Privacy Policy

Last updated: 19/05/2026

SceneSnap S.r.l. ("SceneSnap," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and safeguard your personal information when you access our platform, website, or related services (collectively, the "Services"). By using SceneSnap, you agree to the practices described in this Privacy Policy.

1. Information We Collect

We collect information to provide and improve our Services, personalize learning experiences, and ensure platform security and compliance. The types of information we may collect include:

  • Personal Data: When you create an account or interact with our Services, we may collect personal information such as: - Name and surname - Email address - Institutional affiliation (if applicable) - Billing and payment information - Communication preferences
  • Usage Data: We collect information about how you use SceneSnap to improve functionality, measure engagement, and enhance learning outcomes. This may include: - Learning activity data (e.g., feature usage, course interactions, session logs) - Device, browser, and connection information - Time spent, materials uploaded, and AI feature interactions
  • Cookies and Tracking Technologies: We use cookies and similar technologies to improve functionality and user experience. Essential cookies are required for the website and platform to operate properly (e.g., login sessions, preferences, and security) and are always active. Non-essential cookies may be used for analytics, affiliate tracking, and marketing purposes, including personalized advertising, remarketing, and campaign measurement, and they are only activated with your explicit consent via the cookie banner shown on your first visit. You can change or withdraw your cookie consent at any time by accessing the "Cookie Settings" link available in the website footer. Rejecting non-essential cookies will not affect access to the platform, though some personalized or analytical features may be limited.

2. How We Use Your Information

We use the data we collect to:

  • Provide, maintain, and improve the SceneSnap platform.
  • Personalize learning experiences and content recommendations.
  • Process transactions, manage accounts, and provide customer support.
  • Communicate important updates, feature releases, and promotional offers.
  • Analyze trends and engagement to optimize educational outcomes.
  • Attribute user actions to affiliate partners (only with consent to non-essential cookies).

Use of Data for Research and Development

SceneSnap may use anonymized or aggregated data for research purposes to improve AI capabilities and contribute to academic understanding of learning, human-computer interaction, and personalization. All research data is processed in accordance with GDPR and ethical research standards. When findings are published or shared, all personal identifiers are permanently removed.

Advertising and Marketing

We may use your personal data, subject to your consent where required, to deliver personalized advertising, measure the effectiveness of our campaigns, and improve our marketing strategies.

This may include showing you relevant ads based on your interaction with our platform (e.g., remarketing) and building audiences to reach users with similar interests or behaviors.

These activities may involve third-party advertising platforms such as Google Ads.

Where a valid legal basis exists (such as your consent), we may use limited identifiers (such as hashed email addresses) to create custom audiences on these platforms.

3. Sharing Your Information

SceneSnap does not sell or rent your personal data. We only share information under the following circumstances:

  • With Service Providers: We may share limited data with third-party partners who assist with hosting, analytics, payment processing, artificial intelligence processing, and customer support. These partners are bound by strict data protection agreements and may not use your data for any other purpose.
  • With Institutional Partners: If you access SceneSnap through a university, company, or other organization, limited activity and usage data may be shared with that institution for educational reporting and performance tracking purposes, in compliance with GDPR and contractual obligations.
  • For Research Collaborations: SceneSnap may collaborate with universities, research consortia, or other partners to advance scientific knowledge in learning and AI. Only fully anonymized and aggregated data may be shared under data processing or research cooperation agreements. SceneSnap may also publish anonymized insights and statistical findings to contribute to open research and educational innovation.
  • Legal Obligations: We may disclose information when required by law, legal process, or in good faith belief that such disclosure is necessary to protect our rights, users, or the public.
  • International Data Transfers: Some of our service providers and technology partners may process data outside the European Economic Area (EEA). When this occurs, SceneSnap ensures that appropriate safeguards are in place in accordance with Chapter V of the GDPR. These safeguards include either an adequacy decision issued by the European Commission (e.g., under the EU–U.S. Data Privacy Framework) or the use of Standard Contractual Clauses (SCCs) combined with strict data processing agreements that guarantee a level of protection equivalent to that of the European Union.

We may share limited personal data with advertising and analytics partners (such as Google) to enable campaign measurement, remarketing, and audience creation. These partners may process data in accordance with their own privacy policies.

Legal Basis for Processing

We process personal data for advertising and marketing purposes only where we have a valid legal basis, typically your consent (e.g., via cookie preferences or marketing opt-ins).

Public VIOs and Visitor Analytics

When you enable publishing on a VIO, it becomes a public, read-only web page accessible at scenesnap.co/vio/[id]. The user who publishes the site is the controller of any content shown on that page. SceneSnap acts as hosting provider and as controller solely for the limited usage analytics described below.

  • What we collect from public site visitors: Visitor analytics on public VIOs are designed to be privacy-first and cookieless. For each page view we record an anonymous event that includes the timestamp, the page slug visited, a generic device category derived from the User-Agent (such as mobile, desktop, or tablet), and the referrer domain when supplied by the browser. We do not place cookies on the visitor's device. IP addresses and other connection metadata are processed only to the extent necessary to operate the page, to estimate the number of unique visitors using privacy-preserving techniques that do not allow reverse identification of an individual, and to prevent abuse; they are not retained beyond the period strictly necessary for these purposes.
  • What we do not collect: We do not use third-party advertising trackers, fingerprinting, persistent visitor identifiers, or cross-site tracking on public VIOs. We do not build visitor profiles.
  • Retention: Visitor analytics are retained for no longer than necessary to fulfil the purposes set out above, in accordance with the storage limitation principle under Article 5(1)(e) of the GDPR. Event records that cannot reasonably be associated with an identifiable visitor are kept while the VIO remains published and for a reasonable period thereafter for operational, security, statistical, and product-improvement purposes. Aggregated and statistical metrics, which by their nature do not relate to an identifiable person, may be retained for an extended period for historical, scientific, and statistical purposes within the meaning of Article 89(1) of the GDPR. SceneSnap periodically reviews its retention practices and deletes, anonymises, or further aggregates data once the original purposes no longer require its preservation. The dashboard offered to the publisher within the SceneSnap interface displays a rolling window of the most recent activity (for example, the last 30 days) for usability reasons; this user-facing display window does not constitute the maximum retention period of the underlying data.
  • Legal basis: Processing of cookieless, anonymous usage statistics relies on SceneSnap's legitimate interest (GDPR Art. 6(1)(f)) to measure the performance of the published page and to detect abuse. Because no cookies or similar identifiers are stored on the visitor's device, no prior consent is required under Article 122 of the Italian Code on Electronic Communications.
  • Publisher responsibilities: Users who publish a VIO are responsible for ensuring the content does not infringe third-party rights and that any personal data contained in the source material has a lawful basis for publication. SceneSnap may unpublish public pages following a valid takedown notice (see the Terms of Service).

Sub-Processors

We rely on a limited set of trusted vendors to operate the Services. Each sub-processor is bound by a data processing agreement that includes the safeguards required by Chapter V of the GDPR (such as Standard Contractual Clauses where applicable).

  • OpenAI, L.L.C. — generation of AI-assisted outputs from your inputs (United States; EU–U.S. Data Privacy Framework and/or SCCs).
  • Anthropic PBC — generation of AI-assisted outputs from your inputs (United States; EU–U.S. Data Privacy Framework and/or SCCs).
  • Google LLC (Google Cloud, Google Tag Manager, Google Ads where applicable) — infrastructure, tag management, and, only with your consent, marketing measurement (United States/EU; EU–U.S. Data Privacy Framework and/or SCCs).
  • Stripe Payments Europe, Ltd. — payment processing when applicable (Ireland; onward transfers to the United States under the EU–U.S. Data Privacy Framework and/or SCCs).

We do not use the content you upload, your prompts, or your generated VIOs to train foundation AI models. Our AI sub-processors are contractually instructed not to use SceneSnap API inputs and outputs to train their general-purpose models. We may use anonymized and aggregated metrics to improve our own product features.

4. Data Security

We implement industry-standard security measures, including encryption, secure hosting, access control, and regular audits to protect your information. While no system is entirely immune to breaches, we take all reasonable steps to ensure the confidentiality, integrity, and availability of your data.

5. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, including legal, accounting, or reporting requirements.

The retention period depends on the nature of the data and the context of collection, but in general:

  • Account and profile information are retained while your account remains active.
  • Transaction and payment records are kept for the minimum period required by tax and accounting laws.
  • Usage logs and analytics data are anonymized or deleted after a reasonable period.

6. Your Rights

Under the EU General Data Protection Regulation (GDPR) and other applicable laws, you have the right to:

  • Access the personal data we hold about you.
  • Rectify inaccurate or incomplete information.
  • Delete your personal data ("right to be forgotten"), subject to legal retention requirements.
  • Restrict or object to certain types of processing.
  • Withdraw consent at any time without affecting prior lawful processing.
  • Port your data to another service provider.

Requests can be sent to: support@scenesnap.co.

If you believe your data has been handled unlawfully, you have the right to file a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) or your local supervisory authority.

7. Children's Privacy

SceneSnap is not designed for or directed at children under 14 years of age (the minimum age under Italian implementation of GDPR Article 8, Article 2-quinquies of the Italian Privacy Code). We do not knowingly collect personal data from children under that age. Where required by local law, parental or guardian consent is necessary for minors above the threshold.

8. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, or legal obligations. We will post the revised version on our website and update the "Last updated" date above. Material changes will be communicated through email or in-app notification where required.

9. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at: support@scenesnap.co.