Privacy Policy

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

User-Generated Content:

• Audio recordings you create (stored locally on your device only)
• Tags, notes, and metadata you add to recordings
• Location data you choose to attach to recordings

2.2 Information Collected by Third-Party Services

Apple App Store (automatic collection by Apple, not by slooshai):

Apple automatically collects analytics and performance data for all apps distributed through the App Store. This data is collected by Apple, not by the slooshai app. See Section 15.1 for details.

RevenueCat (Subscription Management):

When you purchase a subscription, our subscription management provider (RevenueCat) collects:

• Anonymous user ID (assigned by RevenueCat — not linked to your identity)
• Purchase history and subscription status
• Subscription tier and entitlements

Apple Payment Processing:

When you purchase a subscription, Apple processes:

• Payment information (credit card, Apple Pay, etc.)
• Purchase history
• This information is processed by Apple and NOT stored by us

2.3 Information We Do NOT Collect

The slooshai app itself does NOT collect or transmit:

• The content of your audio recordings (recordings stay on your device)
• Analytics data or usage telemetry
• Crash reports
• 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: While our app does not collect analytics, Apple automatically collects performance and usage metrics through App Store Connect (see Section 15.1). This is beyond our control.

Note on Biometric Data: The App can use 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 or Apple.

3. How We Use Your Information

3.0 Legal Basis for Data Processing

For United States Residents:

We process your personal information for the following business purposes:

• Providing and maintaining the App's functionality
• Processing payments and managing subscriptions (through Apple and RevenueCat)
• Complying with legal obligations
• Preventing fraud and ensuring security

Privacy Rights Under State Laws:

Residents of California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with comprehensive privacy laws have specific rights detailed in Section 9.1.

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
• Legitimate Interest (Article 6(1)(f)): Processing is necessary for our legitimate interests in:
  • Preventing fraud and ensuring security
  • 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.

We use the collected information for the following purposes:

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 (audio classification)
• Enable location tagging for recordings (with your consent)

3.2 Subscription Management

• Verify subscription status through RevenueCat and Apple
• Manage access to premium features based on subscription tier
• Process subscription payments through Apple

Note: We do not send transactional emails ourselves. Apple sends receipts for purchases. RevenueCat may send subscription-related emails if you have configured notifications through their service.

3.3 Communication

• Respond to your support requests sent to info@slooshai.app
• Send important updates about the App or policy changes (only when legally required or critical)

3.4 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:

• On-device encryption: Recordings and app data are encrypted at rest using your device's built-in encryption
• Encryption in transit: Data transmitted to RevenueCat (subscription verification only) is encrypted using TLS/SSL
• Minimal data exposure: We do not operate servers that store your recordings or personal data
• Access controls: App data is isolated using iOS sandbox security
• Secure coding practices: We follow industry-standard secure development practices

4.3 Data Retention

• Local recordings: Retained on your device until you delete them
• Subscription data: Retained by RevenueCat and Apple while your subscription is active, plus any retention period required by their policies
• Local app data: Deleted instantly when you use "Delete All Data" in app settings
• No server-side user data: We do not store your recordings or personal data on servers, so there is no server-side retention period

Note: Apple automatically collects performance metrics (see Section 15.1). Apple's data retention policies apply to that data, not ours.

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.

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: Verify subscriptions and manage premium feature access
• Data shared: Anonymous user ID, subscription status
• Privacy Policy: https://www.revenuecat.com/privacy
• Data Processing Agreement: https://www.revenuecat.com/dpa
• Compliance: RevenueCat uses Standard Contractual Clauses (SCCs) for international data transfers and maintains GDPR/CCPA compliance

Apple App Store:

• Purpose: Process payments and manage subscriptions (iOS)
• Data shared: Payment information, purchase history (processed by Apple, not stored by us)
• Privacy Policy: https://www.apple.com/legal/privacy/

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 (all data is stored locally and visible to you)
• Update your settings and preferences
• Delete all your data instantly through "Delete All Data" in app settings

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

• We do not send promotional emails or marketing communications
• We only send emails in response to your support requests

6.4 Analytics and Tracking

• The slooshai app does not collect analytics or tracking data
• Apple automatically collects performance metrics through App Store Connect (see Section 15.1)
• You can limit Apple's analytics collection through your device settings:
  • iOS: Settings > Privacy & Security > Analytics & Improvements > Share iPhone Analytics (toggle off)

6.5 Data Deletion

To delete all your data:

1. Go to App Settings > Export and Data
2. Select "Delete All Data"
3. Confirm deletion

Upon deletion:

• All app data is permanently deleted immediately from your device
• This includes all recordings, tags, settings, and preferences
• This action cannot be undone
• Subscription data managed by RevenueCat and Apple is retained according to their policies (for billing history and fraud prevention)

Important: Deleting app data does NOT cancel your subscription. To cancel your subscription, go to iOS Settings > [Your Name] > Subscriptions.

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).

Minimum Age Requirements:

• United States: You must be at least 13 years of age to use slooshai
• European Economic Area: You must be at least 16 years of age
• All Regions: If you are under 18, you confirm that you have parental or guardian consent to use this App

7.2 Age Verification Through the App Store

We use Apple's age verification system to enforce age requirements:

• Apple App Store: Age verification is handled through Apple's age rating system and Family Sharing features. Parents/guardians must approve downloads for users under the App's age rating.

By downloading slooshai from the App Store, you confirm that:

• You meet the minimum age requirements, OR
• You have obtained parental/guardian consent through your device's Family Sharing features

7.3 No Knowingly Collecting Children's Data

We do not knowingly collect personal information from children under 13 (or under 16 in the EU).

If you are a parent or guardian and believe your child has provided us with personal information without consent, please contact us immediately at info@slooshai.app.

7.4 If We Discover Underage Users

If we discover that a child under the minimum age has provided personal information without parental consent, we will:

• Delete the information immediately
• Disable access to the App
• Notify the parent or guardian (if contact information is available)

7.5 Parental Rights and Controls

Parents and guardians can:

• Monitor app usage through Screen Time on iOS
• Request deletion of their child's data by contacting info@slooshai.app
• Manage app downloads through Family Sharing on iOS

8. International Data Transfers

8.1 Data Location

Your subscription data may be processed and stored in countries other than your own by our service providers (RevenueCat, Apple). These countries may have different data protection laws.

Geographic Availability:

The App is currently available throughout the United States. 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

We rely on service providers who comply with international data transfer requirements:

RevenueCat:

• Uses Standard Contractual Clauses (SCCs) for international data transfers
• Maintains Data Processing Agreements compliant with GDPR and CCPA
• Full compliance documentation: https://www.revenuecat.com/dpa

Apple:

• Complies with international data protection frameworks
• Uses encryption in transit (TLS/SSL) and at rest
• Maintains global privacy and security certifications
• Privacy documentation: https://www.apple.com/legal/privacy/

All data transfers between our service providers use industry-standard encryption to protect your information in transit.

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 United States - State Privacy Laws

Primary Jurisdictions: slooshai is available throughout the United States and complies with comprehensive state privacy laws including California's CCPA/CPRA, Virginia's VCDPA, Colorado's CPA, Connecticut's CTDPA, and Utah's UCPA.

California Residents (CCPA/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:

Contact us at info@slooshai.app with "Privacy Request" in the subject line. Include:

• 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.

Other US State Residents:

If you are a resident of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), or Utah (UCPA), you have similar rights under your state's privacy law:

• Right to Access: Confirm whether we are processing your personal data and access such data
• Right to Delete: Request deletion of your personal data
• Right to Correct: Request correction of inaccurate personal data
• Right to Data Portability: Obtain a copy of your personal data in a portable format
• Right to Opt-Out: Opt-out of the processing of personal data for:
  • Targeted advertising (we do NOT engage in targeted advertising)
  • Sale of personal data (we do NOT sell your personal information)
  • Profiling in furtherance of decisions with legal or similarly significant effects (we do NOT engage in such profiling)

How to Exercise Your Rights:

Residents of all US states with privacy laws can exercise their rights by contacting us at info@slooshai.app with "Privacy Request" in the subject line.

Response Timeline: We will respond to your request within 45 days (or as required by your state law).

Right to Appeal: If we deny your request, you have the right to appeal our decision. We will provide appeal instructions in our response.

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9.2 European Economic Area (EEA) - GDPR

Future Expansion: While slooshai is currently available throughout the United States, 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.

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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 (audio classification) run locally on your device
• Your audio is NOT sent to external servers for AI processing
• AI models run entirely on your device using Apple's built-in frameworks

11.2 AI Models

• The App uses Apple's built-in SoundAnalysis framework for audio classification, which is updated by iOS system updates
• No AI models are downloaded or distributed through the App itself
• Any improvements to sound classification come through iOS updates from Apple

11.3 Your Recordings and AI

• Pre-built sound classification models (Apple SoundAnalysis) do not learn from your data
• All AI processing runs locally on your device

11.4 Automated Decision-Making (GDPR Article 22)

• The App does not make automated decisions that significantly affect you
• All AI-generated tags and classifications 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

Note: Since we do not store your recordings or personal data on servers, the risk of a data breach affecting your recordings is minimal.

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:

Contact us at info@slooshai.app with "Privacy Request" in the subject line. We will respond within 45 days.

15. App Store Specific Information

15.1 Apple App Store

Apple's Automatic Analytics Collection:

Apple automatically collects metrics for all apps in the App Store, independent of the app's own data collection practices. These metrics are visible to us through App Store Connect and include:

• Crashes and Hangs: App crashes, performance metrics
• Usage Metrics: Installs, active users, sessions, engagement data
• Performance Data: Memory usage, battery consumption, disk writes
• Device Information: Device models and iOS versions

Important: This data collection is controlled by Apple, not by slooshai. You cannot disable it through our app. The slooshai app itself does NOT send any analytics or crash data to us or to third parties. Apple's full privacy policy is available at https://www.apple.com/legal/privacy/.

To Limit Apple's Analytics Collection:

• Go to Settings > Privacy & Security > Analytics & Improvements
• Toggle off "Share iPhone Analytics"

App Tracking Transparency:

• We do NOT implement app tracking for cross-app advertising
• We do NOT require permission under Apple's App Tracking Transparency (ATT) framework
• You can manage tracking preferences in Settings > Privacy > Tracking if other apps request it

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Summary (Privacy Nutrition Label)

Data We Collect:

• Purchase history and subscription status — Processed by RevenueCat and Apple to verify your subscription. Not linked to your identity.
• Location data — Only when you explicitly add it to a recording. Stored locally on your device only. Not linked to your identity.

How It's Used:

• To provide app features (all audio processing happens on-device)
• To verify your subscription
• To comply with legal requirements

Data Sharing:

• RevenueCat — subscription management
• Apple — payment processing
• Legal authorities — only when required by law

Your Rights:

• Access and delete your data at any time
• Disable location access in your device settings
• Limit Apple's analytics collection in your device settings (Settings → Privacy & Security → Analytics & Improvements)

For Apple's data practices, see Apple's Privacy Policy.

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

Last updated: February 3, 2026