S&K PARTNERS GROUP LTD
Version 1.0 – 16 July 2025
1. INTRODUCTION
This Privacy Policy explains how S&K Partners Group Ltd (company number 14541157) , trading as Snap-Factory, collects, uses, shares and protects personal data when you visit https://snap-factory.com or purchase our digital photographs, AI-generated images and related assets (collectively, “Digital Content”).
We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU GDPR (together, “Applicable Data Protection Laws”).
2. CONTROLLER & CONTACT DETAILS
Role | Details |
Data Controller | S&K Partners Group Ltd, 291 Northfield Avenue, London W5 4XB, United Kingdom |
Company Enquiries | info@snap-factory.com |
Supervisory Authority | UK Information Commissioner’s Office (ICO) |
3. CATEGORIES OF PERSONAL DATA WE COLLECT
Category | Examples | Source |
Account Data | Name, e-mail address, password (hashed & salted), country | Direct from you |
Transaction Data | Order ID, Digital Content purchased, chosen currency (USD/EUR/AUD/GBP/CAD) | Direct and payment gateway |
Payment Tokens | Last 4 digits of card, card type, payment token, transaction status | Payment processor (Stripe/Adyen) – we neverstore full card numbers |
Usage Data | IP address, browser type, pages viewed, download logs, referral URL | Automated via cookies & server logs |
Device & Technical Data | Device ID, OS, time-zone (Europe/Madrid or as configured) | Automated |
Marketing Preferences | Newsletter opt-in/opt-out status | Direct |
Support Records | Live-chat transcripts, e-mail threads, refund requests | Direct |
We do not intentionally collect special-category data (e.g., health, biometrics) or data relating to children under 18.
4. PURPOSES & LAWFUL BASES OF PROCESSING
Purpose | Lawful Basis (Art. 6 UK/EU GDPR) |
Account creation & authentication | Performance of contract (Art. 6 (1)(b)) |
Processing payments & delivering Digital Content | Performance of contract |
Fraud prevention & strong customer authentication (SCA) | Legitimate interest (Art. 6 (1)(f)); legal obligation (PSD2/PSRs) |
Customer support | Performance of contract; legitimate interest |
Marketing e-mails & product updates | Consent (Art. 6 (1)(a)) – withdrawn anytime |
Analytics to improve Website performance | Legitimate interest (minimal impact, aggregated statistics) |
Legal compliance, accounting & record-keeping (7 years) | Legal obligation (Art. 6 (1)(c)) |
We will not use your personal data for automated decision-making producing legal effects within the meaning of Art. 22 UK/EU GDPR.
5. COOKIES & SIMILAR TECHNOLOGIES
We employ (i) strictly necessary cookies for core functionality, (ii) analytical cookies (e.g., Google Analytics 4 with IP anonymisation), and (iii) functional cookies to remember language and currency preferences. Detailed cookie list and consent options are provided in our standalone Cookie Policy.
6. DISCLOSURE OF DATA
We share personal data only when necessary and with appropriate safeguards:
- Payment processors: Stripe Payments Europe, Ltd.; Adyen N.V.
- Hosting & CDN providers: Hostinger International Ltd (EU data-centre) fileciteturn5file1; Cloudflare, Inc.
- Analytics & marketing: Google LLC (GA4, U.S.); Mailchimp/Mandrill (newsletter).
- Professional advisers: accountants, lawyers, auditors (bound by confidentiality).
- Authorities: HMRC, ICO or competent courts where mandated by law.
We do not sell or rent personal data to third parties.
7. INTERNATIONAL DATA TRANSFERS
Where service providers are located outside the UK/EEA (e.g., U.S.), we rely on:
- Adequacy Regulations (UK) or Adequacy Decisions (EU), or
- Standard Contractual Clauses (SCCs) adopted by the European Commission & UK Addendum, augmented by transfer risk assessments.
8. DATA RETENTION
Data Category | Retention Period |
Account & Transaction Records | 7 years after last transaction (tax & audit) |
Inactive Account (no login, no purchase) | 24 months then anonymised |
Support Tickets & Live-chat | 24 months from closure |
Marketing E-mail Logs | Until opt-out + 12 months to evidence consent |
Server Logs & Analytics | 14 months (aggregated thereafter) |
We may retain data longer where required by law or to establish, exercise or defend legal claims.
9. DATA SECURITY
- Encryption: TLS 1.3 in transit; AES-256 at rest (server-side).
- Access Controls: Role-based access, MFA for admin accounts.
- Vulnerability Management: Monthly patching, annual penetration testing.
- PCI-DSS Compliance: All card payments tokenised; no plain card data on our servers.
- Incident Response: 72-hour breach notification protocol under Art. 33 UK/EU GDPR.
10. YOUR RIGHTS
Subject to conditions, you have the following rights under Applicable Data Protection Laws:
- Access – obtain a copy of your personal data we hold.
- Rectification – correct inaccurate or incomplete data.
- Erasure (“right to be forgotten”) – request deletion when data is no longer necessary or processed unlawfully.
- Restriction – request we limit processing in certain cases.
- Portability – receive data in a structured, commonly-used format.
- Objection – to processing based on legitimate interest or direct marketing.
- Withdraw consent – at any time, without affecting prior lawful processing.
To exercise any right, contact info@snap-factory.com (proof of identity may be required). We will respond within one month (extendable by two months for complex requests).
If you believe we have infringed your privacy rights, you may lodge a complaint with the ICO (ico.org.uk) or the supervisory authority in your EU member state.
11. MARKETING COMMUNICATIONS
- We send marketing e-mails only with your prior consent (double opt-in).
- Opt-out at any time via the unsubscribe link or account settings; processing switches to suppression status to honour the opt-out.
12. THIRD-PARTY LINKS
Our Website may contain links to third-party sites. We are not responsible for their privacy practices; review their policies separately.
13. CHANGES TO THIS POLICY
We may amend this Policy to reflect legal, operational or technological developments. Material changes will be notified via e-mail or Website banner 14 days before they take effect.
14. CONTACT
Questions or requests concerning this Policy should be directed to:
Data Protection Lead
S&K Partners Group Ltd (t/a Snap-Factory)
291 Northfield Avenue, London W5 4XB, United Kingdom
E-mail:info@snap-factory.com
© 2025 S&K Partners Group Ltd. All rights reserved.