SnapHolo Privacy Policy

Notice date: 2026-10-23

Effective date: 2026-10-23

Linking advertising visits to accounts and retaining transaction amounts starts on 2026-10-29 at 00:00 KST. Before then, we do not save the new visit records in browser or server storage or record transaction amounts in the new ledger. Existing sign-in, Pro purchase verification and GA4 usage statistics continue.

Friend invite records (see "Friend invites" below) are created only when the friend invite feature is used. If it is not used, we do not create or store invite codes, invite relationships or stage records.

1. Operator

Company: BLEX LLC
Privacy officer: Privacy lead, Operations team / Contact: cs@snapholo.com

2. What we handle

You do not type anything when you sign up; you only choose whether to receive advertising emails (optional). We handle only the following.

Sign-in identifier: the account number that Google or Apple gives us
A login token (session) and when it was issued, last used and expires: on the web it is kept in a cookie; the app keeps it in the device's secure storage and sends it with each request. Our server stores only a hash of the token, not the token itself.
When a sign-in method was linked and when you last logged in
If you sign in with Google: your Google profile name and profile photo address (replaced with the latest values Google gives us each time you sign in)
If you sign in with Apple: a token issued by Apple, used to disconnect from Apple when you delete your account (stored encrypted)
Email address (required) and when it last changed: the email address that your Google or Apple account gives us when you sign in (replaced with the new value if it has changed when you sign in). If you use Apple's "Hide My Email", we receive the relay address Apple creates (see "Email" below).
Consent record for advertising emails (optional): whether you agreed, when you agreed or withdrew, and the version of this policy at that time (see "Email" below)
Daily scan limit record: the numbers of the cards recognized that day (see "Card scanning" below)
Usage records: for each scan, the time, the result (confirmed, candidates, no card, card back, free limit reached or error), the top card, and whether it was on the web or app; collection records (adding, removing or changing the quantity, with the time, the card, whether it is owned or wanted, the quantity and the screen it was added from); when and from which screen each collection card was first added; and your last access time
Access environment records: the path you signed up through (web or app) and the device type (iPhone, Android, PC or other mobile web), the app version, your language setting, the country you connected from (only a country code derived from the IP address), and the first and last access time for each path and device (see "Access environment and country" below)
Pro expiry date (Pro accounts only)
Pro purchase records (if you buy Pro): the store (App Store or Google Play), the store's transaction identifier, the product, the expiry time, the status, and records of purchase confirmation, restores and account transfers (see "Pro payments" below)
Purchase link random identifier: a random value (one per account) that the app sends to the store when you buy Pro, so that the purchase can be linked to this account
Friend invite records (if you use friend invites): your invite code, the invite relationship (who invited whom), the time an invited account first reached each stage, coupon issue and use records, and a hash used to check for rejoining (see "Friend invites" below)

What we do not collect: date of birth, country of residence, contact details other than email (such as phone numbers), payment methods such as card numbers, IP address. Our servers use the IP address of the connecting device only for rate limiting and to identify the country you connect from, in memory and briefly (within two minutes), and never record or store it (for the hosting provider's access logs, see section 5; for what Google receives directly, see "Analytics"). We ask Google for your profile (name and photo) and email address. We ask Apple for your name and email address, but we do not read or store the name.

3. Purposes

Identifying members and keeping them logged in
Linking sign-in methods to one account
Handling account deletion
Showing your Google profile name and photo in the top bar and on the account screen
Counting free usage limits (cards scanned per day, cards in your collection)
Confirming Pro purchases and calculating the Pro period, restoring purchases, applying refunds, and keeping transaction records (see "Pro payments" below)
Friend invites: issuing coupons, preventing abuse (self-invites, multiple accounts, rejoining after deletion) and invite usage statistics (see "Friend invites" below)
Sending service emails: information emails needed to use the service, such as price change alerts and payment and account notices (see "Email" below)
Sending advertising emails and keeping proof of consent (only if you agree)
Running the service and usage statistics: we look at per-member usage records and last access times to see how the service is running and how it is used
Answering member inquiries and running the service: only authorized operations staff see members' email addresses, usage records, collection counts (owned/wanted and quantities), daily scan-limit records, Pro purchase status and last visit time on our admin screens (not purchase prices or notes)

4. Retention and deletion

When you delete your account, the account, its sign-in identifiers, profile name and photo address, email address, consent record for advertising emails, sessions and daily scan limit records are deleted immediately.
Per-member usage records (scan and collection records) are kept while you are a member; when you delete your account, we cut the link to you (the member number is removed) and keep them only as anonymous statistics that cannot be traced to anyone. Your last access time and when and from which screen each collection card was first added are deleted immediately with the account and collection.
If disconnecting from Apple fails, only that token is kept, encrypted, until the disconnection succeeds, and is then deleted.
The login token is removed when you log out or when it expires (30 days after it was last used).
Daily scan limit records are deleted two days after that day.
News comments and display names remain after you delete your account and are deleted on request (see "News comments" below).
When you delete your account, we cut only the link between your Pro purchase records and the account, keep the records for the periods set by the Enforcement Decree of the Korean Electronic Commerce Act (5 years for records of contracts, payments and supply; 3 years for records of dispute handling), and then delete them. The purchase link random identifier is deleted immediately with the account.
Friend invite records: your invite code and your coupon issue and use records are deleted immediately with the account. When you delete your account, we cut the link between the invite relationship record (including stage times and the rejoin-check hash) and both the inviting member and the invited member (the member number is removed), and keep it only as a statistics record that cannot be traced to anyone (see "Friend invites" below).

5. Service providers (processors)

Railway Corporation (United States): hosting of the service's servers and database — servers located in Singapore
Google LLC (United States): verifying Google sign-in, delivering Android app notifications (Firebase Cloud Messaging — device notification token and notification content), usage statistics (Google Analytics and Firebase Analytics — see "Analytics" below), app error reports (Firebase Crashlytics — see "Analytics" below), and personalized advertising (Google Ads — see "Personalized advertising (behavioral information)" below)
Apple Inc. (United States): verifying Apple sign-in, disconnecting from Apple when you delete your account, and delivering iPhone app notifications (APNs — device notification token and notification content)
Resend, Inc. (United States): sending News comment operator alerts (new comments and reports) by email — sent only to SnapHolo operators, and they include the commenter's display name and the comment text, and report alerts also include the reporting member's display name and a pseudonymous identifier (a random string derived from the member number); sent from Japan (Tokyo). Alert emails in the operator mailbox are deleted after 90 days, and Resend's sending records are deleted after 30 days
Cloudflare, Inc. (United States): storing News backups (R2) — a daily copy of the news database and uploaded files
Ahrefs Pte. Ltd. (Singapore): web usage statistics (Ahrefs Web Analytics — see "Analytics" below)
Hosting provider's access logs: Railway's platform access logs may record the IP address of the requesting device, and their retention follows Railway's own policy. The SnapHolo service itself does not store IP addresses.
Apple's and Google's processing of Pro payments is not entrusted by us; each store does it directly (see "Pro payments" below).

6. Transfers abroad

The service's servers and database are located abroad, so the information in this policy is processed and stored abroad.

Country and recipient: Singapore — servers operated by Railway Corporation (United States)
Items: the information in section 2, the records in "Optional collection and profile records", the photos and records in "Card scanning", the records in "News comments", and the records in "App notifications"
Timing and method: each time you use the service, over encrypted internet connections (HTTPS)
Retention: as stated in section 4, "Card scanning" and "App notifications"
News comment operator alerts are sent through Resend from Japan (Tokyo), and News backup copies are stored with Cloudflare (R2) in the Asia-Pacific region; retention is as stated in "News comments".
If you sign in with Google or Apple, information is exchanged with Google LLC or Apple Inc. (United States) to verify the sign-in.
If you buy Pro, then at each purchase, restore, renewal, cancellation or refund and at our daily check, we send the transaction identifier over encrypted internet connections (HTTPS) to the store servers of Apple Inc. (United States) and Google LLC (United States) to look up the purchase's status, and the purchase link random identifier is sent to the store with the purchase from the app (see "Pro payments" below).
App notifications are delivered to your device through Google LLC (Firebase Cloud Messaging) or Apple Inc. (APNs) (United States) each time one is sent, and usage statistics are sent to Google LLC (United States) for Google Analytics and Firebase Analytics each time you use the web or the app; retention is as stated in "Analytics".
Web usage statistics are also sent to Ahrefs Pte. Ltd. (Singapore) for Ahrefs Web Analytics each time you use the web; retention is as stated in "Analytics".

7. Age

We do not ask for your date of birth or age. Only people aged 14 or older in Korea, or 13 or older in other countries, may sign up. If you are younger, you may not sign up.

8. Cookies

On the web we use the three kinds of cookies below (and values kept in your browser for the same purposes).

Essential cookies: keeping you logged in (30 days after last use) and security during sign-in (10 minutes). They are needed to provide the service and cannot be turned off.
Analytics cookies: usage statistics with Google Analytics 4 (GA4; see "Analytics" below). Kept for up to two years.
Advertising cookies: personalized advertising and measuring ad results with Google Ads (see "Personalized advertising (behavioral information)" below). Not used in the European Economic Area, the United Kingdom or Switzerland.
To refuse: you can refuse analytics cookies by blocking cookies in your browser settings or using the Google Analytics Opt-out Browser Add-on (tools.google.com/dlpage/gaoptout). You can refuse advertising cookies by turning off personalized ads in Google Ad Settings (adssettings.google.com) or by blocking cookies in your browser. Refusing does not affect your use of the service.

9. Your rights

You can delete your account yourself on the account screen; all of the information above is then deleted (News comments are handled as stated in "News comments" below, and Pro purchase records, usage records and friend invite records as stated in section 4). For anything else, contact the privacy officer (cs@snapholo.com).

10. Changes

If this policy changes, we will announce it on the site. Material changes that are unfavorable to users will be announced at least 7 days before they take effect.

11. Optional collection and profile records

We store the nickname you choose, wanted/owned card identifiers, quantity, purchase price and currency, purchase date, and notes to sync your collection across devices and calculate its value. These entries are optional. You can remove card records on My page. Nickname and collection records are deleted with your account (usage records such as adding and removing cards remain only as anonymous statistics, as stated in section 4).

12. Card scanning

Card photos taken with your camera are sent to our recognition server for processing, and we may store them for research and analysis to improve recognition accuracy and the service. No account information is attached to the photo.
Recognition results (card candidates, scores, photo quality and the like), and whether you saved or removed a result, are kept for 180 days as anonymous records not linked to any account, and used to improve the service.
To count the free daily scan limit, we keep the numbers of the cards recognized that day together with your account and the date, and delete them after two days. The date follows your device's time zone; the time zone itself is not stored.
Separately, for each scan we keep the usage records in section 2 (time, result, top card, web or app) with your account (retention as in section 4).

13. News comments

When you sign in with your SnapHolo account and comment on News (/news), we keep the following in the news program that SnapHolo runs itself (Ghost).

News member record: an internal identifier that hides your member number, and an email-shaped value made from it. Nothing is ever sent to that address, and your actual email address is not passed to the news program.
Display name: your nickname or Google profile name; if you have neither, the name you type in the comment box
The short bio you type in the comment box (optional)
Comment text, when it was posted or edited, likes you give to comments, and reports you file
Purposes: posting and showing comments, and handling reported comments. SnapHolo operators hide or delete reported comments.
Comment text and display name can be seen by anyone on the News pages. We do not provide comment information to third parties.
Your News comments and the display name shown next to them (your news member record) are kept even after you delete your account. To have them removed, email cs@snapholo.com and an operator will delete them (backup copies disappear after up to 90 days).
Logging out also signs you out of News in that browser. News sign-ins on other devices remain until you log out there or the sign-in expires.

14. Analytics

On the web, we use Google Analytics 4 (GA4) to collect usage statistics such as the screens you visit, your device type and your approximate region. We do not send your name or any other information that identifies you. GA4 uses the connection IP to work out an approximate region but does not log or store IP addresses (according to Google).
The web also collects usage statistics with Ahrefs Web Analytics: the address of the page you visit, the address of the previous page (how you arrived), browser and device information, screen size, language, and country and city. It uses no cookies, does not store the IP address used to work out the country and city, and counts visitors only with a random value that changes every day (according to Ahrefs). Your member number, name and email address are not sent.
When a web page hits an error, or a request to our server fails or takes longer than 3 seconds, we send a record of it (the error message, the page file and line where it happened, and the request path with its response status and duration) with the same GA4 usage statistics. Query strings and numeric or identifier parts of the path are removed before sending, and at most 10 records are sent per page.
In the app, we use Firebase Analytics to collect usage statistics such as screen views and share events.
While you are signed in, we send your SnapHolo internal member number with the web and app usage statistics so that the same member's use across devices, the web and the app can be viewed together. We do not send your name or email address, and we stop sending the member number when you sign out.
If the app crashes or fails to reach our servers, it sends an error report (the error, device model, and operating system and app versions) through Firebase Crashlytics. These reports are not linked to your account and are kept for 90 days.
We do not collect advertising identifiers (IDFA on iPhone, Advertising ID on Android).
How to turn it off: on the web, block cookies in your browser or use the Google Analytics Opt-out Browser Add-on (tools.google.com/dlpage/gaoptout). The app has no setting to turn off usage statistics.
Retention: according to the Google Analytics data retention setting (up to 14 months). Ahrefs Web Analytics follows Ahrefs' retention policy.

15. Personalized advertising (behavioral information)

What we collect: records of how you use the web, such as the screens you view, when you visit, and whether you arrived by clicking an ad (behavioral information). We do not send your name, email address or any other information that identifies you.
How: collected automatically by Google's advertising and analytics cookies when you use the web.
Purposes: to show SnapHolo ads again through Google Ads (Search, YouTube and Display) to people who have visited SnapHolo, and to measure ad results (such as sign-ups and scans).
Company that collects and processes this information: Google LLC (United States)
Retention: you stay on an ad audience list for 30 days after your last visit; other records follow the Google Analytics data retention setting (up to 14 months).
Regions: advertising cookies are not used in the European Economic Area, the United Kingdom or Switzerland.
How to refuse: turn off personalized ads in Google Ad Settings (adssettings.google.com) or block cookies in your browser. Refusing does not affect your use of the service.
Contact: privacy contact (cs@snapholo.com)

16. Provision of personal information to third parties

SnapHolo does not provide your personal information to third parties.

17. App notifications

What we handle: device notification tokens (platform, token, device time zone and when it was last updated), your notification settings, and your consent record for advertising notifications (whether you agreed, when you agreed or withdrew, and the version of this policy at that time)
Purposes: delivering notifications, keeping proof of consent for advertising notifications, and keeping advertising notifications within the allowed hours
Retention: a device notification token is deleted when you turn notifications off, log out or delete your account. Consent records are deleted together with your account when you delete it.

18. Advertising push notifications

Receiving advertising information as app notifications is optional and off by default. If you do not agree, nothing changes in how you can use the service.
How to turn it off: in the app, go to Account > Notifications, or turn off SnapHolo notifications in your device settings.
Advertising notifications are sent only between 8 a.m. and 9 p.m. in your device's local time, and their titles start with "(Ad)".
When you agree or withdraw, we show you the result in the app right away.
If you have agreed, we ask again every two years whether you still agree.
We do not send advertising by text message (we do not collect phone numbers). Advertising emails require separate consent, as described in "Email" below.

19. Email

What we receive (required): the email address that your Google or Apple account gives us when you sign in. If you choose Apple's "Hide My Email", we receive a relay address created by Apple, and Apple forwards mail sent to it to your inbox.
Service emails: we send information emails needed to use the service, such as price change alerts and payment and account notices, to this address. The legal basis is performance of our service contract with you.
Advertising emails: receiving them is optional and off by default. You can choose on the sign-up screen, or turn them on or off later on My page on the web or on the app's account screen. If you do not agree, nothing changes in how you can use the service.
Consent record: we keep whether you agreed, when you agreed or withdrew, and the version of this policy at that time, as proof of consent.
Advertising emails start their subject with "(Ad)", and their body states the sender (SnapHolo), our contact details and how to unsubscribe.
To unsubscribe or withdraw: at any time and free of charge, on My page on the web, on the app's account screen, or with the unsubscribe link in each email; we let you know the result.
If you have agreed, we ask again every two years whether you still agree.
Retention: your email address and consent record are deleted together with your account when you delete it.
Sending providers: we currently do not entrust the sending of emails to members to any other company (Resend in section 5 is used only for operator alert emails).

20. Pro payments

You buy Pro inside the SnapHolo app through in-app purchase on the App Store or Google Play. The stores (Apple and Google and their affiliates) handle the sale and payment directly on SnapHolo's behalf, each under its own terms and privacy policy, and we do not receive payment information such as card numbers or other payment methods, your name, email address or billing address.
What we store: the store (App Store or Google Play), the store's transaction identifier (Apple's original transaction ID or Google's purchase token), the product (monthly or yearly subscription, or lifetime pass), the expiry time, the status (active, grace period, expired, refunded and so on, and whether it auto-renews), when we last checked it, and records of purchase confirmation, restores and account transfers
We retain verified transaction amounts, currencies, purchase times and refund times with purchase records. We do not store store country, payment methods or billing addresses.
How we receive it: when you buy or restore, the app sends the store-signed transaction to our server, and the server confirms it by looking the transaction identifier up with Apple (App Store Server API) or Google (Google Play Developer API). When a renewal, cancellation or refund happens, the store notifies our server (App Store Server Notifications or Google Play Real-time developer notifications), and the server looks the purchase up again then and at our daily check to keep the Pro period correct.
Purchase link random identifier: so that we know which account a purchase belongs to, the app sends a random value made for each account to the store with the purchase, and the store returns it in the transaction information. It is not linked to information such as your name or email address.
Legal basis: performance of the Pro contract (confirming purchases, calculating the Pro period, restoring purchases, applying refunds). Keeping the records after you delete your account is the retention of transaction records required by the Korean Act on the Consumer Protection in Electronic Commerce.
Transfers abroad: at the times above, information is exchanged with the store servers of Apple Inc. (United States) and Google LLC (United States) over encrypted internet connections (HTTPS) (section 6).
Retention: as stated in section 4 — when you delete your account, we cut only the link to the account, keep records of contracts, payments and supply for 5 years and records of dispute handling for 3 years, and then delete them.

21. Advertising visits and purchase statistics

We keep the campaign, creative and keyword tags (UTM) from an advertising link and the visit time in browser analytics storage for up to 30 days. After sign-in, we link them to the same account to compare web visits with app purchases. Visit records are deleted after 90 days or when the account is deleted. We do not store Google click identifiers (gclid, gbraid or wbraid), full visit URLs or IP addresses in these records. This is an internal last-paid-tagged-visit model within 30 days before purchase, not Google Ads attribution or proof of installation. App Store- and Google Play-verified transaction amounts, currencies, purchase times and refund times follow the retention period for purchase records. Free trials, sandbox transactions and transactions without an amount are not inferred as paid revenue. Blocking browser storage or analytics can prevent this link.

22. Friend invites

Optional feature: nothing changes in how you use the service if you do not use friend invites. Entering an invite code when you sign up is also optional.
What we handle (inviting member): your invite code (one per member, created when you first open the friend invite screen) and coupon issue and use records (the stage and round a coupon was issued for, its number of days or whether it is a lifetime coupon, when it was issued, its status (available, used or void) and when it was used, the Pro grant record that is left on your account's Pro period when you use a coupon, and the record of cases where no coupon was issued because of the limit or a lifetime coupon)
What we handle (invited member): the invite relationship (the link between an account that signed up with an invite link or invite code and the member who owns that code, and the sign-up time); the time the account first reached each stage (the time of the first card scan in the app, the time 100 different cards recognized in the app were first reached, and the time of the first paid purchase together with whether it is a monthly subscription, a yearly subscription or a lifetime pass); and the store and transaction identifier, so that the same payment is not counted twice
Rejoin-check hash: a value made one way only from the sign-in identity (Google or Apple account number) the invited member first signed up with. It cannot be turned back into the original value, and it is used only to stop someone who deleted their account from signing up again with the same account and being counted as an invite again.
How we receive it: our server records it automatically when you sign up with an invite link or invite code and while you use the service. An invite code can be entered only when signing up.
Purposes: issuing coupons, preventing abuse (self-invites, multiple accounts, checking for rejoining) and invite usage statistics
What is visible: the inviting member cannot see the invited friend's identity, such as name or email, and sees only the number of friends at each stage and the coupons received. The invited member cannot see the inviting member's information either. Authorized operations staff see, on our admin screens, a masked account and totals of friends per stage, coupons issued and used, and days granted.
Legal basis: performing the friend invite rewards section of the Terms of Service, and preventing abuse
Transfers abroad: like the information in section 2, the above is processed and stored abroad as stated in section 6.
Retention: as stated in section 4 — when you delete your account, your invite code and coupon issue and use records are deleted immediately with the account, and the invite relationship record has only its link to the members cut and is kept for statistics. The remaining stage times and rejoin-check hash cannot show whose record it is.

23. Access environment and country

What we process: the path you signed up through (web or app) and the device type, the app version, your language setting, the country you connected from, and the first and last access time for each path and device
How we receive it: the server records it automatically when you sign up or sign in and while you use the service signed in (at most once an hour for the same path and device). The device type and app version come from the device information the app or browser sends (User-Agent), and the language from your device's language setting.
Country: we derive the country from the IP address of the connecting device and keep only a two-letter country code (for example KR, JP or US). The IP address is used only in memory while the country is looked up and is never recorded or stored. Country lookup uses IP Geolocation by DB-IP (db-ip.com, CC BY 4.0).
Existing members: for members who joined before this record started (2026-10-23), the sign-up path and device are estimated from existing usage records (devices registered for app notifications, web or app scans, sign-in method) and marked as "estimated".
Purposes: running the service and usage statistics (member counts by path, device and country), and answering member inquiries
Retention: deleted immediately together with your account when you delete it.