  • Remediation measures implemented and monitored
  • Regular review of incident response procedures

10. Privacy by Design

10.1 System Development

  • Privacy considerations integrated from project inception
  • Data protection impact assessments for new features
  • Regular security testing and vulnerability assessments
  • User privacy controls built into all systems

10.2 Default Settings

  • Privacy-friendly default settings
  • Minimal data collection by default
  • Clear user controls for data processing
  • Regular review of default configurations

11. Training and Awareness

11.1 Staff Training

  • Mandatory data protection training for all employees
  • Regular updates on regulatory changes
  • Incident response training and drills
  • Privacy awareness in daily operations

11.2 User Education

  • Clear privacy notices and policies
  • Regular blog posts and updates on privacy topics
  • User guides for privacy controls
  • Transparent communication about data practices

12. Compliance Monitoring

12.1 Regular Assessments

  • Monthly: Security monitoring and incident review
  • Quarterly: Data processing audits and compliance checks
  • Annually: Comprehensive privacy impact assessments
  • Ongoing: Regulatory monitoring and policy updates

12.2 Documentation

  • Comprehensive records of all processing activities
  • Documentation of legal basis for all processing
  • Records of user consent and preferences
  • Audit trails for all data access and modifications

13. Contact Information

13.1 Data Protection Inquiries

  • Email: [ADMIN_EMAIL]
  • Subject: Include "Data Protection" for faster routing
  • Response Time: Within 5 business days

13.2 Emergency Contact

  • Security Incidents: Report immediately to [ADMIN_EMAIL]
  • Data Breaches: 24/7 incident response team
  • Urgent Requests: Mark as "URGENT" in subject line

This Data Protection Policy is regularly reviewed and updated to ensure ongoing compliance with applicable data protection laws and best practices.