August 2026

This Privacy Policy explains how SNAP Life Ltd ("SNAP Life", "we", "our" or "us") collects, uses, shares, stores and protects personal information when you use the SNAP Life website, mobile application and associated services.

SNAP Life is a digital bone-health, healthy-ageing and wellbeing platform. It provides educational content, wellness support, tracking tools, AI-supported wellness functionality, coaching access and related features. SNAP Life is not a healthcare provider and does not provide medical diagnosis or treatment.

Pre-launch confirmation required: This draft updates the June 2026 policy to reflect the current product. Final AI provider/subprocessor names, processing locations, retention periods, international-transfer safeguards and the final Article 6/Article 9 lawful-basis position must be confirmed from the developer due-diligence exercise and professional privacy review before publication.

1. Who We Are

SNAP Life Ltd is responsible for deciding how and why personal information is processed through the SNAP Life platform and acts as the data controller where applicable.

• Company: SNAP Life Ltd
• Privacy contact: teamsnap@snaplife.co.uk
• Website: www.snaplife.co.uk

If a Data Protection Officer, EU/EEA representative or other privacy representative becomes legally required, the relevant contact details will be added to this Policy.

2. Who Can Use SNAP Life

SNAP Life is intended for adults aged 18 and over. We do not knowingly provide accounts to, or intentionally collect personal information from, anyone under 18. If we become aware that information has been collected from a person under 18 contrary to this Policy, we will take appropriate steps to delete it.

3. Information We Collect

Information you provide

• Name and email address
• Age or date-of-birth information where requested
• Country or general location
• Profile and onboarding information
• Bone-health information
• DEXA scan information and historical results
• Official FRAX results entered by you
• Information used to generate or display a general Risk Estimate
• Height and weight records
• Medication and supplement information
• Nutrition and daily-intake information
• Exercise, activity, movement and mobility information
• Wellness, breathing and meditation activity
• Learning-pathway activity and progress
• Goals, outcomes and self-reported wellbeing information
• Bone Buddy conversations and information you choose to submit to Bone Buddy
• Coaching, expert-support and consultation requests
• Feedback, testimonials and customer-support communications
• Consent and privacy-preference records

Information collected automatically

• Device and operating-system information
• App version and technical identifiers
• IP address and approximate technical location information
• Feature usage and engagement events
• Learning and wellness session events, such as starts and completions, where enabled
• Diagnostic information, error logs and crash reports
• Notification and preference events
• Security and authentication events

Subscription information

• Subscription tier and status
• Trial eligibility/status
• Transaction or purchase identifiers
• Purchase and renewal history supplied by the relevant payment platform

Payment card details are processed by authorised payment providers or app-store platforms and are not intended to be stored directly by SNAP Life.

4. Health Information and Special Category Data

Some information processed through SNAP Life may reveal information about your health and may therefore constitute special category personal data under UK data-protection law. This can include DEXA and FRAX information, medication, supplements, bone-health status, height and weight history, activity, nutrition and other health or wellbeing information you choose to record.

We use this information only for defined SNAP Life purposes such as providing requested tracking functionality, personalising the user experience, generating user-facing wellness insights, supporting Bone Buddy functionality, and producing permitted aggregated Community Insights.

SNAP Life does not use this information to provide a medical diagnosis, prescribe treatment or make clinical decisions on your behalf.

Pre-launch confirmation required: SNAP Life must document the final Article 6 lawful basis and separate Article 9 condition for each special-category processing purpose before launch. The current working assumption should not be treated as final legal sign-off.

5. How We Use Personal Information

• Create, authenticate and manage your account
• Provide the features and services you request
• Record and display bone-health and wellness information over time
• Personalise educational and wellness experiences
• Provide Bone Buddy AI functionality
• Provide Learning Pathways, Wellness Lounge, movement and nutrition functionality
• Display user-entered DEXA and official FRAX history and other longitudinal insights
• Provide general Risk Estimate functionality where available
• Manage subscriptions, trials and access entitlements
• Send service messages, reminders and notifications you have enabled
• Facilitate coaching and expert-support requests
• Respond to customer-support and privacy requests
• Maintain security, detect abuse and troubleshoot technical problems
• Measure product performance and understand feature engagement
• Develop and improve SNAP Life
• Produce aggregated Community Insights where permitted and subject to applicable privacy controls
• Meet legal, regulatory, accounting and dispute-resolution obligations

6. Legal Bases for Processing

Under UK data-protection law, SNAP Life must have an appropriate lawful basis for each processing purpose. Depending on the activity, this may include processing necessary to perform our contract with you, compliance with legal obligations, legitimate interests, or consent where consent is appropriate.

Where we process special category health information, we must also identify a separate condition under Article 9 of the UK GDPR. Where we rely on explicit consent for a particular use of health information, that consent will be requested through a clear affirmative statement and can be withdrawn in accordance with applicable law.

Where we rely on legitimate interests, we will consider the impact on your rights and interests and will not rely on that basis where your interests or fundamental rights override ours.

Pre-launch confirmation required: Insert the final purpose-by-purpose lawful-basis table after privacy/legal review. Do not publish a generic list of possible bases without confirming which basis applies to which purpose.

7. Bone Buddy AI

Bone Buddy is an AI-supported educational and wellness companion. It may use information you provide in a conversation and, where the product is configured to do so, relevant information you have recorded elsewhere in SNAP Life to provide a more contextual response.

Bone Buddy is not a doctor, clinician or healthcare professional. It does not diagnose conditions, prescribe treatment or replace advice from a qualified healthcare professional. AI-generated information can be incomplete or inaccurate and should not be relied upon for medical decisions.

Information used to operate Bone Buddy may be transmitted to third-party AI service providers acting as technology providers to SNAP Life. We will provide transparent information about the relevant provider(s), categories of data shared, processing locations, retention arrangements and applicable safeguards once the final production architecture is confirmed.

Individual Bone Buddy conversation content is not intended to be included in Community Insights or partner-level aggregated reporting. Limited technical or engagement events may be retained where necessary to operate, secure and improve the service, subject to this Policy.

Pre-launch confirmation required: Developer to confirm final AI provider/model, data fields transmitted, training-use setting, retention, subprocessors, geographic processing and contractual safeguards.

8. DEXA, FRAX and Risk Estimate Data

SNAP Life allows users to record and track bone-health information over time. This may include DEXA scan results and official FRAX results obtained from an external or clinical source and entered by the user.

Where SNAP Life provides a general Risk Estimate, it is separate from an official FRAX assessment. A Risk Estimate generated within SNAP Life is intended for educational and informational purposes and is not represented as an official FRAX result, diagnosis or clinical assessment.

Unless expressly stated otherwise, health information entered into SNAP Life is self-reported and is not independently verified by SNAP Life.

9. Community Insights, Analytics and Research

SNAP Life may use permitted information to understand how the platform is used, improve features and generate aggregated Community Insights. Community Insights are intended to show patterns at group level rather than expose information about an identifiable individual.

For internal aggregated Community Insights, SNAP Life currently applies a minimum reporting cohort of 10 participants and suppression controls intended to reduce the risk that an individual can be identified through small groups or combinations of filters.

Individual Bone Buddy conversation content is excluded from Community Insights. Users who have opted out of an applicable optional data use should be excluded in accordance with their recorded preference and the relevant processing rules.

Any future external research collaboration, partner dataset, publication or materially different use of health information will be subject to separate governance, privacy and, where required, consent and ethical/regulatory review before that use begins.

Pre-launch confirmation required: Final Community Insights consent/opt-out model and the legal basis for each analytics/research purpose must be confirmed in the DPIA and governance documentation.

10. Sharing Personal Information

We do not sell personal information.

We may share personal information with service providers where necessary to operate SNAP Life. Depending on the final production architecture, these may include:

• Authentication and identity providers
• Cloud hosting and database providers
• AI service providers
• Analytics, diagnostics and crash-reporting providers
• Email and communications providers
• Notification providers
• Subscription, app-store and payment providers
• Customer-support or operational service providers
• Professional advisers where necessary for legal, regulatory, accounting, security or compliance purposes

Coaching and expert services

Where you request coaching, nutrition, consultant or other expert support, information necessary to facilitate that request may be shared with the relevant professional. Where an expert provides a service independently, they may act as a separate data controller for information they collect or process in connection with their professional service. Their own privacy terms may also apply.

Legal and safety requirements

We may disclose information where required by law, court order or regulatory obligation, or where reasonably necessary to establish, exercise or defend legal rights, protect the security of SNAP Life, or address fraud or misuse.

Pre-launch confirmation required: Add the final named subprocessor/service-provider schedule or a maintained link once developer due diligence confirms the production stack.

11. International Data Transfers

SNAP Life is intended to be available internationally and some technology providers may process personal information outside the United Kingdom or the country in which you live.

Where UK data-protection law requires safeguards for an international transfer, SNAP Life will use an appropriate lawful transfer mechanism, such as applicable adequacy regulations, the UK International Data Transfer Agreement or UK Addendum to approved Standard Contractual Clauses, as appropriate to the transfer.

You may contact us for further information about the safeguards relevant to your personal information.

Pre-launch confirmation required: Developer due diligence must confirm the actual countries/regions used by hosting, database, authentication, analytics, email, AI, backups and other subprocessors before this section is finalised.

12. Data Retention

We keep personal information only for as long as necessary for the purpose for which it was collected, to provide the service, comply with legal and accounting obligations, resolve disputes, maintain security and enforce agreements.

Retention periods may differ depending on the category of information. When information is no longer required, we will delete it, anonymise it, or place it beyond ordinary use in accordance with our retention and backup processes.

Account deletion may not immediately remove information from encrypted backups where immediate deletion is technically impracticable. Any such backup information will remain protected and will be removed or overwritten in accordance with the applicable backup-retention cycle, unless retention is required by law.

Pre-launch confirmation required: Insert final retention periods/criteria for account data, health records, Bone Buddy conversations, analytics/events, support records, transaction records, logs and backups after the retention schedule is approved.

13. Data Security

SNAP Life uses administrative, technical and organisational measures designed to protect personal information against unauthorised access, loss, alteration, disclosure or misuse. These measures may include access controls, authentication, encryption, logging, secure hosting and backup arrangements, depending on the relevant system.

No online service can guarantee absolute security. Users should protect their account credentials and notify SNAP Life if they suspect unauthorised access.

Pre-launch confirmation required: Final wording should be checked against the developer security return, including encryption at rest/in transit, MFA, secret management, backup/restore testing and vulnerability/security testing.

14. Your Privacy Choices and Rights

Depending on applicable law and the circumstances, you may have rights to:

• Access personal information we hold about you
• Correct inaccurate or incomplete information
• Request deletion of personal information
• Request restriction of processing
• Object to certain processing
• Receive certain information in a portable format
• Withdraw consent where processing is based on consent
• Object to direct marketing at any time
• Lodge a complaint with the relevant data-protection regulator

Where you withdraw consent, this does not affect the lawfulness of processing carried out before withdrawal. Some rights are not absolute and may depend on the lawful basis and circumstances of the processing.

To exercise a privacy right, contact teamsnap@snaplife.co.uk. We may need to verify your identity before completing a request.

15. Automated Processing and Profiling

SNAP Life uses software and AI to personalise content, generate wellness responses, display trends and provide informational outputs such as a general Risk Estimate. These features are not intended to make solely automated decisions that produce legal or similarly significant effects on users.

SNAP Life does not intend to use Bone Buddy or the Risk Estimate to determine eligibility for healthcare, insurance, employment, credit or other significant rights or benefits.

Pre-launch confirmation required: Developer to confirm there is no solely automated decision-making with legal or similarly significant effects and document the logic/inputs of Risk Estimate and any material profiling.

16. Marketing Communications

Where permitted by law, SNAP Life may send educational updates, product news, wellness content or promotional communications. Where consent is required, we will request it before sending those communications.

You can unsubscribe from marketing emails using the unsubscribe option in the communication or by contacting us. Service and transactional communications necessary to operate your account may still be sent.

17. Cookies, Analytics and Similar Technologies

The SNAP Life website and app may use cookies, SDKs, device identifiers, analytics technologies and similar tools to provide functionality, maintain security, understand usage and improve the service.

Where applicable law requires consent for non-essential cookies or similar technologies, we will provide an appropriate choice mechanism. Website cookie information may also be provided in a separate Cookie Policy or consent interface.

Pre-launch confirmation required: Confirm final website/app analytics and advertising SDKs. Cookie/SDK consent must reflect the actual technologies in production.

18. App Stores and Subscription Providers

If you download SNAP Life or purchase a subscription through an app store, the relevant store provider may process information independently under its own privacy terms. SNAP Life receives limited subscription and transaction information needed to manage access and customer support, but does not receive your full payment-card details from the app store.

19. California and Other International Privacy Rights

Users in certain jurisdictions may have additional privacy rights under local law. Where those laws apply to SNAP Life, we will honour applicable rights and provide any additional notices required.

SNAP Life does not sell personal information. The meaning of terms such as "sale" or "sharing" may vary under local privacy laws; our final disclosures will reflect the production analytics, advertising and service-provider arrangements actually used.

Pre-launch confirmation required: US/global privacy obligations should be reviewed against actual launch markets, user volumes and production SDKs before final publication.

20. Complaints

If you have a concern about how SNAP Life uses your personal information, please contact us first at teamsnap@snaplife.co.uk so that we can try to resolve it.

If you are in the United Kingdom, you may also have the right to complain to the Information Commissioner's Office (ICO). Users elsewhere may have the right to contact their local data-protection or privacy regulator.

21. Changes to This Privacy Policy

We may update this Privacy Policy as SNAP Life develops, our technology providers change, or legal and regulatory requirements evolve. Material changes will be communicated where required. The effective date will show when the latest version applies.

22. Contact Us

• SNAP Life Ltd
• Email: teamsnap@snaplife.co.uk
• Website: www.snaplife.co.uk

23. Medical and Wellness Notice

SNAP Life provides educational, informational, wellness and lifestyle support. SNAP Life, Bone Buddy, tracking tools, Risk Estimate functionality, educational content, coaching access and expert-support features are not intended to diagnose, treat, cure or prevent disease and are not a substitute for professional medical advice.

Official FRAX results recorded in SNAP Life are user-entered results obtained from an external or clinical source. Any separate Risk Estimate generated within SNAP Life is not an official FRAX assessment or clinical diagnosis.

Always seek advice from an appropriately qualified healthcare professional regarding symptoms, diagnoses, medication, treatment or healthcare decisions. In an emergency, contact the appropriate emergency service immediately.