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Privacy Policy

Effective date: September 12, 2026

This Privacy Policy explains how Guillaume Rozand ("we", "us", "our"), the individual developer of Snoli (the "App"), handles information in connection with your use of the App. We built Snoli to work with as little data as possible, and this policy reflects that.

1. Data controller

Guillaume Rozand, individual developer, France, is the data controller for the purposes of the EU General Data Protection Regulation (GDPR). Contact: guillaume.rozand@icloud.com.

2. What we collect — and what we don't

We do not operate any analytics, advertising, or crash-reporting service inside the App, and we do not ask you to create an account. Specifically:

3. Purchases (handled by Apple)

All purchases and subscriptions are processed entirely by Apple through the App Store and StoreKit. We never see or receive your payment card details. Apple shares with us only the minimum information needed to unlock the content you purchased (for example, subscription status and product identifier), which is not linked to your name or contact details on our side. Apple's own collection and use of your data is governed by Apple's Privacy Policy, not this one.

4. Device-level diagnostics

If you have opted in to share analytics with app developers in your iPhone's Privacy settings, Apple may provide us with anonymized crash and performance reports through App Store Connect. This is controlled entirely by your iOS settings and by Apple's own privacy practices, not by anything inside the App.

5. Legal basis for processing (GDPR)

The first name, age, and sex you optionally provide during onboarding are processed on the basis of your consent (Art. 6(1)(a) GDPR) and to deliver the personalized experience you're requesting (performance of a contract, Art. 6(1)(b) GDPR). You can withdraw this at any time by clearing the App's data in your device settings or deleting the App — since this information is never sent to us, doing so removes it completely and immediately, with nothing left on our side to erase. Purchase-related data is processed to comply with legal obligations (Art. 6(1)(c)), such as tax records that Apple maintains as payment processor.

6. Data sharing

We do not sell, rent, or share personal data with third parties for their own marketing purposes. The only third party involved in the App's operation is Apple Inc., acting as the App Store operator and payment processor.

7. International transfers

Any data Apple processes on our behalf may be transferred to and processed in the United States or other countries where Apple operates, under the safeguards described in Apple's own privacy documentation.

8. Data retention

We do not retain personal data on any server, because none of it is transmitted to us. Your onboarding profile (first name, age, sex) and app preferences, stored locally on your device, remain there until you delete the App or clear its data — at which point they are gone entirely, on your device and everywhere else, since no copy exists elsewhere.

9. Children's privacy

Snoli is not directed at children under 13 (or the equivalent minimum age in your country), and we do not knowingly collect personal data from children. The age entered during onboarding is self-reported and stored only on your device; we have no way to verify it and no access to it. If you believe a child has used the App and provided information during onboarding, a parent or guardian can remove it at any time by deleting the App or clearing its data.

10. Your rights

If data protection law applies to you (for example, the GDPR if you are in the European Economic Area, or the UK GDPR), you have the right to request access to, correction of, deletion of, or restriction on the use of your personal data, to object to processing, and to data portability, to the extent we hold any such data. Because your onboarding profile and preferences are stored only on your device, you can exercise most of these rights yourself directly in the App (redo onboarding to correct your details, or delete the App to erase everything) — we hold no remote copy to access, correct, or delete on our end. You also have the right to lodge a complaint with your local data protection authority — in France, the CNIL.

11. California and other U.S. state privacy rights

We do not sell or share personal information as defined under the California Consumer Privacy Act or similar U.S. state laws. Because we collect no personal information directly, there is no sale, sharing, or targeted advertising to opt out of on our side.

12. Security

Because your preferences stay on your device and we do not operate servers that store your personal data, the main safeguard is your own device security (passcode, iOS updates). Payment security is handled by Apple's infrastructure.

13. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be reflected by a new effective date at the top of this page.

14. Contact

Questions about this Privacy Policy, or requests relating to your data rights, can be sent to guillaume.rozand@icloud.com.