Privacy Policy - Slooshai

1. Introduction

slooshai ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application ("App").

By using the App, you agree to the collection and use of information in accordance with this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use the App.

2. Information We Collect

2.1 Information You Provide Directly

Payment Information:

Payment information (processed by Apple or Google, not stored by us)

User-Generated Content:

Audio recordings you create
Tags, notes, and metadata you add to recordings
Location data you choose to attach to recordings

2.2 Automatically Collected Information

Device Information:

Device type and model
Operating system version
App version
Device identifiers (for crash reporting and analytics)

Usage Data:

Features used
App performance metrics
Crash reports and error logs
Time and date of app usage

Location Data:

Precise location (GPS) when you choose to pin a recording location
Location data is ONLY collected when you explicitly enable location for a recording
You can disable location access at any time through device settings

Biometric Data:

Device biometric authentication (Face ID, Touch ID) used for app security and account protection
Biometric data is processed exclusively on your device and never transmitted to our servers
No biometric templates, identifiers, or records are stored or processed by slooshai

2.3 Information We Do NOT Collect

We do NOT collect:

The content of your audio recordings (recordings stay on your device)
Your contacts, photos, or other personal files
Your browsing history outside the App
Voice biometric data (voiceprints, voice identification, speaker recognition)
Your exact identity without your explicit consent

Note on Biometric Data: The App uses your device's biometric authentication (Face ID, Touch ID) for app security. This biometric data is processed exclusively by your device and never transmitted to our servers. See section 2.2 for biometric authentication details.

3. How We Use Your Information

3.0 Legal Basis for Data Processing

For California Residents (CCPA/CPRA):

We process your personal information for the following business purposes:

Providing and maintaining the App's functionality
Processing payments and managing subscriptions
Improving features and user experience
Analyzing app usage and performance
Complying with legal obligations
Preventing fraud and ensuring security

You have the right to request we stop collecting or using your information for any purpose where collection is not necessary to provide the services you requested.

For Future EU Expansion (GDPR):

Once available in the EEA, we will process personal data based on the following legal grounds under GDPR Article 6:

Contract Performance (Article 6(1)(b)): Processing is necessary to provide the App's services you have requested, including audio recording, storage, and AI features
Consent (Article 6(1)(a)): When you opt-in to optional features such as:
- Location tagging for recordings
- Marketing or promotional communications
- Cloud sync features (if enabled)
Legitimate Interest (Article 6(1)(f)): Processing is necessary for our legitimate interests in:
- Improving the App's features and user experience
- Preventing fraud and ensuring security
- Analyzing usage patterns (anonymized data)
- Providing customer support
Legal Obligation (Article 6(1)(c)): Processing is necessary to comply with laws and regulations

You will have the right to withdraw consent at any time for processing based on consent. Withdrawal does not affect the lawfulness of processing before withdrawal.

3.1 Core Functionality

Provide and maintain the App's features
Process and store your recordings locally on your device
Perform on-device AI analysis (transcription, tagging)
Enable location tagging for recordings (with your consent)

3.2 Subscription Management

Process subscription payments through Apple or Google
Manage your subscription status and access to premium features
Send transactional emails (receipts, subscription updates)

3.3 Improvement and Analytics

Analyze app usage to improve features and user experience
Debug and fix technical issues
Monitor app performance and stability
Develop new features based on usage patterns

3.4 Communication

Respond to your support requests
Send important updates about the App or these policies
Notify you about new features (if you opt-in)

3.5 Legal Compliance

Comply with legal obligations
Enforce our Terms of Service
Protect against fraud or malicious activity

4. Data Storage and Security

4.1 Local Storage

All audio recordings are stored LOCALLY on your device
Recordings are NOT uploaded to our servers
You have full control over your recordings and can delete them at any time

4.2 Security Measures

We implement appropriate technical and organizational measures to protect your data:

Data encryption in transit (TLS/SSL)
Data encryption at rest (on-device storage)
Regular security audits
Access controls and authentication
Secure coding practices

4.3 Data Retention

Local recordings: Retained until you delete them
Account data: Retained while your account is active
Analytics data: Retained for up to 24 months
Deleted data: Permanently removed within 30 days of deletion request

5. Data Sharing and Disclosure

5.1 We Do NOT Sell Your Data

We do NOT sell, rent, or trade your personal information or audio recordings to third parties.

What We DO Sell (Trained AI Models):

We may sell or license trained AI/ML models (mathematical weights and parameters) to third parties for research and commercial purposes
These models are derived from aggregated, anonymized training data and contain NO identifiable personal information or audio recordings
Trained models are purely mathematical representations and cannot be reverse-engineered to recover individual recordings or personal data
Model sales are a separate business activity and do not involve access to user content

Your Recordings: We do NOT share, sell, or provide access to your audio recordings. All recordings remain on your device under your control.

5.2 Third-Party Service Providers

We share limited data with trusted third-party services that help us operate the App:

RevenueCat (Subscription Management):

Purpose: Process subscriptions and manage payments
Data shared: User ID, subscription status, device type
Privacy Policy: https://www.revenuecat.com/privacy

Apple App Store / Google Play:

Purpose: Process payments and manage subscriptions
Data shared: Payment information, purchase history
Privacy Policies:
- Apple: https://www.apple.com/legal/privacy/
- Google: https://policies.google.com/privacy

Analytics Services (if applicable):

Purpose: Understand app usage and improve features
Data shared: Anonymous usage data, device type, app version
Data is anonymized (stripped of all identifiers and cannot be linked back to you) or pseudonymized (de-identified with technical identifiers removed)

Crash Reporting Services (if applicable):

Purpose: Identify and fix bugs
Data shared: Device model, OS version, crash logs
No personal recordings or content is shared

5.3 Legal Requirements

We may disclose your information if required by law or in response to:

Valid legal process (subpoena, court order)
Requests from law enforcement or government agencies
Protection of our rights, property, or safety
Prevention of fraud or illegal activity

5.4 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information is transferred and becomes subject to a different privacy policy.

6. Your Rights and Choices

6.1 Access and Control

You have the right to:

Access your data through the App
Update your account information and settings
Delete your recordings and account data
Export your data (if cloud sync is enabled)

6.2 Location Data

You can enable or disable location access at any time through device settings
Location data is only collected when you explicitly attach location to a recording
Past location data can be removed by editing or deleting recordings

6.3 Marketing Communications

You can opt-out of promotional emails by clicking "unsubscribe"
Transactional emails (receipts, security alerts) cannot be disabled

6.4 Analytics and Tracking

You can limit analytics data collection through your device settings
iOS: Settings > Privacy > Analytics & Improvements
Android: Settings > Google > Ads > Opt out of Ads Personalization

6.5 Account Deletion

To delete your account:

Go to App Settings > Account
Select "Delete Account"
Confirm deletion

Upon deletion:

Your account data is permanently deleted within 30 days
Local recordings remain on your device until you delete the App
Cloud data (if any) is permanently deleted

7. Children's Privacy

7.1 Age Restrictions

The App is NOT intended for children under 13 years of age (or under 16 in the EU).

We do not knowingly collect personal information from children under 13/16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

7.2 Parental Controls

If we discover that a child under 13/16 has provided personal information, we will:

Delete the information immediately
Terminate the account
Notify the parent or guardian (if contact information is available)

8. International Data Transfers

8.1 Data Location

Your data may be processed and stored in countries other than your own. These countries may have different data protection laws.

Geographic Availability:

The App may initially be available only in select jurisdictions. We will expand availability based on:

Compliance with local privacy and data protection laws
Infrastructure and support capabilities
Market demand and business considerations

8.2 Safeguards

When we transfer data internationally, we use appropriate safeguards such as:

Standard Contractual Clauses (SCCs)
Data Processing Agreements
Encryption and security measures

8.3 Jurisdictional Restrictions

We reserve the right to restrict App availability or features based on your location to ensure legal compliance.

9. Your Regional Privacy Rights

9.1 California - CCPA/CPRA

Current Primary Jurisdiction: slooshai is currently launching in California and fully complies with California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

If you are a California resident, you have the following rights:

Right to Know: Request what personal information we collect, the categories of sources, the business purpose, and the categories of third parties we share it with
Right to Delete: Request deletion of your personal information that we have collected from you
Right to Correct: Request correction of inaccurate personal information we maintain about you
Right to Opt-Out: Opt-out of the sale of personal information (we do NOT sell your personal information)
Right to Limit Use of Sensitive Information: You can limit our use of precise geolocation data by disabling location services in device settings
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights (you will receive the same service and pricing)

How to Submit Requests:

Your name
The specific right you're exercising
Any relevant details

Response Timeline: We will respond to your request within 45 days of receipt. If we need more information, we will let you know.

Authorized Agents: You may designate an authorized agent to make requests on your behalf. Your authorized agent must provide:

Written authorization from you
Proof of their authority (power of attorney, written permission)
Verification of your identity (government-issued ID)

California "Shine the Light" Law:

California residents may request information about sharing of personal information with third parties for their direct marketing purposes. We do NOT share your data for third-party direct marketing.

9.2 European Economic Area (EEA) - GDPR

Future Expansion: While slooshai is currently available only in California, we are committed to GDPR compliance for future expansion into the European Economic Area.

If you are in the EEA, you have the following rights under GDPR:

Right to Access: Request a copy of your personal data
Right to Rectification: Correct inaccurate data
Right to Erasure: Request deletion of your data ("right to be forgotten")
Right to Restrict Processing: Limit how we use your data
Right to Data Portability: Receive your data in a machine-readable format
Right to Object: Object to processing of your data
Right to Withdraw Consent: Withdraw consent at any time

GDPR Compliance: Our Privacy Policy includes comprehensive GDPR compliance measures including:

Transparent disclosure of data processing (Article 13/14)
Legal basis for processing (Article 6)
Data minimization and storage limitation (Article 5)
Data protection impact assessments for high-risk processing
Data breach notification within 72 hours (Article 33)
Standard Contractual Clauses for international data transfers (Article 44-49)

To exercise GDPR rights once the App becomes available in the EEA, contact us at info@slooshai.app.

9.3 Other Regions

Depending on your location, you may have additional privacy rights under local laws. Contact us at info@slooshai.app to understand your rights and exercise them.

10. Third-Party Links and Services

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. Please review their privacy policies before providing any information.

11. AI and Machine Learning

11.1 On-Device Processing

AI features (transcription, audio tagging) run locally on your device
Your audio is NOT sent to external servers for AI processing
AI models are downloaded to your device and run offline

11.2 Model Updates

We may update AI models periodically to improve accuracy
Model updates are distributed through the App and installed on your device
You can disable automatic model updates in settings

11.3 AI Training and Model Development

Current State:

We do NOT automatically use your recordings to train AI models
AI models are pre-trained and do not learn from your data without consent
All on-device AI runs locally and does not send data to our servers

Optional Training Contribution (Future Feature):

If implemented, users may opt-in to contribute anonymized data for model training
Participation will be completely voluntary with explicit consent
You can opt-in or opt-out at any time through App settings
Contributing users may receive compensation or premium features
All contributed data will be anonymized and aggregated before use

Model Sales:

Trained models may be sold or licensed to third parties (researchers, businesses, developers)
Models contain only mathematical weights/parameters, not user data or recordings
Revenue from model sales supports app development and operations

11.4 Automated Decision-Making (GDPR Article 22)

The App does not make automated decisions that significantly affect you
All AI-generated tags and transcriptions are suggestions only
You have full control to review, edit, or delete any AI-generated content
No automated decisions are made regarding subscriptions, access, or account status

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes:

We will update the "Last Updated" date
For material changes, we will notify you through the App or by email
Continued use of the App after changes constitutes acceptance

We encourage you to review this Privacy Policy periodically.

13. Data Breach Notification

In the event of a data breach that affects your personal information:

We will notify you within 72 hours of discovering the breach
We will explain what data was affected and what steps we are taking
We will provide guidance on how to protect yourself

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, please contact us:

Email: info@slooshai.app
Website: www.slooshai.app

For Privacy Rights Requests:

15. App Store Specific Information

15.1 Apple App Store

For iOS users, data collection and usage also comply with Apple's App Store Guidelines and App Tracking Transparency framework.

App Tracking Transparency:

We will request permission before tracking your data across apps or websites
You can change tracking preferences in Settings > Privacy > Tracking

15.2 Google Play Store

For Android users, data collection and usage also comply with Google Play's Data Safety requirements.

Google Play Data Safety:

Our Data Safety declaration accurately reflects this Privacy Policy
You can review our Data Safety information on the Google Play Store listing

Summary (Privacy Nutrition Label)

Data We Collect:

✅ Account email (optional, for subscriptions)
✅ Device information (type, OS version)
✅ Usage analytics (anonymous)
✅ Location data (only when you add it to recordings)
✅ Crash logs (anonymous)

Data We DON'T Collect:

❌ Audio recording content (stays on your device)
❌ Contacts or photos
❌ Browsing history
❌ Biometric data
❌ Data from other apps

How We Use Data:

✅ Provide app features
✅ Process subscriptions
✅ Fix bugs and improve performance
✅ Comply with legal requirements

Data Sharing:

❌ We do NOT sell your recordings or personal information
✅ We may sell trained AI models (mathematical weights only, no user data)
✅ Limited sharing with service providers (RevenueCat, App Stores)
✅ Only as required by law

Your Rights:

✅ Access, update, or delete your data
✅ Disable location access
✅ Delete your account
✅ Export your data

By using slooshai, you acknowledge that you have read and understood this Privacy Policy.

Last updated: December 9, 2025