Sip — Privacy Policy (UK)

1. Background

1.1 — Tacit Labs Ltd, with its registered office at 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, collects and uses certain Personal Data in connection with the Sip application. Tacit Labs is the data controller and is responsible for ensuring that it uses that Personal Data in compliance with data protection laws. 1.2 — At Tacit Labs we respect the privacy of our users and we are committed to keeping your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Tacit Labs in the course of providing the Sip application. 1.3 — We use the following definitions in this Privacy Policy: "Tacit Labs", "we" or "us" means Tacit Labs Ltd. "Sip" means the Sip Android application (package com.tacitlabs.sip), its home-screen widgets and Wear OS companion. "Personal Data" means any data which relates to a living individual who can be identified from that data or from that data and other information, which is in the possession of, or is likely to come into the possession of, Tacit Labs (or its representatives or service providers). "Cookie & SDK Notice" means our companion notice describing the third-party SDKs used by Sip, available at tacitlabs.co.uk/sip/cookie-sdk-notice.

2. The products and services we provide

2.1 — This Privacy Policy concerns the following categories of information that we collect about you in connection with: - The Sip application and any data transmitted from it; and - Communications between you and Tacit Labs (for example, via privacy@tacitlabs.co.uk).

3. The types of information Sip handles

3.1 — This section describes every category of information Sip handles in connection with your use of the app. Most of it stays on your device and is never transmitted to Tacit Labs. The only Personal Data that reaches us is the limited technical and usage information collected through Google Firebase where you have consented (described below), and any information you choose to send to us directly. We do not receive your name, contact details, location, hydration or caffeine logs, or any of the optional profile fields (weight, age, sex, activity level) through any of the SDKs Sip uses. Information stored on your device. Sip stores your hydration logs, caffeine logs, custom drinks, optional profile (display name, weight, age, sex and activity level), settings, purchase records and related app state inside Sip's local application sandbox on your device. Some of this information is data concerning health — including your hydration and caffeine logs, the profile fields used by Sip to calculate personalised goals, and the pharmacokinetic estimates Sip derives from your caffeine intake (such as estimated onboard and plasma caffeine levels in milligrams, the absorption peak state, and sleep clearance status). All of this processing happens on your device, under your control. Tacit Labs has no copy, no access and no ability to read it. We are not the controller of this on-device processing — you determine what to enter, when to enter it, and which optional features to enable. If Android Auto Backup is enabled on your device, Android may include this on-device data (which contains data concerning health) in the device backup it creates in your own Google Drive; Tacit Labs has no access to that backup, which is governed by your Google account. Health Connect (Sip Pro). If you are a Sip Pro subscriber and you choose to enable Health Connect sync, Sip exchanges data with Google's Health Connect on your device: it writes your hydration entries (as HydrationRecord) and caffeine entries (as NutritionRecord with caffeine mass) into Health Connect, and reads your latest body weight and recent exercise minutes from Health Connect to keep your daily fluid goal current. Health Connect data is data concerning health. Enabling the Health Connect toggle in Sip is your explicit consent to this processing; you may withdraw that consent at any time via Settings → Health Connect, or by revoking Sip's Health Connect permissions in the Health Connect system app. Health Connect data is exchanged only between Sip and Health Connect on your device — Tacit Labs does not receive a copy. The Health Connect store is operated by Google as part of your device's platform and is governed by your Google account and the Health Connect privacy notice. Data you have written to Health Connect via Sip remains in Health Connect after you uninstall Sip; to remove it you must delete it within Health Connect itself. Wear OS sync. If you have a paired Wear OS smartwatch with the Sip companion installed, hydration log entries are routed between your phone and your watch via Google's Wearable Data Layer. The data is in transit only; it is sent to your own paired device, not to Tacit Labs. Because hydration entries are data concerning health, we note for transparency that Google acts as a transit provider for this data even though Google does not persist it. Analytics, crash, performance and remote configuration data. Where you have given consent, we collect limited technical and usage information through Google Firebase. This includes in-app event signals (for example, the amount of water logged), user properties (for example, app theme), crash diagnostics (for example, the stack trace and device model), performance metrics (for example, screen load times), and remote configuration fetches (device metadata sent as part of the request used to retrieve app feature settings). This information is not linked to your name or contact details, and the full list of fields is set out in the Cookie & SDK Notice. Advertising data. Where the free tier of Sip is used and you have given consent (via our consent form), Google AdMob processes advertising signals (for example, ad impressions and interactions) as an independent controller for ad targeting and measurement. The Android Advertising ID (AD_ID) is disabled at the SDK level and is not collected. Where consent is refused, ads are still shown in the free tier but are non-personalised. See the Cookie & SDK Notice for full details. Location-related data. Where you choose to use the optional weather feature, an approximate city location may be derived from your device's IP address by ipwho.is (an independent third-party geolocation provider), or you may enter a city manually. Weather forecasts are then fetched from Open-Meteo using coordinates rounded to approximately 1 km. Tacit Labs does not collect or retain your IP address or precise location. Purchase data. Where you purchase Sip Pro, Google Play handles the payment in full as an independent controller for payment processing. Tacit Labs receives only an opaque purchase token and product ID; we do not receive payment card details or financial information. Information you provide directly. Any information you choose to share with us, for example through email correspondence with privacy@tacitlabs.co.uk. Anonymised data. In addition to the categories above, Tacit Labs will also process aggregated and anonymised information that is not processed by reference to a specific individual.

4. How we use your information

4.1 — Your Personal Data may be stored and processed by us in the following ways and for the following purposes: - To provide the Sip application and any features you have enabled within it; - Where you have consented to analytics, crash and performance data collection: for the ongoing review, improvement and security of the Sip application, and to diagnose crashes, monitor performance and understand how features are used; - To serve advertising in the free tier (only on the basis of your consent, with non-personalised ads served where consent is refused); - To process and verify in-app purchases through Google Play; - To respond to communications and rights requests from you; - To comply with and assess compliance with applicable laws, rules and regulations; and - For the management and administration of our business. 4.2 — However we use Personal Data, we make sure that the usage complies with law. The legal bases on which we rely include where: - Consent has been given for analytics, crash, performance, remote configuration and advertising data; - The processing is necessary for the performance of a contract with you, including delivering the Sip Pro entitlement you have purchased and providing the optional features you have enabled (such as the weather feature, which requires fetching data from third-party providers to function); - We have legal and regulatory obligations that we have to discharge; or - We may need to do so to establish, exercise or defend our legal rights or for the purpose of legal proceedings. We do not rely on legitimate interests for any processing of Personal Data that reaches our infrastructure, and we do not engage in direct marketing. 4.3 — We will take steps to ensure that Personal Data is accessed only by personnel or processors that have a need to do so for the purposes described in this Privacy Policy. 4.4 — Special category data Sip processes data concerning health. This includes your hydration logs, caffeine logs, the optional profile fields used to personalise your daily fluid goal (weight, age, sex and activity level — weight and age default to 70 kg and 30 years respectively if not entered; sex and activity level have no defaults, and a general population goal is calculated if they are not provided), the pharmacokinetic estimates Sip derives from your caffeine intake, and — if you enable Health Connect — the hydration, caffeine, weight and exercise records exchanged with Health Connect on your device.

(a) All processing happens on your device. Sip is designed so that data concerning health is not transmitted to Tacit Labs. Tacit Labs has no copy, no access and no ability to read it. Tacit Labs is not the controller of this on-device processing; you are processing your own data on your own device for your own purposes, and Sip is the tool you have chosen to use to do so.

(b) Lawful basis where you enable Health Connect. Where you turn on Health Connect sync inside Sip, the Health Connect toggle is your explicit consent to Sip reading from and writing to your Health Connect data. You may withdraw that consent at any time via Settings → Health Connect, or by revoking Sip's Health Connect permissions in the Health Connect system app. The exchange happens entirely between Sip and Health Connect on your device.

(c) If we ever change the application such that any data concerning health would reach Tacit Labs' infrastructure, we will obtain your explicit consent before any such processing begins, and we will update this Policy and notify you in advance through an in-app notice. 4.5 — Aggregated and anonymised data. We may create aggregated, de-identified or anonymised data from any Personal Data we lawfully process. We may use and share such data for our lawful business purposes, provided that we do not share it in a manner that could identify you. 4.6 — No medical advice. Sip is a personal hydration and caffeine tracking tool, not a medical device. For information on what Sip's guidance is and is not, please see our Terms of Service.

5. Disclosure of your information to third parties

5.1 — We may share your Personal Data outside of Tacit Labs for the following purposes: - With third-party processors and infrastructure providers for the purposes of providing services to us. This includes Google LLC, which provides Firebase Analytics, Crashlytics, Performance Monitoring and Remote Config under the Firebase Data Processing Terms. These processors are subject to appropriate data protection obligations and will only use your Personal Data in accordance with this Privacy Policy and our agreements with them. - With independent third-party controllers where you choose to use features that involve them. This includes Google AdMob (advertising in the free tier), Google LLC for Google Play Billing (payment processing for Sip Pro), ipwho.is (IP-based city lookup for the optional weather feature), Open-Meteo (weather forecast data), Google LLC for the Wearable Data Layer (in-flight routing of hydration data to your own paired Wear OS watch — Google does not persist the data), and Google LLC for Health Connect (the on-device health-data platform Sip exchanges hydration, caffeine, weight and exercise records with if you enable Health Connect sync as a Sip Pro subscriber — the data is stored in your Health Connect on your device, governed by your Google account and the Health Connect privacy notice, and Tacit Labs does not receive a copy). These third parties act as independent controllers (and, in the case of Health Connect, as the operator of the on-device health-data platform you control) and their own privacy policies apply to their processing. Links and full details are in the Cookie & SDK Notice. - To the extent required by law, for example if we are under a duty to disclose your Personal Data to comply with any legal obligation, or to establish, exercise or defend our legal rights. - In the context of a corporate transaction, for example if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes. 5.2 — We do not sell or rent your Personal Data, and we do not share it with third parties for their own marketing purposes.

6. International transfers of personal data

6.1 — Some of the third parties described in paragraph 5 process Personal Data outside of the United Kingdom, in particular Google LLC (United States) for Firebase services and AdMob. 6.2 — Where we transfer your Personal Data to a country outside the UK that is not subject to a UK adequacy decision, we rely on the UK International Data Transfer Addendum issued by the Information Commissioner's Office, together with the EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) as incorporated by the Addendum. Our transfers to Google LLC for Firebase Analytics, Crashlytics, Performance Monitoring and Remote Config are made under those clauses as incorporated into the Firebase Data Processing Terms. Other recognised transfer mechanisms permitted by law may also apply where relevant. 6.3 — You can obtain more details of the protection given to your Personal Data when it is transferred outside the UK (including a copy of the standard data protection clauses entered into with recipients of your Personal Data) by contacting us as described in paragraph 11 below.

7. How we safeguard your information

7.1 — We have controls in place to maintain the security of our information and information systems. Information is protected with safeguards appropriate to its sensitivity. All network connections used by Sip use TLS, and on-device data is protected by the Android application sandbox and device-level encryption where enabled by your device. 7.2 — Access to systems containing Personal Data is restricted to personnel who need it to perform their roles. Unauthorised use or disclosure of confidential information is prohibited.

8. How long we keep your personal data

8.1 — How long we hold your Personal Data will vary and will be determined by the following criteria: - The purpose for which we are using it — Tacit Labs will keep the data only for as long as is necessary for that purpose; and - Legal obligations — laws or regulations may set a minimum period for which we have to keep certain data. 8.2 — Specific retention periods for analytics, crash and performance data held by Google Firebase on our behalf are set out in the Cookie & SDK Notice. 8.3 — Data stored on your device persists until you delete it, clear Sip's app data, or uninstall the application. Exception: if you have enabled Health Connect sync (Sip Pro), data Sip has written to Health Connect remains in Health Connect after you uninstall Sip and must be deleted within Health Connect itself — see paragraph 3 above.

9. Your rights

9.1 — In all the above cases in which we collect, use, or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include: - The right to obtain information regarding the processing of your Personal Data and access to the Personal Data we hold about you; - The right to withdraw your consent to the processing of your Personal Data at any time, including via Settings → Manage Consent within Sip. Please note that we may still be entitled to process your Personal Data if we have another legal basis for doing so; - In some circumstances, the right to receive Personal Data in a structured, commonly used and machine-readable format, and to request that we transmit it to a third party where this is technically feasible; - The right to request that we rectify your Personal Data if it is inaccurate or incomplete; - The right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it; - The right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. There may be circumstances in which we are legally entitled to refuse such a request; - The right not to be subject to automated decisions producing legal or similarly significant effects (we do not undertake any such decision-making); and - The right to lodge a complaint with the Information Commissioner's Office (the UK data protection regulator) if you think that any of your rights have been infringed by us. 9.2 — Sip does not require you to create an account. Uninstalling the application or clearing its data on your device removes the Personal Data held locally within Sip's sandbox on your device. Note that if you have enabled Health Connect sync, data written to Health Connect remains in Health Connect after uninstall; to delete it, use the Health Connect system app on your device. To remove correspondence held in our mailbox, or to request deletion of analytics or crash data held by Google Firebase on our behalf, please contact us as described in paragraph 11. 9.3 — You can exercise your rights by contacting us using the details listed in paragraph 11 below. 9.4 — We will respond to your request within one calendar month of receiving it. If your request is complex, or you have made several requests, we may extend this period by up to two further months — if so, we will tell you within one month and explain why.

10. Children

10.1 — Sip is intended for users aged 18 and over, but we have designed it so that anyone aged 13 or over can use it safely. Data collection is off by default, your hydration, caffeine and profile information stays on your device, and we ask for your consent before collecting any analytics, crash data or advertising data. 10.2 — Sip is not intended for children under 13, and we do not knowingly collect personal information from anyone under 13. If you believe a child under 13 has given us their information, please contact us at privacy@tacitlabs.co.uk and we will delete it. 10.3 — We have designed Sip with younger users in mind. There are no social features, no profiling, no behavioural advertising — just a hydration tracker that keeps your information on your phone. 10.4 — Health Connect and younger users. The Health Connect integration described in paragraphs 3 and 4.4 is a Sip Pro feature and is off by default. Because it processes data concerning health, we encourage parents and guardians of users aged 13–17 to review whether enabling Health Connect is appropriate, and to use the Health Connect system app's own controls to manage which apps can read or write health data on the device.

11. Questions and concerns

11.1 — If you have any questions or concerns about Tacit Labs' handling of your Personal Data, or about this Policy, please contact us using the following contact information: Tacit Labs Ltd, 71–75 Shelton Street, Covent Garden, London WC2H 9JQ privacy@tacitlabs.co.uk We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may complain to the Information Commissioner's Office (www.ico.org.uk).

12. Changes to this Policy

12.1 — We may update this Privacy Policy from time to time to reflect changes in our practices, the SDKs used by Sip, or applicable law. The "Last updated" date at the top of this Policy will reflect the most recent change. 12.2 — Where changes are material, we will notify you in advance through an in-app notice on next launch and, where relevant, an update to the Sip listing on Google Play. Continued use of Sip after a material change takes effect indicates acceptance of the updated Policy; you may withdraw consent to optional processing at any time via Settings → Manage Consent.