This TinySnap Privacy policy strives to protect user privacy and information when using our services.
BY USING THIS TINYSNAP WEBSITE https://mytinysnap.com/ (the "Website") OR ANY OTHER SYSTEM / ONLINE ECOSYSTEM USED BY RL GREENWAY LLC TO PROVIDE YOU SERVICES (collectively - the "System"), YOU AGREE TO THE PRIVACY POLICY, WHICH MAY GET UPDATED WITHOUT PRIOR NOTIFICATION.
1.1 RL Greenway LLC is a limited liability company formed under the laws of the State of Delaware, File No. 7583389, having its registered address at 8 The Green, Suite B, Dover, DE 19901, USA (the "Company" / "us" / "we").
1.2 Any person using Company's services / systems is considered to be a client of the Company (the "Client" / "You").
1.3 The Company and the Client are legally bound by the Terms of service (the "Agreement") which governs the contractual relationship between the Company as a service provider and the Client, any natural person, as a service user, or a user of System prior to / without logging-in / creating an account ("Account").
1.3.1 The Company provides a web-based platform that enables users—primarily parents and family members of newborns and infants (0–12 months)—to upload personal photos of their babies or young children and transform them into studio-quality, artistically enhanced portraits. The platform uses AI-powered image generation technology to create customized visual outputs. TinySnap combines artistic design models, photo enhancement algorithms, and predesigned creative themes (e.g., cozy, floral, dreamlike, seasonal, etc.) to produce high-quality, realistic baby portraits suitable for digital sharing, printing, or personal keepsakes (the "Services"). The Services can be accessed and used via the System as indicated in the Agreement. The types and features of the Services may vary and may depend on the Client choices available in the System.
1.3.2 The latest version of Agreement shall be available at Terms Of Services.
1.4 This Privacy Policy shall be applicable and interpreted in line with Agreement. The definitions set out in the Agreement shall be applicable to this Privacy Policy.
1.5 You can contact the Company filling a question box on the Website in the "Contact" section, as well as by sending us an email or inquiry to the mailing address at hello@mytinysnap.com For the matters regarding this Privacy Policy, as well as regarding any privacy matter, we recommend contacting the Company via email, by sending Your inquiry to hello@mytinysnap.com
1.6 The Company shall have the right to unilaterally modify and / or update the Privacy Policy at any time without notice. The continuous use of the Services / System by the Client shall be deemed as acceptance of Privacy Policy in the last and most updated version. Any Client shall periodically check and assess the Privacy Policy. Any updated version of this Agreement comes in force at the moment it is published at the System.
1.7 The latest version of the Privacy Policy shall be available at Privacy Policy page.
1.8 By agreeing to the Agreement as per the rules set forth in the Agreement, You are automatically agreeing to the Privacy Policy. For the avoidance of doubt, You acknowledge understanding that by using System in any way prior to creating an Account (Clause 2 of the Agreement) or without logging-in to the System (for example, when browsing the Website), You are also bound by this Privacy Policy and Your data / information may be collected by the Company automatically.
1.9 If You disagree to be bound by the Privacy Policy in any scope or way, You must not use or must immediately cease Your use of the Services, System or any part of it, as well as its features and functionalities.
1.10 The Company values the trust that You place in the Company when using Services / System. For this reason, privacy and data security are extremely important to the Company. It is very important to the Company that You feel safe when You visit our System and use our Services, as well as in all other business transactions with the Company. As soon as You use Company's System / Services, You entrust Company with the processing of Your personal data. The Company wants to offer You the best possible experience with the System to ensure that You can enjoy using Services now and in the future. That is why the Company wants to understand user behaviour on the System in order to continuously improve it. The processing of Your personal data is therefore not only necessary for the provision of Services, but also to improve user-friendliness. Therefore, in this Privacy Policy You are informed which personal data the Company collects from/about You, how the Company processes it and to whom the Company passes it on in detail. In addition, the Company informs you about the precautions it takes to protect Your personal data, what rights You have in this context and who You can contact regarding data protection issues.
1.11 In the light of the above, the Company strives to protect Your privacy and obliges to process Your personal data in accordance with the following rules and principles:
1.11.1 Processing shall be performed lawfully, fairly, and in a transparent manner.
1.11.2 Personal data must be adequate and limited to what is necessary in relation to the purpose for which it is processed.
1.11.3 Personal data shall be accurate and, where necessary, kept up to date.
1.12 This Privacy Policy is prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the "GDPR") and other relevant legal acts, as well as with the best practices and principles of data protection. You can find information on applicable legal acts here: https://commission.europa.eu/law/law-topic/data-protection_en (if applicable).
1.13 With regard to the terms used in this Privacy Policy, such as "Processing" or "Controller", we refer to the definitions of the GDPR.
1.14 Your contact information (phone number or email address) will not be shared with third parties/affiliates for marketing/promotional purposes.
2.1 This Privacy Policy applies to all persons who use the System / Services or otherwise interact with the Company (e.g. business partners, interested parties, service providers, etc.); generally, those persons who are hereinafter referred to as "Client" or "You".
2.2 Company's System and Services are not meant for anyone under the legal age. Only people of legal age are allowed to use System, Services and register for an Account. The Company therefore does not knowingly collect personal data from minors. So, if You are under 18 years of age / under legal age under the laws imperatively applicable to You, please do not use the System / Services and do not provide us with any personal data.
3.1 For the purposes of applicable data protection law, the Company is typically the "data controller" of any personal information provided to the Company. Very occasionally, the Company might act on specific retainers as a "processor" (by processing personal data only in accordance with the directions of a data controller, or as otherwise permitted by law).
3.2 Privacy Policy shall be applied to the processing of personal data by a data controller (the Company) located in the Republic of Cyprus processing the personal data of data subjects (You) residing or working within or outside the European Economic Area (the "EEA").
3.3 If You have any questions regarding the processing of Your personal data and the exercise of Your rights under the GDPR, You can contact our team: hello@mytinysnap.com
3.4 The Company might require additional identification data from You for certain inquiries (e.g. Passport, ID card, etc.) in order to ensure that Your personal data is only passed on to You.
3.5 The Company, as a data controller (or in some cases – data processor), has the following obligations:
3.5.1 Data transfers. The Company shall not transfer personal data to a country or territory outside the EEA unless that country ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
3.5.1.1 Where adequate level of protection is not ensured, an exemptions shall be made by a) creating adequate protection through appropriate safeguards (for example, by using Standard Contractual Clauses), or 2) by getting data subject's explicit consent and making sure the transfer does not conflict with the nature of Art. 46 of GDPR.
3.5.2 Data processing records. The Company shall keep data processing records upon its own decision, unless such record keeping is mandatory legal requirement.
3.5.3 Data protection. The company shall ensure proper data protection requirement implementation and optimization of procedures. The Company shall be equipped with the skills and know-how for safeguarding personal data.
You can contact Company's staff regarding data protection by sending an email to hello@mytinysnap.com
3.5.4 Data breach notification. The Company strives to protect Your personal data in the best way possible. However, sometimes data breaches occur, and such events can happen for various reasons.
3.5.4.1 In the case of a data breach that would prejudice the privacy, confidentiality and security of the personal data of a data subject, the Company, as a data controller, immediately upon becoming aware of such breach, shall notify the data regulator in the Republic of Cyprus (see Clause 7.1.9) of such data breach.
3.5.4.2 The required notification shall include details such as: the nature, category, reasons, approximate number and records of the data breach, a description of the likely consequences of the data breach; and a description of the measures and remedial action taken by the controller to address the data breach.
3.5.5 Data retention. The Company shall not store personal data after the completion of the purpose for which such data was processed unless the identity of the data subject is no longer identifiable through the use of anonymization techniques. We retain your personal data only for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. Account details (such as your name, email, and profile information) are kept while your account is active and deleted or anonymized within 30 days of closure or inactivity. Body measurements and style data (such as body shape, weight, height, and eye color) are stored only while your account is active and deleted or anonymized within 30 days of account closure or inactivity. Transactional data (such as invoices and payment records) may be retained for up to 7 years in compliance with Cyprus tax and accounting laws, and technical or log data (such as device identifiers and usage logs) may be retained for up to 12 months for security and troubleshooting purposes. We may also keep anonymized and aggregated data, which cannot be linked back to you, for analytics and service improvement without time limitation. Where no fixed retention period applies, we determine the appropriate period based on the type of data, the purpose of processing, and our legal obligations. You may request deletion of your personal data at any time, subject to legal requirements, by contacting us at hello@mytinysnap.com
3.5.6 Sensitive personal data protection. In general, the Company does not process any special categories of personal data from Clients. This includes data that reveal racial or ethnic origin, political opinions, religious or ideological convictions or trade union membership, as well as genetic and biometric data. In some cases, during provision of Services, some personal data can be provided by the Clients and recorded by the Company. Processing of such personal data takes place exclusively based on Your own choice and expressed consent, which You can revoke at any time. The Company explicitly urges You not to provide any sensitive information since it is not required by the Company to provide Services.
3.5.7 Proper agreements between controller and processor. The processor shall perform and implement the processing of personal data based on the instructions of the controller and in accordance with the contracts and agreements entered into between them, which shall specifically set out the scope, subject-matter, purpose and nature of the processing, the type of personal data, and categories of data subjects. The Company, either acting as a controller or the processor, shall make sure beforehand that such agreements are concluded and are proper for planned data processing.
4.1 The Company may collect personal information from You in the course of provision of the Services, when You use the System, contact us or request information from us, or as a result of Your relationship with any of our personnel or clients.
4.2 The personal information that we might process includes:
4.2.1 Contact data. When creating a new user Account or communicating with the Company (for example, by contacting our support team), we may process basic details, such as Your name, Your contact information (such as Your email address, physical address, contact numbers).
4.2.2 Order data. In the context of ordering Services, we might process information relating to the matter on which You are seeking our Services.
4.2.3 Financial data. In the context of ordering Services and accepting payments, as well as making refunds we might process, for example: bank details (IBAN, BIC), information about the payment service provider, payment details, transaction-ID, etc.
4.2.4 Log data. During activities on the System and while using Services, we might process, for example: IP-address, traffic data, transaction data (like deposit, payment, refund withdrawal address), computer or mobile device information, frequency, time, length of visit and other page interaction data, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc.
At all times when using System / Services, we collect and process the following log data:
4.2.4.1 IP address of first or the last login.
4.2.4.2 Account credentials and other information as per Clause 2 of the Agreement, including date and time of Account creation, as well as log-in date and time.
4.2.4.3 Information collected by cookies and Google Analytics (see Clause 6.6), for example: access time and dates, unique device identification number, other. The mentioned data in this Clause might be collected without assigning it to the specific user.
4.2.5 Marketing data. If You visit System or our social media sites, we might process statistical and marketing data, for example: number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies (pixels, ClearGIFs, etc.), consumer's behavior, interests and preferences, data on market research and target group surveys, etc.
4.2.6 Photo, video and audio data. When we attend or organize events or fairs or conduct interviews with people, or You visit our offices or our meetings and events, or You conduct video / phone conversations or other communication with our team, we may take photos and other recordings of such events / communication and process photo, video and audio data, as well as data on time, location, participant list, etc. However, we will always inform You separately about any such recordings by photographic or video images and / or audio recordings.
4.2.7 Hiring data. If You apply for a job on our System, social media (for example, via LinkedIn), we may process data that is necessary for the recruitment process, for example: contact details, curriculum vitae, qualifications, police clearance certificate, credit report, national identity documents such as passport, driver's license and the data from all of these documents, links to Your portfolio or social media platforms, etc.
5.1 All processing is carried out in accordance with the GDPR. We process Your personal data based on at least one of the legal bases mentioned below. If the Company requests the provision of other personal data not described above, this data as well as the purpose and legal basis for the collection and processing will be communicated to the Client at the point of collecting the personal data.
5.1.1 Performance of the contractual obligations under the Agreement. A controller (the Company) / processor may process personal data without the consent of the data subject (You) to which the data relates where processing is necessary for the performance of a contract (the Agreement) to which the data subject is party or in order to take steps at the request of the data subject for entering into, amending or terminating an Agreement.
5.1.2 Consent. We may ask You to provide Your consent if the data subject's (Yours) consent is relied upon as a lawful basis for the processing of Your personal data. For example, we may ask You to express consent prior to using the System before the Agreement is concluded or when You are using the System without logging-in, as well as before collecting / processing any other personal data not described in this Privacy Policy.
If You have given us Your consent to the processing of Your personal data, the processing will only occur for the defined purposes and to the extent agreed in the declaration of consent.
A given consent can be revoked at any time without giving reasons with effect for the future if You no longer agree to the processing.
With Your consent, we process data for the following purposes, for example: Direct marketing and advertising (e.g., customer satisfaction surveys, newsletters, sweepstakes, and other advertising communications). Website analysis and tracking for advertising purposes (see also our cookie policy at Clause 6.6). Certain uses of audio, video and photo data (e.g., commercials, interviews, etc.) for marketing and other representing purposes through various channels, as well as for the provision of Services. Application management system, recruitment process and processing of Your application. Revoking Your consent does not affect the legality of the processing carried out based on Your consent up to the point of withdrawal.
5.1.3 Compliance with legal obligations. Processing of personal data may also be necessary to abide by various legal obligations. Such legal obligations include, for example, the following data processing operations: contract management, accounting, and invoicing, monitoring to prevent fraud, misuse, money laundering and terrorist financing, providing information to criminal authorities in context of fiscal criminal proceedings or prosecution to official orders, assessing the working capacity of the employee or the provision of health / social care, etc.
5.1.4 Protection of legitimate interests. Where necessary, data processing can occur beyond the performance of the contract to ensure the legitimate interests of the Company or a third party. Such a legitimate interest includes the following data processing operations:
5.2 The Company may also process personal data without the consent of the data subject to which the data relates where the data has been made public by the data subject (Article 9 of the GDPR).
6.1 The Company maintains social media presences on various platforms (see below) in order to communicate with its active customers, potential customers and interested social media users about Company's services, products and other news. When accessing such social media platforms, the general terms and conditions and the privacy policies of these operators also apply. We would like to point out that user data can also be processed outside of EEA or the region / location You are in. This can result in risks for users due to different legal frameworks (e.g. the enforcement of data subject rights could be made more difficult).
6.2 As part of the technical process of various social media platforms (e.g. Google, Facebook, X etc.), when You click on a content or a website You are visiting, they find out whether You are logged into Your social media account at the same time. This information is collected by social media platforms and assigned to Your social media accounts, regardless of whether You click on the content of this platform or not. By logging out of Your accounts, You can prevent these companies from associating the collected information with Your accounts.
6.3 The activities of these companies are not controlled by the Company and therefore we do not accept any liability for any damage You may suffer because of the use of Your data by these companies.
6.4 The Company may only process personal data from social media users if they communicate directly with the Company via such platforms (e.g. visitors number, posted articles, likes, direct messages, customer inquiries, comments, etc.). In these cases, the Company is also responsible for processing the personal data collected thereby. In addition to data processing by us, other providers, in particular operators of social networks and platforms, also process personal user data. We have no influence on this data processing and are not responsible for it – the data processing takes place exclusively in the area of responsibility of the other providers.
6.5 For a detailed explanation of the respective processing and the possibilities of objection (opt-out) by providers of social media networks, we refer to the respective privacy policies of the providers (see below). In the case of requests for information and the assertion of data subject rights to data processing by other providers, we point out that these can be asserted with the providers listed below. Only the providers have access to the data of the users and can directly take appropriate measures and provide information.
6.6 The Company uses the following social media accounts in order to engage with You and other third parties:
6.6.1 Facebook account – accessible using this link: https://www.facebook.com/TinySnap.Official
We use Page Insights function to process statistic data from users on Facebook (https://www.facebook.com/legal/terms/page_controller_addendum).
More information about data collected by Facebook and Your preferences is available here: https://www.facebook.com/privacy/center/
6.7 The above indicated list is non-finite and the Company is entitled to change / add social media accounts. The latest and up-to-date list of Company's social media accounts shall be available at the System's section "Social". The list of third-party social media networks' privacy policies (Clause 6.6.) is provided for Your convenience only – as they are created, amended and published by third parties, You must always check whether they are up-to-date and valid versions. The Company takes no responsibility and does not guarantee that the versions indicated in the Clause 6.6. are valid or up-to-date.
6.8 You should always make sure that the social media account is Company's before submitting or revealing any personal information of Yours while engaging in any social media communication (for example, exchanging messages or leaving a comment).
6.9 You should be aware that SMS / messaging and email services are susceptible to spoofing and phishing attacks and should be careful when reviewing messages that claim to be from the Company. You should always use communication tools in the System or contact us via email by sending an inquiry to the address hello@mytinysnap.com if You are unsure about the authenticity of a communication or notice. Note that phishing attacks often occur despite SMS or email or equivalent services, via search engines or advertisements in search engines or other fraudulent links. The Company takes no responsibility for any loss due to spoofing, phishing, or other equivalent attacks.
7.1 You shall be entitled to the following rights:
7.1.1 Right to withdraw Your consent and right to opt-out. In all cases You are entitled to object to and suspend to the processing of Your personal data where the processing is performed based on your consent, for example - for direct marketing purposes, and when the processing is performed for statistical survey purposes.
7.1.1.1 You have the right to revoke Your consent any time within the methods described in this Privacy Policy or by email to hello@mytinysnap.com. Please note that if You withdraw Your consent, we may no longer be able to offer You all of our Services. Withdrawing Your consent does not affect the legality of the processing carried out based on Your consent up to the point of withdrawal.
7.1.1.1.1 By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account, You expressly confirm that You have read the Agreement together with Privacy Policy and that You agree to the data processing described therein.
7.1.1.1.2 By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account, You expressly confirm that You have read other policies as indicated in such notice.
7.1.1.1.3 By checking the respective box during the registration process (creating an Account) or when updating after logging into Your Account for news and updates by email (including newsletter and other marketing material), You expressly consent to receiving electronic communication.
7.1.1.1.4 By checking the respective box (boxes) during the use of System for use of cookies, You expressly consent to usage of cookies as indicated in this Policy, the notice and as per Your preferences expressed by checking all / any boxes.
7.1.2 Right prior to the start of processing activities, to get information on the purpose of the processing, sectors or entities inside or outside the EEA with whom Your personal data will be shared, the appropriate safeguards used by the Company in the context of cross-border processing.
7.1.3 Right to obtain additional information upon request, including:
7.1.3.1 Confirmation whether we are processing personal data related to You.
7.1.3.2 The types of personal data of the data subject being processed.
7.1.3.3 The decisions taken on the basis of automated processing.
7.1.3.4 The rules and criteria of the periods for which the personal data will be stored and kept.
7.1.3.5 The measures to be taken upon the occurrence of a data breach.
7.1.4 Right to rectification. You are entitled to obtain the rectification of inaccurate personal data concerning You, and to have incomplete personal data completed.
7.1.5 Right to erasure. You are entitled to request the Company to delete Your personal information if:
7.1.5.1 The personal data is no longer necessary in relation to the purposes for which it was collected or processed.
7.1.5.2 You withdraw Your consent or expressed objection to processing and there are no legitimate grounds for the Company to continue the processing.
7.1.5.3 The personal data have been illegally processed.
7.1.5.4 The deletion of personal data is necessary to fulfill a legal obligation under law to which the Company is a subject.
7.1.6 Right to receive a copy and have Your personal data transmitted to another controller, if technically feasible. You shall have the right to receive the personal data concerning You that You have provided to us in a structured, commonly used and machine-readable format where the processing is based on Your consent or is necessary to fulfil a contractual obligation and implemented by automated means. You also shall have the right to have this data transmitted directly to another controller named by You, insofar as this is technically feasible and the rights and freedoms of others are not impaired. The right to data portability can only be exercised if the processing is based either on Your consent or on a (pre)contractual necessity and where the processing is automated. The right to data portability does not apply to processing which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7.1.7 Right to object to decisions based on automated processing. The Company usually does not use any personal data for automated decision-making including profiling (e.g. decisions that have legal effects on data subjects, or significantly affecting them in any other way that are based solely on automated processing of personal data including profiling). In case we would make such decision in any scope, You shall be entitled to object.
Additionally, You have the right to object to the processing of Your personal data at any time if the processing is based on Your legitimate interests. If You object to the processing, we will no longer process Your personal data unless we can demonstrate compelling legitimate grounds for the processing that outweigh Your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. The objection does not affect the legality of the processing of Your personal data based on legitimate interests until You withdraw Your consent.
7.1.8 Right to restriction of processing. You shall have the right to request that we restrict processing if one of the following conditions is met:
7.1.8.1 You dispute the accuracy of the personal data (the restriction applies for a period of time that enables the Company to verify the accuracy of the personal data).
7.1.8.2 The processing of Your personal data was unlawful, and You refuse to delete Your personal data and instead request that its use is to be restricted.
7.1.8.3 The Company no longer needs your personal data for processing purposes, but You need them to assert, exercise or defend legal claims.
7.1.8.4 You have objected to the processing of Your personal data, and it has not yet been determined whether the Company's legitimate grounds outweigh Your own.
7.1.9 You can exercise Your rights and lodge a complaint with your respective state Attorney General's office or You may contact the Federal Trade Commission (FTC) at www.reportfraud.ftc.gov.
7.1.10 Right to contact. To exercise any of the above rights, You can send an email to hello@mytinysnap.com or a letter to RL Greenway LLC, 8 The Green, Suite B, Dover, DE 19901, USA. We shall respond to Your inquiry within 30 days from the day of receiving it (with the possibility of two 30-day extensions).
7.2 In all cases we encourage You to contact us directly. We at the Company believe that best decisions can be made by mutual agreement and effort.
7.3 As a general principle of the Company, we process personal data only for the purposes for which they were collected. In exceptional cases, however, we may process Your personal data that we have collected for another purpose. In this case, before the intended processing, we will inform You of this purpose, the duration of the storage of Your personal data, the exercise of data subject rights, the possibility of revoking consent, the existence of a right to complain to the data protection authority, whether the provision of the data was necessary on legal or contractual grounds and possible consequences of non-provision and whether automated decision-making or profiling is carried out.
Last updated: January 14, 2026