Information

URL Name	gdpr

Title	Snap Ads and European Laws FAQs

Article Details

Article

Snap Ads and European Laws FAQs

This section provides additional information on EU laws that are relevant to Snapchat Ads.

Advertiser data relating to EEA and UK data subjects

How does Snap protect the personal data of advertisers’ EEA/UK customers?
When you provide personal data that relates to your UK/EEA customers, Snap processes this data as a data processor, distinct from Snap’s own user data. When we process personal data on your behalf, we do so in accordance with your instructions and to provide the advertising services you requested. For example, we may use the data you provide to Snap to create a custom audience for you (Snap Customer List Audiences), and the data you provide to us may be hashed (SHA-256) prior to sharing with Snap. If you use the Snap Pixel / Conversion API, we enable you to target visitors of your websites and apps on Snapchat. See Customer Audiences and the FAQs in the Install Pixel Section of our Business Help Center for more information.

Data Processing Agreement

Do advertisers need Snap to sign their own data processing agreement to comply with GDPR and UK data protection laws?
Snap makes a standard Data Processing Agreement available as part of its click-through advertiser business terms. Snap's Data Processing Agreement reflects the specific functionalities of Snap’s advertising services and is compliant with GDPR and UK data protection laws. Whenever there are changes in applicable data protection laws, we update our data processing agreement and our advertiser-facing terms so that we can assist our advertisers with their own compliance obligations.

How does Snap ensure its subprocessors handling advertiser data are compliant?
Snap requires third parties that process advertisers’ customer personal data on our behalf (“subprocessors”) to sign data processing agreements that comply with the GDPR and require the same level of privacy and security that applies to Snap under Snap's Data Processing Agreement.

What about subprocessors handling advertiser data that are located outside the EEA/UK and Swiss?
Snap only transfers European individuals’ personal data provided by advertisers outside of the European Union, the UK and Switzerland using one of the European Commission-approved transfer mechanisms. Snap Inc. has certified that it complies with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks, and the UK Extension to the EU-U.S. DPF (the “DPF”).

If Snap uses a subprocessor that is not located in a country deemed “adequate” by the European Commission, Switzerland and the ICO, Snap uses Standard Contractual Clauses (SCCs) as its lawful transfer mechanism. If you have signed an NDA with Snap, you can access more information on transfers in Snap’s Whistic profile here. If you are unable to access our profile, you can reach out to our team via this form.

How does Snap support notifying authorities of breaches of personal data?
Snap has in place a robust data breach incident response plan and we are prepared to meet the breach notification requirements under the GDPR and UK data protection laws. Our breach investigation procedures are designed to facilitate an efficient and comprehensive investigation and make the proper notifications.

Will Snap assist with audits?
Yes. The GDPR and UK data protection laws require data processors to grant audit rights to data controllers; these rights are detailed in Snap's Data Processing Agreement.

Will Snap respect my request to delete or return personal data?
Yes. As detailed in Snap's Data Processing Agreement, Snap will delete or return personal data at your request. In some cases, Snap may store anonymized and aggregated personal data to improve its services.

Transfers

Are advertisers transferring customer personal data to Snap entities outside the EEA or UK?
If you are an advertiser in Europe, you do not transfer personal data relating to your customers directly to Snap entities outside of the EEA or the UK. As a European or UK advertiser, you provide such personal data to Snap’s European and UK entities, such as Snap Camera GmBH, Snap Europe SAS and Snap Group Limited (SGL) under Snap’s Business Services Terms and Data Processing Agreement. In the case of SGL, the United Kingdom has received an adequacy decision from the European Commission.

Do advertisers need Snap to sign their own data transfer agreement?
No. We already make available three approaches for advertisers to confirm they are in compliance with European data transfer obligations:

Snap Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. Data Privacy Framework (UK Extension to the EU-U.S. DPF), and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) EU Data Protection Frame. Snap Inc.’s DPF certification that can be viewed on the DPF list.
We have also incorporated the latest EU SCCs and UK IDTA terms (with you as data exporter and Snap Inc as data importer) into the Snap Business Services Terms. These data transfer terms can be found here: Data Transfer Agreement and may apply to in-scope transfers not covered by our DPF certification or another adequacy decision.
If you are an advertiser in Europe you will contract directly with our Snap entities in the European Union and if you’re a UK advertiser you contract with Snap Group Limited, Snap’s UK entity. This structure means that you don’t transfer data directly to Snap entities outside of the EEA or the UK. The EU and UK entities may transfer data to non-EU/UK Snap entities who perform subprocessor activities. Our inter-company agreement also incorporates current EU Standard Contractual Clauses (SCCs) and UK International Data Transfer Agreement (IDTA) terms.

Where can advertisers find information to conduct a transfer impact assessment ?
If you have signed a NDA, you can find necessary information to carry out transfer impact assessments in Snaps’ Whistic profile here. If you are unable to access our profile, you can reach out to our team via this form.

Children

Does Snap allow advertisers to upload personal data of EEA/UK children for ad targeting?
No. While Snapchat is directed to individuals who are 13+, Snap Ads does not match customer personal data uploaded by advertisers via our Pixel/Conversion API or Customer List Audiences to teenage accounts (i.e., between 13-17 years old) in the UK and the EEA for personalized advertising.

Does Snap target advertising to target EEA/UK minors?
Snap does not serve ads to teenage accounts in the UK, Switzerland, Norway and EU (“EU+ and UK”) that are personalised (e.g. targeted) based on aspects like certain historic content profiles or inferred interests. They will still receive advertising based on certain contextual information and information for safeguarding or legal requirements, such as age, language, location, device information and current content/ad. These changes are all a part of our continued commitment to European privacy, security and safety laws, including the European Digital Services Act.

What are the unavailable targeting and delivery options for EEA/UK minors?
The following targeting options are not available for ad sets reaching Snapchatters aged 13-17 in EU+, UK and Switzerland:

Gender
Pre-defined audiences
Custom audiences
DPA (Dynamic Product Ads)
Install state targeting

Advanced demographic targeting also continues to be unavailable in EU+, UK and Switzerland.

The following optimization goals are not available for ad sets reaching Snapchatters aged 13-17 in EU+, UK and Switzerland:

Click
App Install
Video Views (2 or 15 second)
Use / Share (Lens)
Story Open
Pixel Sign Up / Purchase / Add to Cart / Page View
App Sign Up / Add to Cart / Purchase / Re-engagement (purchase and open)
Lead Form Submission

What are the available targeting and optimization options for EEA/UK minors?
Certain targeting options are available for ad sets reaching Snapchatters aged 13-17 in EU+, UK and Switzerland advertising for safeguarding or legal requirements or to provide non-profile based context:

Placement
Age
Language
Location
Device information (including operating system, carrier, and phone model)

Optimization goals and delivery options that do not rely on user profiles are also available for ad sets reaching Snapchatters aged 13-17 in EU+, UK and Switzerland:

Impressions
Reserved Campaigns (Takeovers, Reach & Frequency, Snap Select)

This means that:

Ad sets that exclusively target users under the age of 18 in EU+, UK and Switzerland will not run, unless the ad sets are updated with the available targeting options (i.e. targeting by placement, age, language, location, and device information + non-profile based optimization/delivery goals).
Ad sets that target users in EU+, UK and Switzerland both under the age of 18 and adults aged 18+ will continue to run, but will not be delivered to people under 18. Instead, the ad set will automatically adjust to target a minimum age of 18, unless the ad set is updated to continue reaching users under the age of 18 using the allowed targeting options (i.e. targeting by placement, age, language, location, and device information + non-profile based optimization/delivery goals).

Digital Services Act

How will the Digital Services Act impact advertising transparency on Snap?
Snap maintains a Political and Advocacy Ads Library and an Ads Gallery, which provides an overview of ads that have run on Snap in the EU over the past year and some details about the targeting and reach of those ads, such as whether the information is an ad, on whose behalf advertising is presented and (if this differs) the person or organization who paid for the ad, and the content of ads.

How will the Digital Services Act impact targeted advertising on Snap?

Adults who opt out: Snap already allowed Snapchatters to opt-out of the use of Event Data and Customer List Data (explained earlier in this FAQ) for targeted advertising on Snapchat. With the introduction of the DSA, EU Snapchatters are also able to opt-out of profiling-based advertising. If they do, in addition to disabling targeted ad use of Event Data and Customer List Data, ads will also not be personalized (e.g. targeted) based on aspects like certain historic content profiles or inferred interests. They will still receive advertising that is personalized based on certain contextual information and information for safeguarding or legal requirements, such as age, language, location, device information and current content/ad.
Teens: See Children section above.
Special Category Data: The Digital Services Act also prohibits online platforms from displaying advertising to users (including non-minors) based on profiling using special categories of personal data. Snap has never allowed targeting based on special categories of data so this will not result in any changes to Snapchat Ads.