Last updated: July 2026
This Privacy Policy (“Policy”) applies to Spectacom Global Private Limited (“Company”, “SnapdMe”, “We”, “Us” or “Our”), a company incorporated under the Companies Act, 2013, having its registered office at 809 Udyog Vihar, Phase V, Gurugram, Haryana – 122016, India, and its subsidiaries, holding company and affiliates, wherever the context so requires. The Company owns and operates the website www.snapdme.com and any associated mobile application (collectively, the “Platform”), through which the Company provides facial-recognition-enabled event photo discovery, matching, retrieval and sharing services, and any ancillary products or content offered in connection therewith (“Services”).
This Policy describes how We collect, receive, store, use, process, disclose, transfer and otherwise handle information relating to You (“You”, “Your”, “User”, “Data Principal”) when You visit, register on, or otherwise interact with the Platform, use the Services to search for or retrieve Your photographs from an event, or otherwise communicate with Us. This Policy does not apply to information collected by any third party, including an Event Organiser (defined below) or any third-party website, application or service that You may access through or in connection with the Platform, and We assume no liability in respect of the same.
Please read this Policy carefully, and in particular Section 4 (Facial Recognition and Biometric Data), before using or registering on the Platform, or uploading a photograph of Yourself to search for Your Event Media.
By accessing or using the Platform, creating an account, or otherwise providing information to Us including by uploading a photograph of Yourself for facial-recognition matching, You accept and agree to be bound by this Policy and consent to the collection, storage, use, processing, disclosure and transfer of Your information, including Personal Data (defined below) and Biometric Data (defined below), in the manner described herein. If You do not agree with this Policy, in whole or in part, You must not access or use the Platform or avail the Services.
This Policy is incorporated into, and must be read together with, Our General Terms & Conditions (“Terms”). All capitalised terms used but not defined in this Policy have the meaning given to them in the Terms.
The Platform is not intended for, and We do not knowingly permit registration by, a person under the age of 18 years, and We do not knowingly collect Biometric Data or other Personal Data directly from such a person. Section 17 below sets out how We handle the Personal Data of minors who may appear in Event Media captured by an Event Organiser.
We may update this Policy to reflect changes in Our practices or to comply with legal, regulatory or administrative requirements. Where We make a material change, We will provide reasonable notice, such as a prominent notice on the Platform, and will update the “Last updated” date above. To the extent permitted by applicable law, Your continued use of the Platform after such notice constitutes Your acceptance of the revised Policy.
We collect the following categories of information about You, directly from You, automatically through Your use of the Platform, and, in limited circumstances, from third parties as described in this Section:
This includes Your complete name, date of birth, gender and photograph (used, among other things, to register You for an Event Organizer’s event and, where You choose to create a public User Account, to display on Your profile); correspondence details such as Your email address, telephone number and postal address, used to communicate with You, resolve Your queries, and provide support in relation to the Services; financial and payment information such as Your bank account, payment account, credit or debit card, UPI or other payment instrument details, used solely to enable and effect Your transactions on the Platform; emergency contact details, where an Event Organizer requires this information to register You for its event; and any other information You voluntarily provide when You leave Us a message, take part in a customer support conversation or survey, or where We assist with a matter relating to law enforcement or an investigation.
Provision of this information is voluntary; however, certain information is mandatory to avail specific Services (such as completing an event registration or processing a payment), and Your inability or unwillingness to provide such mandatory information may mean We, or the relevant Event Organizer, cannot provide the corresponding Product or Service to You.
Certain of the information We process, passwords; financial or payment instrument details; and Biometric Data (including facial-recognition data generated from a photograph You upload, or in which You appear, for event photo-matching purposes). Section 4 describes how We collect, use, retain and protect Biometric Data specifically. Any information that is freely available or accessible in the public domain, or furnished under the Right to Information Act, 2005 or any other law for the time being in force, is not treated as Personal Data for the purposes of this Policy.
Where You subscribe to, or make a payment for, a Service, We collect and store information about Your transactions, including transaction status, order and payment history. Payment card and similar instrument details are processed by Our third-party, secure payment gateway partners, and We do not store Your full card or payment instrument details on Our own servers. We also process one-time passwords and similar short messages used to verify Your device and secure Your account.
We may collect Your IP address, device model, operating system, browser type, and unique device or session identifiers when You access the Platform. We use this information to diagnose and resolve technical issues, administer the Platform, maintain security, and derive broad, non-identifying demographic and usage information.
We may receive information about You, and Event Media in which You may appear, from Event Organisers, payment gateways, and analytics providers, where such third parties are lawfully entitled to share the information with Us and represent to Us that they have obtained all consents necessary to do so, including in respect of any Event Media uploaded to the Platform.
We, and Our authorised third-party partners, collect non-identifying and automated information including but not limited to browser type, internet service provider, aggregate usage data, IP addresses, operating systems, session identification numbers, and cookie data through cookies, web beacons, clear GIFs, pixel tags, and similar tracking technologies placed on the Platform. These technologies are deployed to ensure Our Platform functions securely, to optimise performance, remember Your preferences, analyse traffic trends, measure promotional efficacy, and maintain architectural security.
We categorise these tracking technologies as follows:
You may occasionally encounter cookies deployed by third-party companies, sponsors, or advertisers via hyperlinks or embedded content on the Platform. We do not control, review, or supervise these third-party cookies, and they are entirely exempt from this Policy. You retain the capability to accept, decline, or modify cookie configurations through Your browser settings, though blocking essential cookies may affect Platform functionality.
Separate from automated site data, You expressly agree that if You transmit personal correspondence to Us (such as emails, letters, or support requests), or if other Users or third parties forward correspondence to Us regarding Your specific activities on the Platform, We reserve the right to collect, compile, and store such information within Our systems for security, verification, and legal-defence purposes.
We use the information described in Section 2 for the following purposes (collectively, the “Purposes”):
We will not share Your Personal Data with another User of the Platform without Your express consent. We may monitor or record customer-support calls or chats for training, quality, legal compliance, or to establish or defend a legal claim.
This Section applies specifically to Our use of facial-recognition technology and Biometric Data as follows:
We use Biometric Data solely to enable You to discover and retrieve Event Media in which You appear, by matching a photograph You upload against Event Media made available by Event Organisers. We do not use Biometric Data to build a general profile of You, for behavioural monitoring, or for targeted advertising, and We do not use it for any purpose beyond event photo discovery, unless We separately obtain Your explicit consent for such other purpose.
We collect and process Your Biometric Data only after You provide explicit, informed and affirmative consent through the consent mechanism provided on the Platform before uploading Your photograph. You may decline to provide Biometric Data, in which case You will not be able to use the facial-recognition matching feature of the Services, though You may still be able to browse or search Event Media by other means made available for an event (such as an event code or gallery, where offered).
Our facial-recognition and photo-matching technology is developed and operated in-house by the Company. We do not share, sell, rent or license Your Biometric Data to advertisers or other unrelated third parties. Biometric Data is stored and processed exclusively on servers owned and controlled by the Company. Event Media is captured using data storage devices owned by the Company, which are issued to photographers engaged for the relevant event and returned to the Company on conclusion of the event. We may share Biometric Data and Event Media with select third-party technology and service providers engaged to support specific technical functions of the Services, each of whom is bound by confidentiality and data-protection obligations at least equivalent to those undertaken by Us under this Policy.
We implement encryption, access controls, and other appropriate technical and organisational measures for the storage and processing of Biometric Data, consistent with Section 8. Facial-recognition technology is probabilistic in nature and may not identify every photograph accurately. The Company does not warrant that all matches generated by the Platform will be complete or error-free.
Photographs and videos captured as Event Media are retained by the Company for so long as the Company retains rights over such Event Media under Section 5, which may be in perpetuity. Biometric Data (facial-recognition templates) derived from such Event Media, or from any photograph You upload to search for Your Event Media, is used solely to enable photo-matching and retrieval for the relevant Event and is automatically and permanently purged from Our systems within 90 days of the conclusion of that Event, or such period as Our systems are configured to apply once photo-matching and retrieval for that Event has concluded. Purging Your Biometric Data does not require Us to delete the underlying photograph or video, which the Company (or the relevant Event Organiser) may continue to hold and use in accordance with Section 5. Where You withdraw Your consent under this Section before such purging occurs, We will cease using Your Biometric Data for facial-recognition matching and will remove the corresponding facial-recognition template within a reasonable period, without affecting the retention of the underlying Event Media as described above.
You may withdraw Your consent to the processing of Your Biometric Data at any time by writing to Us at the email address in Section 14. On withdrawal, We will cease using Your Biometric Data for facial-recognition matching and will delete it within a reasonable period, save that withdrawal will not affect the lawfulness of processing carried out before withdrawal, and may mean We can no longer offer You the facial-recognition matching feature of the Services.
We do not knowingly enrol the Biometric Data of a person under the age of 18 for facial-recognition matching without verifiable consent from a parent or lawful guardian. Where an Event Organiser’s Event Media includes minors who are not themselves Users of the Platform, We rely on the Event Organiser’s representation, as described in Section 5, that it has obtained all consents necessary under Applicable Law for such minors to be photographed and for that Event Media to be made available on the Platform. We do not independently create a facial-recognition profile of such a minor for any purpose beyond enabling a verified parent or lawful guardian to retrieve that minor’s photographs, and We will act promptly on any request under Section 17 concerning a minor’s information.
We may disclose Your information, including Personal Data, to the following categories of recipients, for the purposes described in this Policy:
We do not sell Your Personal Data to any third party for monetary consideration, and, as set out in Section 4, We do not share Your Biometric Data with advertisers or unrelated third parties. We may share aggregated or anonymised information, which does not identify You, with third parties at Our discretion, including for research, analytics or promotional purposes.
Your Personal Data may be stored, hosted or processed on servers located outside India, including by Our cloud infrastructure and IT service providers. We will only transfer Personal Data outside India in accordance with Applicable Law, and will not transfer Personal Data to any country or territory restricted by the Central Government of India from time to time under Section 16 of the Digital Personal Data Protection Act, 2023. Where We transfer Personal Data outside India, We will require the recipient to be contractually bound to apply protections substantially equivalent to those required of Us under this Policy and Applicable Law.
We maintain reasonable security safeguards and procedures, including technical and organisational measures such as encryption and access controls, to protect Your privacy and Personal Data (including Biometric Data) from loss, misuse, unauthorised access, disclosure, destruction, and alteration, in compliance with Applicable Law.
You are responsible for maintaining the confidentiality of Your account credentials and for all activity that occurs under Your account. You agree to notify Us immediately of any unauthorised use of Your account or any other suspected breach of security. We are not liable for loss or damage arising from Your failure to keep Your login credentials, password or one-time passwords confidential; please never share these with anyone, including anyone claiming to represent the Company.
Payment information transmitted through the Platform is protected using industry-standard encryption. While We take reasonable steps to secure Your information, no method of transmission or storage is completely secure, and We cannot guarantee absolute security against a sufficiently determined unauthorised third party. Subject always to Our statutory obligations, We are not liable for unauthorised access, disclosure or loss of Your information that results from causes beyond Our reasonable control, including a security breach on a third-party website or platform, or a Force Majeure Event.
A “Force Majeure Event” means any event beyond Our reasonable control, including but not limited to acts of God, fire, explosion, war, civil unrest, strikes, epidemic or pandemic, cyberattack, governmental action or restriction, or failure of a third-party hosting, telecommunications or internet service provider.
If We become aware of a personal data breach that affects Your Personal Data, We will, in accordance with Applicable Law, notify the Data Protection Board of India and take reasonable steps to notify affected Data Principals without undue delay.
We retain Personal Data only for as long as necessary to fulfil the Purposes for which it was collected, including to meet legal, accounting or reporting requirements, or as otherwise required or permitted under Applicable Law. As a general guide: account data is retained for the duration of Your relationship with the Platform and for a reasonable period thereafter to address post-event queries; transactional and payment data is retained in accordance with applicable financial record-keeping requirements; and Biometric Data is retained as described in Section 4.
Where You request erasure of Your information, We will honour that request, save that We may retain certain information where permitted or required by Applicable Law, including to prevent fraud or abuse, to exercise or defend a legal claim, or to comply with a legal or regulatory obligation.
The Platform may contain links to, or embed content from, third-party websites or platforms, including payment gateways and Event Organiser microsites (“Third-Party Sites”). This Policy does not apply to, and We accept no responsibility for, the privacy or data-security practices of any Third-Party Site, which are governed solely by that Third-Party Site’s own privacy policy. We recommend You review the privacy policy of any Third-Party Site before providing information to it.
All information You disclose to Us is deemed to be disclosed willingly. We process Your Personal Data on the basis of Your consent, or, where permitted under Applicable Law.
You may exercise the following rights by writing to info@spectacom.in, or through the Platform’s Settings, where available. We will acknowledge Your request within a reasonable time and respond within such period as Applicable Law may prescribe, and We may need to verify Your identity before actioning a request:
You should be aware that information You have shared on a third-party website, or that another User has independently copied or re-shared, may remain available even after You delete it from the Platform, as this is outside Our control.
We will only send You promotional or marketing communications (as distinct from transactional, administrative or safety-related communications necessary for Us to provide the Services) where You have provided the consent required under Applicable Law. You may withdraw Your marketing consent at any time through the Platform’s Settings or by writing to info@spectacom.in, and We will act on that request within a reasonable time. This Section does not affect Our ability to send You transactional or administrative communications relating to a Service You have used. Withdrawal of consent to receive promotional communications shall not affect the Company's ability to send transactional, security-related, legal, administrative or service communications that are necessary for providing the Services.
We have appointed the following Grievance Officer to address questions, concerns or grievances regarding this Policy or Our handling of Your Personal Data, and to assist You in exercising Your rights:
Name: Abishek Agarwal
Designation: Grievance Officer
Email: info@spectacom.in
Postal Address: Spectacom Global Private Limited, 809 Udyog Vihar, Phase V, Gurugram, Haryana – 122016, India
We will acknowledge Your query or grievance and aim to resolve it within a reasonable period. If You suspect any misuse of, or unauthorised access to, Your Personal Data (including Your Biometric Data), please let Us know immediately at the email above.
Certain data collected through the Platform, including Biometric Data, is stored with reputable third-party cloud infrastructure providers, which may store such data on servers located outside India, subject to Section 7. Any such provider is contractually required to maintain security measures consistent with this Policy and Applicable Law.
We are not responsible for, and disclaim liability in connection with, the security practices, content or privacy policies of a Third-Party Site or a third-party service provider engaged by You independently of the Company, including where that third party has independently obtained Your Personal Data.
The Platform and Our Services are intended only for individuals who are at least 18 years of age, and account registration is not available to persons under 18. As described in Section 4 and Section 5, Event Media uploaded by an Event Organiser may nonetheless include minors who are not themselves Users. We do not knowingly collect Biometric Data from, or create a facial-recognition profile of, a minor without verifiable consent from a parent or lawful guardian, and any exercise of rights under this Policy on behalf of a minor must be made by such parent or guardian. Where Event Media uploaded to the Platform contains identifiable images of minors, the Company does not independently create a facial-recognition profile of such minor for any purpose beyond enabling a verified parent or lawful guardian to retrieve that minor’s photographs. We will act immediately to purge any data if it is discovered that parental consent was not lawfully secured by the capturing party.
We do not use a minor’s Personal Data for behavioural monitoring, tracking or targeted advertising. Where We become aware that a minor’s Personal Data, including Biometric Data, has been provided to or processed by Us without the requisite verifiable parental or guardian consent, We will take reasonable steps to promptly verify such consent or, failing verification, to delete the relevant Personal Data.
We may update this Policy from time to time as described above. We encourage You to review this Policy periodically. Your continued use of the Platform following notice of a change constitutes Your acceptance of the updated Policy.
If any provision of this Policy is held to be invalid, illegal or unenforceable under Applicable Law, that provision will be severed from this Policy, and the remaining provisions will continue in full force and effect and will be interpreted so as to reasonably achieve the intent of the severed provision to the extent permitted by Applicable Law.