Hugo, the AI conversation-driven tour guide

3. How We Use Information

• Provide and maintain the service
• Process subscriptions and account management
• Improve performance and develop new features
• Analyze usage patterns and conduct analytics
• Send push notifications (if permitted)
• Send marketing communications (unsubscribe link and in-app toggle available)
• Comply with legal obligations and enforce terms

4. Sharing of Information

We share information with the following third parties:

• Supabase: authentication and database storage (encrypted at rest and in transit)
• ElevenLabs: conversational AI voice processing
• RevenueCat: subscription and billing management
• Advertising and analytics partners: to support marketing and analytics, subject to user rights under applicable law

We may also share information to comply with legal obligations, protect our rights or safety, or in connection with a merger, acquisition, or business transfer.

We do not sell personal information for monetary value. We may share data with advertising partners for marketing purposes, which may be considered "selling" or "sharing" under the California Consumer Privacy Act (CCPA/CPRA). California residents may opt out (see Section 6).

5. Data Retention

We retain personal data only as long as necessary for the purposes described:

• Account data: active account plus up to 3 years after deletion
• Subscription/billing records: 6 years (legal/tax compliance)
• Voice inputs/transcripts: up to 12 months unless otherwise required; ElevenLabs may retain up to 3 years
• Location logs: up to 12 months
• Analytics and usage logs: 12 months
• Crash reports: 6-12 months

After retention periods, data is deleted or anonymised.

6. Your Rights

• Access and Portability: Email our DPO to request a copy of your data.
• Correction: Email our DPO to request corrections.
• Deletion: Delete your account in the app or email our DPO.
• Marketing Opt-Out: Click the unsubscribe link in emails or toggle settings in the app.
• California residents: Email our DPO to submit a "Do Not Sell or Share My Personal Information" request.

We will respond to verified requests within 1 month.

7. Legal Bases for Processing (GDPR)

• Contract: to provide Hugo and manage your account
• Consent: for marketing emails, push notifications, targeted ads (where applicable)
• Legitimate interests: analytics, service improvement, fraud prevention
• Legal obligations: tax and accounting records

8. Security

We implement reasonable technical and organizational measures, including:

• Encryption in transit (TLS)
• Encryption at rest (via Supabase)
• Access controls and monitoring
• Regular internal security reviews

We also rely on the security measures of our processors (Supabase, ElevenLabs, RevenueCat).

9. International Transfers

Data may be transferred to jurisdictions outside your country. Where required, we use safeguards such as standard contractual clauses.

10. Changes to This Policy

We may update this Privacy Policy. If changes are material, we will notify users through Hugo or by other appropriate means.

11. Contact Information

For questions or to exercise your rights, contact our Data Protection Officer:

Anna van Wingerden
Snowdrop Labs Ltd
21 Thurleigh Court
Clapham, London, SW12 8AQ
annaencodehack@gmail.com

1. Eligibility

You must be at least 13 years old to use Hugo. By using Hugo, you represent and warrant that you meet this requirement.

2. Account Registration

You must provide accurate and complete information when creating an account. You are responsible for maintaining the confidentiality of your password and for all activity under your account.

3. Subscriptions and Billing

Hugo may offer paid subscriptions or in-app purchases. All billing, payments, cancellations, and refunds are handled exclusively through the Apple App Store in accordance with Apple's terms and conditions. Subscription status is managed using RevenueCat. We do not collect or process your payment card details directly.

4. Acceptable Use

You agree not to:

• Use Hugo for unlawful, fraudulent, or harmful purposes.
• Reverse engineer, decompile, or attempt to access Hugo's source code.
• Interfere with or disrupt Hugo or its servers.
• Infringe intellectual property rights or other legal rights of others.

5. Intellectual Property

All intellectual property rights in Hugo, including the software, design, features, and content, belong to Snowdrop Labs Ltd or its licensors.

By using Hugo, you grant us a limited license to process your voice inputs, location data, and other content solely as necessary to provide and improve the service.

6. Termination

We may suspend or terminate your account at our discretion if you violate these Terms or use Hugo unlawfully. You may delete your account at any time within the app.

7. Privacy and Data Protection

Your use of Hugo is subject to our Privacy Policy, which explains how we collect, use, share, and protect your data.

Key retention commitments include:

• Account data: active account plus up to 3 years after deletion
• Subscription/billing records: 6 years
• Voice inputs/transcripts: up to 12 months; ElevenLabs may retain up to 3 years
• Location logs: 12 months
• Analytics and usage logs: 12 months
• Crash reports: 6-12 months

8. Disclaimer of Warranties

Hugo is provided on an "as is" and "as available" basis. We disclaim all warranties, express or implied, including but not limited to merchantability, fitness for a particular purpose, and non-infringement.

9. Limitation of Liability

To the maximum extent permitted by law, Snowdrop Labs Ltd shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including loss of profits, data, goodwill, or other intangible losses, arising out of your use of Hugo.

Our total liability to you for any claims arising from Hugo shall not exceed what is required by law.

10. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of England and Wales. Any disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.

11. Changes to These Terms

We may update these Terms from time to time. If changes are material, we will notify you through Hugo or by other appropriate means. Continued use of Hugo after changes take effect constitutes acceptance of the revised Terms.

12. Contact Information

For questions about these Terms, contact our Data Protection Officer:

Anna van Wingerden
Snowdrop Labs Ltd
21 Thurleigh Court
Clapham, London, SW12 8AQ
annaencodehack@gmail.com

1. Description of Processing

• Data categories: Name, email, password, voice recordings, transcripts, device identifiers, usage logs, crash reports, subscription status, location data.
• Purpose: Provide voice-based tour guide functionality, manage subscriptions, personalise experience, improve app, marketing.
• Data subjects: Hugo users (13+).
• Data flow:
  • Supabase: authentication and encrypted database storage.
  • ElevenLabs: voice input processing.
  • RevenueCat: subscription management.
  • Advertising and analytics partners: marketing and usage analysis.

2. Necessity and Proportionality

• Account data required to authenticate and manage subscriptions.
• Voice and location required to deliver core service (tour guidance).
• Logs and analytics necessary to improve stability and performance.
• Retention periods defined and minimised where possible.

3. Risks Identified

• Data breach risk (voice and location data are sensitive).
• Profiling and marketing risk (sharing with advertising partners).
• Retention creep (logs retained longer than necessary).
• Children risk (if under-13s bypass age gate).

4. Mitigations

• Supabase encryption at rest plus TLS in transit.
• Retention schedules:
  • Account: 3 years post-deletion.
  • Billing: 6 years.
  • Voice: 12 months (ElevenLabs up to 3 years).
  • Location logs: 12 months.
  • Analytics logs: 12 months.
  • Crash reports: 6-12 months.
• Age gate at signup (13+ only).
• Unsubscribe links plus in-app toggle for marketing.
• Data subject request procedure with 1-month turnaround.
• Signed data processing agreements with processors.
• Breach notification plan (72 hours under GDPR).

5. Outcome

With mitigations in place, processing is proportionate and compliant with GDPR, UK law, and CCPA/CPRA. No residual risks require prior consultation with regulators.