Sip — Privacy Policy (Rest of World, including United States and California)

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 information in connection with the Sip application. Tacit Labs is the business responsible for that personal information and for ensuring it is handled in compliance with applicable law. 1.2 — At Tacit Labs we respect the privacy of our users and we are committed to keeping your personal information secure. This Privacy Policy governs the handling of personal information 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 information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. "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 categories 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 information that reaches us is the limited technical and usage information collected through Google Firebase (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 — including your hydration and caffeine logs, the profile fields Sip uses 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) — relates to your health. All of this processing happens on your device, under your control. Tacit Labs has no copy, no access and no ability to read it. If Android Auto Backup is enabled on your device, Android may include this on-device data 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 and caffeine entries into Health Connect, and reads your latest body weight and recent exercise minutes from Health Connect to keep your daily fluid goal current. Enabling the Health Connect toggle in Sip is your opt-in consent to this exchange; you may withdraw it 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. 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. Analytics, crash, performance and remote configuration data. Outside the UK and EEA, we collect limited technical and usage information through Google Firebase by default, consistent with Google's standard Firebase terms. 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. You can disable this collection at any time in Settings → Manage Consent. Advertising data. Where the free tier of Sip is used, advertising is served by Google AdMob, which acts as an independent business for ad targeting and measurement under its own terms. The signals processed include ad impressions and interactions. The Android Advertising ID (AD_ID) is disabled at the SDK level and is not collected. 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 business 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 information 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; - 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; - 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 — We do not engage in direct marketing. 4.3 — We will take steps to ensure that personal information is accessed only by personnel or processors that have a need to do so for the purposes described in this Privacy Policy. 4.4 — Sensitive information / health information. Sip processes health-related information about you, including 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. All of this processing happens on your device, under your control; Tacit Labs has no copy and no access. Where you turn on Health Connect sync, that toggle is your opt-in consent to the exchange between Sip and Health Connect described in Section 3. If we ever change the application such that any such health information would reach Tacit Labs' infrastructure, we will provide notice and, where required by applicable law, obtain your opt-in consent before any such processing begins. 4.5 — Aggregated and anonymised data. We may create aggregated, de-identified or anonymised data from any personal information 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 information outside of Tacit Labs for the following purposes: - With third-party service providers 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 service providers are subject to appropriate contractual obligations and will only use your personal information in accordance with this Privacy Policy and our agreements with them. - With independent third parties 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 businesses for their own processing (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. 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 information 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 information to the prospective buyer for due diligence purposes. 5.2 — We do not sell or rent your personal information for monetary consideration, and we do not share it with third parties for their own marketing purposes. For California-specific definitions of "sale" and "share", see Section 12.

6. International transfers of personal information

6.1 — Tacit Labs is established in the United Kingdom. If you use Sip from outside the United Kingdom, your personal information will be transferred to and processed in the United Kingdom and, via the third-party service providers described in paragraph 5, in the United States and other jurisdictions where those providers operate. 6.2 — By using Sip, you acknowledge that data protection laws in those jurisdictions may differ from those in your country of residence.

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 information 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 information

8.1 — How long we hold your personal information 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 Section 3 above.

9. Your choices

9.1 — Sip does not require you to create an account. You may exercise the following choices at any time: - Disable analytics, crash and performance data collection — Settings → Manage Consent within Sip; - Remove Sip Pro ads — purchase Sip Pro; - Delete personal information stored on your device — uninstall Sip or clear its app data via Android Settings (note: 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); - Request deletion of analytics or crash data held by Google Firebase on our behalf — contact us at privacy@tacitlabs.co.uk; - Remove correspondence held in our mailbox — contact us at privacy@tacitlabs.co.uk. 9.2 — We will respond to requests sent to privacy@tacitlabs.co.uk within one calendar month of receiving them. If a 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. California residents: see also Section 12.8 for the California response timing.

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 minimised, your hydration, caffeine and profile information stays on your device, and you can turn off analytics, crash reporting and personalised advertising at any time in Settings → Manage Consent. 10.2 — Sip is not intended for children under 13, and we do not knowingly collect personal information from anyone under 13. If you are a parent or guardian and 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 — If you live in California and are under 16, we do not sell or share your personal information for advertising purposes. See Section 12 for more on California-specific rights.

11. Contact

11.1 — If you have any questions or concerns about Tacit Labs' handling of your personal information, 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

12. Notice to California residents

This section provides additional information required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), and applies only to residents of California. 12.1 — Categories of personal information collected. In the preceding 12 months, we have collected the following categories of personal information about California residents, as defined in Cal. Civ. Code § 1798.140: - Identifiers — limited to those processed by Google Firebase (e.g. Firebase Installation ID) and, where you provide them, your email address; - Internet or other electronic network activity information — in-app event signals as described in Section 3; - Geolocation data — coarse, city-level only, and only if you use the optional weather feature (your IP address is sent to ipwho.is but is not stored by Tacit Labs); - Commercial information — opaque purchase tokens for Sip Pro; - Inferences — none drawn by Tacit Labs from the above. 12.2 — Sources of personal information. Directly from you (when you use Sip or contact us) and from your device (via the SDKs described in the Cookie & SDK Notice). 12.3 — Purposes for collection. As described in Section 4. 12.4 — Disclosures of personal information. As described in Section 5. We disclose personal information to the service providers and independent third parties listed there for the purposes set out alongside each. 12.5 — "Sale" and "sharing" of personal information. Tacit Labs does not sell personal information for monetary consideration. We do not "share" personal information for cross-context behavioural advertising as defined under the CPRA: ads served via Google AdMob in the free tier are non-personalised by default for users who have not opted in to personalised advertising, and the Android Advertising ID is explicitly disabled at the SDK level by Sip. 12.6 — Sensitive personal information. Sip processes health-related information (including hydration, caffeine, profile fields and, if you enable Health Connect, the Health Connect records exchanged with Sip) entirely on your device. Tacit Labs does not receive that information, does not "use" it within the meaning of the CPRA, and does not infer characteristics about you from it. We do not collect or use sensitive personal information (as defined under the CPRA) for the purpose of inferring characteristics about a consumer. 12.7 — Your California rights. Subject to verification of your identity and to applicable exceptions, California residents have the right to: - Know what personal information we have collected about you, the categories of sources, the purposes for collection, and the categories of third parties to whom we disclose it; - Access a copy of the specific pieces of personal information we hold about you; - Delete personal information we have collected from you; - Correct inaccurate personal information we hold about you; - Opt out of the sale or sharing of your personal information (Tacit Labs does not engage in either, but you may submit a request to confirm this); - Limit the use and disclosure of sensitive personal information (Tacit Labs does not use sensitive personal information for purposes that would trigger this right); - Not be discriminated against for exercising any of these rights. 12.8 — How to exercise your rights. To submit a request, contact us at privacy@tacitlabs.co.uk with the subject line "California Privacy Request" and a description of your request. We will verify your identity by matching the information you provide with information already in our possession (for example, the email address from which you previously contacted us). You may designate an authorised agent to make a request on your behalf; we will require written authorisation and proof of identity. We will respond within 45 days, with one possible 45-day extension where reasonably necessary. 12.9 — Notice of financial incentives. We do not offer financial incentives in exchange for the collection, sale, sharing or retention of personal information. 12.10 — Shine the Light. California residents may request information about our disclosure of personal information to third parties for those parties' direct marketing purposes. We do not disclose personal information for such purposes.

13. Changes to this Policy

13.1 — 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. 13.2 — 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.