Privacy Notice

1. About us and this notice

Snootly is operated by Mistral Spark Limited, a company registered in England and Wales under company number 16874200. In this notice, “we”, “us” and “our” refer to Mistral Spark Limited. We are the controller of the personal data described below and are registered with the Information Commissioner's Office.

This notice explains what personal data we collect when you use the Snootly app, on any device or platform through which we make it available, or visit snootly.app, why we collect it, who we share it with, how long we keep it, and the rights you have in relation to it. Our terms of service govern your use of the app itself.

If you have any question about this notice or about your personal data, you can write to us at hello@snootly.app.

2. The personal data we collect

Account information

You sign in with your Apple or Google account. From the relevant provider we receive your name (or, if you use Apple's Hide My Email, the relay address Apple generates), your email address and a sign-in identifier. We do not receive your password, and we do not ask for your date of birth.

Information about your pets

This comprises the profiles and photographs you create for your pets and the records you choose to keep, which may include medications, vaccinations, allergies, the details of your veterinary practice, insurance information, emergency contacts, microchip numbers, daily care entries such as meals, medication, toileting and mood, together with any free-text notes, and documents you upload or send in by email, such as veterinary records. Documents of this kind may contain information about other people, for example the staff of your veterinary practice; we process such information solely as part of your pet's records.

Location

If you start a walk, we record its route using precise location, including in the background until the walk ends, subject to the location permission you have granted on your device. Recording stops when the walk ends. If you use the map, venue or weather features, we use your location for the purpose of answering that request; weather lookups are made using reduced-precision coordinates, which are not stored once the request has been answered.

Voice conversations

Voice features are optional. If you use them, your speech is processed by ElevenLabs in order to convert it to text, and the content of the conversation by Anthropic, as described in Section 6. Relevant information from your pet's profile, which may include the allergies and health information you have recorded for your pet, is used as context so that the assistant can answer you. Your session is held by ElevenLabs only while it is in progress: when it ends, we delete the recording and transcript from ElevenLabs immediately, and if a deletion attempt fails we retry it until it succeeds. We do not ask for, and do not use the feature to gather, information about your own health. Before you use voice, or any other AI feature, for the first time, the app shows a screen explaining what is sent to which provider and asks for your permission, which you can withdraw at any time in the app under Profile, then Privacy.

Content you share

This includes posts, photographs and videos, comments, recipes, reviews of venues, and your interactions with other users, such as following, liking, reporting and blocking.

Content shared by others which includes you

Other users' posts and photographs may include you, for instance a picture taken at a meetup. If such content concerns you, you may report it from the post and we will review it under our community guidelines.

Household sharing

If you invite another person to act as a caregiver, we hold that person's email address until the invitation is accepted, declined or expires, after which it is deleted in accordance with our retention schedule. Any message you write with the invitation is visible to its recipient.

If you have received an invitation and are not a Snootly user, we obtained your email address from the person who invited you. We use it only to deliver and administer that invitation, this notice applies to it, and it is deleted once the invitation is resolved or expires.

Technical information

We collect device and app information, push notification tokens and error reports. Error reports describe the technical structure of a fault. Our own diagnostic logs may record the data being processed when a fault occurs; access to them is restricted, they are used only to diagnose and repair the fault, and they are deleted within 3 (three) years.

Usage information

We use PostHog, hosted in the European Union, for product analytics and, only with your consent, session replay within the app. Replays mask the text you type. If you choose to complete the optional feedback form when cancelling a subscription or leaving, the text you write is held by our analytics provider.

Website visitors

The website sets only strictly necessary cookies unless you consent to analytics through the banner. Section 12 deals with cookies.

3. Purposes and lawful bases

Under the UK GDPR we must have a lawful basis for each use we make of personal data. The table below sets out our purposes and the corresponding bases.

We do not sell personal data and we do not show advertising. We have configured our AI and analytics providers so that your content is not used to train their models, and Anthropic's commercial terms do not permit training on our data.

Providing basic account information is a contractual requirement: we cannot provide the service without it. You are under no statutory obligation to provide us with personal data, and everything else you record or share is optional.

Information about other people:Content processed on your account may include other people's personal data: another person's voice captured during a voice session, a person appearing in a photograph, or the staff of your veterinary practice named in a document. We process such information on the basis of legitimate interests (Article 6(1)(f)), namely operating the service our users have asked us to provide, and this notice applies to it in the same way.

Special category data: We do not ask for special category data, and information about your pets is not special category data about you. Occasionally content you choose to record may reveal something about your own health. For the AI features, including voice, our condition for processing such content is your explicit consent (Article 9(2)(a)), which we ask for separately from the lawful basis on which we provide the feature itself; otherwise we do not use such content for any purpose beyond holding it as part of the records you keep and, where Section 5 applies, screening it for prohibited content. Where screened content reveals something about your health, our condition for the screening is the substantial public interest condition for preventing or detecting unlawful acts (Article 9(2)(g); Schedule 1, paragraph 10, Data Protection Act 2018), supported by our appropriate policy document. Records relating to content flagged as potentially illegal are handled under the additional safeguards the law requires for offence-related data.

4. Visibility of what you share

Your profile may be set to public or private in Settings.

If your profile is public, a post can be opened by anyone who has its link. The link shows the post's title, caption and images. Comments, likes and follower lists are not shown on link views, and link pages are excluded from search engine indexing. When you share a post, you should assume that anyone holding the link can view it.

If your profile is private, your posts and media are visible only to signed-in users you have allowed.

Profile pictures are publicly accessible irrespective of the public or private setting: anyone who has a picture's link can view it.

Your pets' household records, that is care entries, health records, documents and walk routes, form no part of the social features. They are visible only to you and to the caregivers you have invited, although images and documents you add to them are screened for prohibited content as described in Section 5.

5. Automated screening and moderation

Photographs you upload are checked automatically for prohibited content using Google's Gemini service. Screening applies to every image you upload, including household photographs and documents that form no part of the social features; it is a safety check only and does not make private content visible to other users. Content identified as prohibited may be removed or hidden. If you disagree with a moderation decision you may contest it by contacting us, and a person will review it.

The text of posts and comments you share is also checked automatically for prohibited content using Anthropic's Claude service, and videos you post are checked by Gemini as a set of still frames taken from the video. This screening runs whether or not you have allowed the AI features described in Section 6.

We do not take significant decisions about you based solely on automated processing. If automated screening ever affects you in a significant way, you are entitled to human review of the decision.

6. AI features

The AI features are optional, and nothing is sent to an AI provider for them until you allow it. The first time you use one, the app shows a screen that explains what is sent and to whom and asks for your permission. You can withdraw it at any time in the app under Profile, then Privacy; the AI features then stop until you allow them again, and our servers refuse AI requests from accounts that have not given permission.

The following features use Anthropic's Claude service:

• Snootly Agent, the AI assistant, including Tell Snootly: your messages and any photographs you attach, relevant context from your pets' profiles, logs and training progress, and your approximate location when you chat, so that answers can reflect local conditions such as the weather.
• Daily tips on your dashboard: your pet's profile and training progress. Once you have allowed the AI features, these load when you open the dashboard.
• Record scanning: the documents and photographs of pet records you choose to scan, so that their details can be read into your pet's records.
• Days Out and day planning: your requests, including the area you search.
• Custom guide lists, training programmes and movement programmes: what you type when you ask for one, together with relevant context from your pet's profile.

Anthropic automatically deletes inputs and outputs within 30 days, except where content is flagged under its usage policies or retention is required by law, in which case limited data may be kept for longer. Its commercial terms do not permit training on our data. Snootly Agent is not a veterinary service and nothing it produces is veterinary advice.

If you use the voice features, including dictation, voice conversations and replies read aloud, your speech and the text to be spoken are processed by ElevenLabs, and in a voice conversation the replies are generated by Anthropic's Claude service through ElevenLabs. ElevenLabs holds the recording and transcript of your session only while the session is in progress; when it ends, we delete them from ElevenLabs immediately, and failed deletions are retried until they succeed. Because a voice conversation may reveal information about your health, we ask for your explicit consent on the AI consent screen before your first use. If you use the voice features around other people, the microphone may also capture their speech. Your consent covers your own use of the feature, so please make sure that anyone present is aware before you begin a session.

7. Recipients of personal data

We use service providers to operate Snootly. The current list of providers, with each one's role, location and transfer safeguard, is maintained at snootly.app/subprocessors, and we update that page before any new provider begins processing personal data.

The principal providers at the date of this notice are Supabase (database, authentication and storage, hosted in the European Union), PostHog (analytics, hosted in the European Union), Anthropic (AI processing, United States), ElevenLabs (voice processing), Google (image screening, sign-in, maps and calendar, United States and global infrastructure), Resend (email), Apple (sign-in, notifications, weather and maps, global infrastructure) and Vercel (website hosting).

Our database, content storage and analytics are hosted in the European Union. Other providers, including Anthropic, process personal data in the United States or on global infrastructure; where personal data leaves the United Kingdom or the European Union, the safeguards described in Section 8 apply.

Apple and Google act as independent controllers in respect of their own sign-in services, under their own privacy policies.

If our business or its assets are sold or reorganised, personal data may be transferred as part of that transaction on the basis of our legitimate interests (Article 6(1)(f)) in the orderly sale or reorganisation of the business. Any recipient will be required to respect commitments consistent with this notice, and we will tell you of any material change to how your personal data is used.

We disclose personal data to public authorities only where we are legally required to do so, and we assess every such request against the law said to compel it.

8. International transfers

Our database, content storage and analytics are hosted in the European Union. Some providers, including Anthropic, process personal data in the United States or on global infrastructure.

Where they do, the transfer is made under the UK International Data Transfer Addendum or the EU Standard Contractual Clauses, or in reliance on the provider's certification under the EU-US Data Privacy Framework and its UK Extension.

9. Retention

We keep personal data for no longer than the purpose requires. In outline:

10. Your rights

You have the right to request access to your personal data, its rectification or erasure, restriction of processing, and a copy of the data you have provided in a structured, commonly used and machine-readable format (we provide JSON), and to object to processing carried out on the basis of legitimate interests. Where processing rests on consent, you may withdraw that consent at any time; withdrawal does not affect the lawfulness of processing carried out before it. These rights are subject to the exceptions the law provides: in particular, we may retain the records described in Section 9 where the law requires or permits it, and we will tell you if we rely on an exception.

Right to object: Where we process personal data on the basis of legitimate interests, you may object at any time. We will stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms.

To exercise any of these rights, write to us at hello@snootly.app. A request is valid however it reaches us. We will respond within one month and normally free of charge; where a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act on it, and we will explain why. Where a request is particularly complex we may extend by up to two further months, in which case we will tell you within the first month. Deletion of your account does not require a request: it is available directly in the app, under Settings.

If you are dissatisfied with our handling of your personal data or of a request, you may complain to us using the details in Section 15; we will acknowledge your complaint within 30 days and tell you the outcome without undue delay. You may also complain to the Information Commissioner's Office (ico.org.uk) or, if you are outside the United Kingdom, to your local supervisory authority.

11. Controls within the app

For convenience, the principal controls are as follows. Your profile's public or private setting is in Settings under Privacy. Consent to the AI features, including voice, is given on the AI consent screen and may be withdrawn in the app under Profile, then Privacy. Blocking and reporting are available from any post, comment or profile. Account deletion is in Settings and takes effect without further steps on our part. Your choice regarding website analytics is made through the cookie banner and may be changed from the cookie statement page. In-app analytics may be switched off in Settings. The location, microphone, photograph and notification permissions are governed by your device's own settings, where they may be withdrawn at any time; withdrawing the location permission prevents walk routes from being recorded.

12. Cookies

The website sets strictly necessary cookies only, unless you accept analytics through the consent banner, in which case analytics load thereafter. The accept and reject options are presented with equal prominence, and no analytics load before a choice is made. Further detail is in the cookie statement on the website.

13. Children

Snootly is not intended for children under 13, or under 16 in the United Kingdom and the European Economic Area. We do not collect dates of birth. Privacy-protective settings are applied to every account by default, apart from profile pictures, which are publicly accessible as described in Section 4.

14. Changes to this notice

We will publish any revised version of this notice with a new effective date, and previous versions will remain available. Where a change is material, we will notify you prominently within the app before the change takes effect and, where the change also concerns our terms of service, ask you to accept the revised terms before continuing.

15. Contact