Privacy Policy 

SNUGI AI – PRIVACY POLICY

Last Updated: October 23, 2025

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Introduction

Snugi AI ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard information when you use our platform and interact with Nunu, our AI companion.

By using Snugi AI, you agree to the practices described in this Privacy Policy.

1. Information We Collect

1.1 Information You Provide

When you use Snugi AI, we collect:

• Age bracket: Whether you are 13-17 years old or 18+ (we do NOT collect exact birthdates)

• Messages: The text you send to Nunu during conversations

• Anonymous identifiers: Random session codes to maintain conversation continuity
  
  

1.2 Automatically Collected Information

• Session data: Timestamps and duration of your interactions

• Technical data: Browser type and device information (for security purposes only)

• Crisis indicators: Messages flagged by our safety system as potentially concerning
  
  

1.3 Information We Do NOT Collect

We do NOT collect:

• Your name, email address, or phone number (unless you are a counselor)

• Your precise location or IP address

• Payment information (our service is free)

• Social media profiles or personal identifiers

• Exact age or birthdate
  
  

2. How We Use Your Information

We use your information solely for the following purposes:

2.1 Providing Services

• Maintaining conversation context during your session with Nunu

• Delivering relevant coping skills and emotional support resources

• Improving Nunu's responses over time
  
  

2.2 Safety & Crisis Support

• Detecting messages that indicate potential self-harm or crisis situations

• Alerting authorized counselors when immediate support may be needed

• Tracking patterns of concerning behavior to provide appropriate resources
  
  

2.3 Compliance & Reporting

• Meeting legal obligations under California SB 243 and other applicable laws

• Generating anonymized statistical reports for regulatory compliance

• Maintaining records for safety audits
  
  

3. Information Sharing & Disclosure

3.1 Who Can Access Your Data

Authorized School Counselors:

• Licensed counselors may access crisis-flagged conversations to provide support

• Counselors are bound by professional ethics and mandatory reporting laws

• Access is limited to messages identified as high-risk by our system
  
  

Service Providers:

• We use secure cloud hosting providers to store and process data

• These providers are contractually obligated to protect your information

• They cannot use your data for their own purposes
  
  

3.2 When We Must Share Information

We may disclose information when:

• Required by law or legal process

• Necessary to prevent imminent harm to you or others

• Responding to valid law enforcement requests

• Protecting the rights and safety of Snugi AI and its users
  
  

3.3 What We Never Do

We will NEVER:

• Sell your personal information to third parties

• Share your conversations for advertising purposes

• Use your data for marketing or commercial exploitation

• Provide your information to data brokers
  
  

4. Data Storage & Security

4.1 How We Protect Your Information

• Encryption: All data is encrypted both in transit (HTTPS/TLS) and at rest

• Access controls: Only authorized personnel can access sensitive data

• Regular audits: We conduct security reviews to identify vulnerabilities

• Anonymization: Student data is pseudonymized to protect identity
  
  

4.2 Data Retention

• Conversation history: Typically retained for 30-90 days

• Crisis logs: Retained indefinitely for safety monitoring and counselor review

• Session data: Automatically deleted when you close your browser
  
  

4.3 International Data Transfers

Your data is stored on servers located in the United States and is subject to U.S. privacy laws.

5. Your Privacy Rights

5.1 General Rights

You have the right to:

• Access: Request a copy of the data we have about you

• Correction: Ask us to correct inaccurate information

• Deletion: Request deletion of your data (with exceptions for safety records)

• Opt-out: Stop using Snugi AI at any time
  
  

5.2 California Residents (CCPA/CPRA Rights)

If you are a California resident, you have additional rights:

Right to Know:

• What categories of personal information we collect

• The purposes for which we use your information

• Whether we sell or share your personal information (we don't)

Right to Delete:

• Request deletion of personal information we have collected

• Exceptions apply for legal compliance and safety purposes

Right to Opt-Out:

• We do NOT sell personal information, so there is nothing to opt out of

Right to Non-Discrimination:

• We will not discriminate against you for exercising your privacy rights

How to Exercise Your Rights: Contact us at the information provided in Section 10 below. We will respond within 45 days.

5.3 CalOPPA Compliance

Under the California Online Privacy Protection Act (CalOPPA), we:

• Provide this Privacy Policy prominently on our website

• Describe how we respond to "Do Not Track" signals (we do not track users across sites)

• Allow you to review and request changes to your personal information
  
  

6. Children's Privacy (COPPA Compliance)

Snugi AI is designed for users 13 years of age and older.

We do NOT knowingly collect information from children under 13.

If we discover that we have inadvertently collected information from a child under 13, we will:

• Delete that information immediately

• Notify the child's parent or guardian (if identifiable)

• Terminate that user's access to the platform
  
  

For users aged 13-17:

• We minimize data collection to the absolute minimum necessary

• We do not require email addresses, phone numbers, or account creation

• We encourage parental awareness and involvement
  
  

7. Cookies & Tracking Technologies

7.1 What We Use

• Session storage: Temporary data stored in your browser to remember your conversation (deleted when you close the tab)

• Essential cookies: Required for the platform to function (e.g., age verification)
  
  

7.2 What We Don't Use

We do NOT use:

• Third-party advertising cookies

• Cross-site tracking technologies

• Analytics tools like Google Analytics

• Social media tracking pixels
  
  

7.3 Do Not Track Signals

We respect "Do Not Track" (DNT) browser settings. However, since we don't track users across websites, enabling DNT does not change our practices.

8. Third-Party Services

We use the following third-party services:

Cloud Hosting Provider:

• Purpose: Store and process conversations securely

• Data shared: Encrypted conversation logs, session identifiers

• Privacy policy: Available upon request
  
  

Authentication Service (Counselors Only):

• Purpose: Verify identity of school counselors

• Data shared: Email address and name (counselors only, not students)

• Privacy policy: Governed by the authentication provider

These third parties are contractually prohibited from using your data for their own purposes.

9. Data Breach Notification

In the unlikely event of a data breach that compromises your personal information:

• We will notify affected users within 72 hours of discovery

• We will report the breach to relevant regulatory authorities

• We will provide information on steps you can take to protect yourself

• We will take immediate action to secure the platform and prevent future breaches
  
  

10. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your data:

Email: hello@snugi.io
Website: https://www.snugi.io/contact-us
Response Time: We aim to respond within 5 business days

For privacy-related requests (access, deletion, correction), please include:

• Your approximate date of last use

• The type of request you're making

• Any relevant session or user identifiers (if available)
  
  

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in our practices

• New legal or regulatory requirements

• Improvements to our security measures
  
  

When we make changes:

• We will update the "Last Updated" date at the top of this page

• We will notify users of material changes by prominent notice on our website

• Continued use of Snugi AI after changes constitutes acceptance of the updated policy
  
  

We encourage you to review this Privacy Policy periodically.

12. Legal Basis for Processing (For International Users)

If you are located outside the United States, we process your information based on:

• Consent: You voluntarily use our platform and provide information

• Legitimate interests: Providing mental health support and crisis detection

• Legal obligations: Complying with applicable laws and regulations
  
  

13. Additional State Privacy Rights

Nevada Residents

Nevada residents have the right to opt-out of the sale of personal information. We do not sell personal information.

Virginia, Colorado, Connecticut, and Utah Residents

Residents of these states have rights similar to CCPA, including the right to access, correct, delete, and opt-out of targeted advertising and sale of personal information. We do not engage in targeted advertising or sell personal information.

Summary

What we collect: Anonymous identifiers, conversation logs, age bracket
Why we collect it: To provide support, detect crises, and ensure safety
Who sees it: You, authorized counselors (crisis logs only), our secure systems
Your rights: Access, delete, correct your information
Our promise: We never sell your data or use it for advertising

Your privacy and safety are our top priorities.

This Privacy Policy was last updated on October 23, 2025 and is effective immediately.