Privacy Policy-Snowie AI
Snowie AI is an artificial intelligence–powered relationship assistance service operated by Heartware AI Co., Limited (“Snowie”, “we”, “us”, or “our”). Snowie provides tools that analyze user-provided interactions to generate insights related to communication patterns, emotional context, and relationship dynamics.
This Privacy Policy describes how we collect, use, store, disclose, and otherwise process personal data when you access or use our website, applications, and integrations with third-party messaging platforms (including, but not limited to, WhatsApp and Telegram) where Snowie determines the purposes and means of processing such data, and therefore acts as a data controller (the “Services”). This includes both individual consumer use and access provided through Snowie’s commercial offerings to organizations and their end users.
This Privacy Policy does not apply in circumstances where Snowie processes personal data solely on behalf of, and under the instructions of, a third-party organization (for example, where access to Snowie is provisioned by an employer or through a third-party application). In such cases, that organization is the data controller, and its privacy practices will govern the processing of your personal data.
Additional information regarding the development, training, and improvement of our artificial intelligence systems—including the potential use of data obtained from third-party sources or submitted by users in accordance with applicable safeguards—is addressed in our Non-User Privacy Policy.
This Privacy Policy further outlines the rights available to individuals with respect to their personal data, as well as the mechanisms through which such rights may be exercised.
Supplemental disclosures may apply to individuals located in certain jurisdictions in order to address specific legal or regulatory requirements.
1. Collection of Personal Data
We collect personal data that you choose to provide when using Snowie, as well as information generated through your interaction with the Services.
Account and Identification Information
When you register or access Snowie, we may collect basic account details such as your email address, phone number (including when using messaging platforms like WhatsApp or Telegram), and system-generated user identifiers necessary to operate your account.
Subscription and Payment Information
If you subscribe to paid features, payment-related information is processed through our payment providers. We may retain limited transaction records for billing, accounting, and compliance purposes.
Content You Submit for Analysis
Snowie is designed to analyze real interactions. As such, we collect the content you choose to share with us, including messages, conversation excerpts, screenshots, or other materials submitted for insight generation. This may include personal data about you or other individuals referenced in those interactions.
AI-Generated Content and Interaction Records
As part of providing the Services, Snowie generates responses, summaries, and relationship insights based on your inputs. We store relevant interaction history to maintain continuity, improve accuracy, and support features such as emotional tracking and pattern recognition.
Relationship Profile Data
You may organize interactions by creating profiles for different individuals (e.g., partner, friend, family member). Information associated with each profile is collected and used to preserve context and prevent overlap between different relationship analyses.
User Feedback
If you provide evaluations, comments, or suggestions regarding Snowie’s outputs or features, we may collect this information together with the related interaction context to improve system performance and user experience.
Support and Communications
When you contact us for support or inquiries, we collect the information you provide, including contact details and the content of your communication.
Personal Data Collected Automatically
When you use Snowie, certain information is collected automatically to support the operation, performance, and security of the Services (“Technical Data”).
Device and Access Information When you access Snowie through our website or messaging platforms (such as WhatsApp or Telegram), we may receive technical details about your device and connection. This can include device type, operating system, browser type, IP address, general location inferred from your IP, network provider, and time zone settings. This information helps us ensure compatibility, maintain security, and deliver a stable experience across platforms.
Service Interaction Data We collect information about how you engage with Snowie, such as when you access the Services, which features you use (e.g., chat analysis, relationship insights, profile management), and general interaction patterns. This allows us to improve feature performance, understand usage trends, and refine the quality of insights generated by Snowie.
System Performance and Error Data To maintain reliability, we collect diagnostic information when the Services are used. This may include system logs, performance metrics, and error reports (e.g., time of error, feature in use, and system state). Where necessary, limited interaction data may be associated with such events to identify and resolve technical issues.
Cookies and Similar Technologies On our website and web-based interfaces, we use cookies and similar technologies to operate core functionality, remember user preferences, and analyze usage patterns. These technologies help us improve usability, measure performance, and maintain security. You can manage your cookie preferences through your browser settings or as described in our Cookie Policy.
Data Used to Improve and Develop Our Systems
Snowie may use certain data to improve the performance, accuracy, and safety of its AI systems. This may include the following categories of information:
Publicly Available Information We may incorporate publicly available data to improve general language understanding and ensure Snowie can interpret a wide range of communication styles and contexts.
Licensed or Third-Party Data Sources Where appropriate, we may use datasets obtained through lawful commercial or research arrangements to enhance system capabilities, provided such use complies with applicable data protection requirements.
User Interactions with Snowie We may use interactions with the Services—including messages, submitted content, and generated responses—to to improve system quality, unless such use is restricted by applicable settings or legal requirements. Where possible, such data is processed in aggregated or de-identified form.
User Feedback and Evaluations Feedback provided by users, including ratings, corrections, or suggestions, may be used to refine system behavior, improve output relevance, and enhance overall user experience.
Safety and Policy Review Data Content that is flagged or reviewed for safety, misuse prevention, or policy enforcement may be used to strengthen Snowie’s ability to detect harmful patterns (such as manipulation or abusive communication) and improve system safeguards.
Internally Generated Data We may generate synthetic or internally derived data to test, evaluate, and improve system performance without relying solely on user-provided content.
2. Purposes for Processing Personal Data
We process personal data only where permitted under applicable data protection laws, and for the following purposes:
Service Delivery and Functionality To operate, deliver, and maintain Snowie’s core features, including conversation analysis, emotional insights, relationship tracking, and profile-based interactions.
Account Management To create, manage, and administer user accounts, including authentication, access control, and account-related communications.
Personalization and Contextualization To tailor outputs and insights based on your interactions, preferences, and Relationship Profiles, ensuring that different relationships remain contextually distinct and relevant.
Payments and Subscription Management To process payments, manage subscriptions, and maintain related financial records in connection with Snowie’s paid services.
User Communications To communicate with you regarding service updates, feature changes, support responses, and other relevant information related to your use of Snowie.
Safety, Security, and Misuse Prevention To detect, prevent, and respond to harmful or abusive use of the Services, including identifying manipulation patterns, enforcing platform policies, and protecting users and system integrity.
Legal and Compliance Obligations To comply with applicable laws, regulations, legal processes, and enforceable governmental requests, and to protect the rights, property, and safety of Snowie, its users, and third parties.
Dispute Resolution and Enforcement To investigate, manage, and resolve disputes, enforce our Terms of Service, and address violations of our policies.
System Integrity and Debugging To monitor performance, identify technical issues, and maintain the reliability and functionality of the Services.
Product Improvement and Research To improve Snowie’s features, enhance accuracy, and develop new capabilities, including through analysis of usage patterns and system performance.
Use of Interaction Data for System Improvement
We may use user interactions, including submitted content and generated outputs, to improve the quality and performance of Snowie’s systems, subject to applicable safeguards.
Where possible, such data is processed in aggregated or de-identified form.
Even where users limit certain data uses through available controls, we may still process relevant data in limited circumstances, including:
where content is reviewed to detect or prevent harmful, abusive, or manipulative behavior (e.g., safety or policy enforcement), or
where users voluntarily submit content as part of feedback, reporting, or support requests
3. Disclosure of Personal Data
We do not sell your personal data. However, we may disclose personal data to third parties in the following circumstances, where necessary to operate our Services and comply with legal obligations:
Group Entities and Affiliates
We may share personal data within Heartware AI Co., Limited and its affiliated entities to support internal operations, product development, and service delivery.
Service Providers and Infrastructure Partners
We engage third-party vendors to support the operation of Snowie, including cloud hosting, data storage, payment processing, analytics, and customer support. These providers process personal data on our behalf and are contractually required to safeguard it.
Platform Integrations
Snowie operates through third-party messaging platforms such as WhatsApp and Telegram. When you interact with Snowie through these platforms, certain data is transmitted through those services and is subject to their respective privacy policies. Snowie does not control how these third parties process your data outside of our integration.
Corporate Transactions
In the event of a merger, acquisition, financing, reorganization, or sale of assets, personal data may be transferred as part of the transaction, subject to applicable confidentiality and data protection requirements.
Legal and Regulatory Disclosures
We may disclose personal data where required to do so by law, regulation, legal process, or governmental request. We may also disclose information where necessary to:
comply with legal obligations,
enforce our Terms of Service or other agreements,
detect, prevent, or address fraud, security, or technical issues, or
protect the rights, safety, or property of Snowie, our users, or others.
Protection and Safety
We may disclose personal data where we believe it is necessary to prevent harm, including in situations involving abusive or harmful behavior identified through use of the Services.
User-Directed Disclosure
We may share personal data where you explicitly request or consent to such disclosure, including when using features that involve sharing insights or outputs with others.
4. Your Rights and Controls
Depending on your location and applicable data protection laws, you may have certain rights in relation to your personal data. These rights are not absolute and may be subject to legal or technical limitations. Snowie will assess and respond to requests in accordance with applicable laws.
To exercise your rights, you or your authorized representative may contact us at:privacy@snowie-ai.comWe may require verification of your identity before processing your request. Where permitted by law, we may decline or limit requests where necessary (for example, to comply with legal obligations or protect system integrity). Snowie will not discriminate against you for exercising your rights.
Your Rights May Include:
Right to Access You may request information about the personal data we hold about you, including how it is used and disclosed.
Right to Data Portability Where applicable, you may request a copy of your personal data in a structured, commonly used format.
Right to Deletion You may request deletion of your personal data, subject to certain exceptions (for example, where retention is required for legal, security, or operational purposes). You may also delete your conversation history or account, which will remove associated data in accordance with our retention practices.
Right to Correction You may request correction of inaccurate or incomplete personal data we maintain about you. Please note that Snowie generates AI-based outputs, and while we aim for accuracy, we cannot guarantee that all generated content will be factually correct.
Right to Object or Restrict Processing You may have the right to object to or request restriction of certain types of processing, including where processing is based on legitimate interests, subject to applicable law.
Right to Withdraw Consent Where we rely on your consent to process personal data, you may withdraw that consent at any time. This will not affect the lawfulness of processing prior to withdrawal.
Use of Data for Improvement
Where permitted, Snowie may use interaction data to improve system performance. You may have options to limit certain uses of your data, depending on your settings or applicable law.
Automated Processing
Snowie uses AI systems to generate insights and recommendations. However, Snowie does not make decisions that produce legal or similarly significant effects solely through automated processing.
Marketing Preferences
Snowie does not sell your personal data. Where we send service-related or optional communications, you may opt out or adjust your preferences at any time.
Managing Your Data
We provide tools within the Services that allow you to manage your data, including:
managing Relationship Profiles
deleting conversations
adjusting account settings
Additional controls may be made available over time as we continue to improve the platform.
5. International Data Transfers
Due to the global nature of Snowie’s Services, your personal data may be processed in jurisdictions outside of your country of residence, including in countries that may not provide an equivalent level of data protection.
This may occur, for example, when you use Snowie through our website, web application, or messaging platforms (such as WhatsApp or Telegram), or where data is processed by our infrastructure providers and partners operating in multiple regions.
GDPR Compliance and Transfer Safeguards
Where Snowie processes personal data subject to the General Data Protection Regulation (GDPR), we implement appropriate safeguards to ensure that international transfers meet the requirements set out under applicable law.
These safeguards include:
Adequacy Decisions (Article 45 GDPR) Where personal data is transferred to jurisdictions recognized by the European Commission as providing an adequate level of data protection, Snowie relies on such adequacy decisions.
Standard Contractual Clauses (Article 46 GDPR) For transfers to countries without an adequacy determination, Snowie enters into legally approved transfer mechanisms, including Standard Contractual Clauses (SCCs), with relevant service providers and partners to ensure that your personal data is protected.
Supplementary Measures Where necessary, Snowie implements additional technical and organizational safeguards—such as data minimization, encryption, and access controls—to enhance the level of protection for transferred data.
Derogations Under Applicable Law In limited circumstances, Snowie may rely on permitted derogations under GDPR (such as where a transfer is necessary for the performance of a contract or based on your explicit consent).
Snowie is committed to handling personal data in accordance with GDPR principles, including lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, and integrity and confidentiality.
We continuously review our data transfer practices to ensure compliance with evolving regulatory requirements across the jurisdictions in which we operate.
6. Data Retention, Lifecycle Management, and Security
Snowie retains personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, including providing the Services, maintaining account functionality, improving system performance, and complying with legal and regulatory obligations.
Data Retention and Deletion
The retention period for different types of data may vary depending on their purpose and legal requirements. When personal data is no longer needed, Snowie will take appropriate steps to securely delete, anonymize, or otherwise dispose of such data in accordance with applicable laws.
Users may also request deletion of their data or remove certain content (such as conversations or Relationship Profiles) through available controls within the Services, subject to technical and legal limitations.
Use of Aggregated and De-Identified Data
Snowie may process data in aggregated or de-identified form for purposes such as improving service quality, understanding usage patterns, and enhancing system performance.
For example:
Interaction data may be separated from direct identifiers and analyzed to improve the relevance and accuracy of insights
Feedback and usage patterns may be aggregated to evaluate feature effectiveness and user experience
Data associated with safety or policy review may be processed in a de-identified manner to strengthen detection of harmful or abusive patterns
Such information does not identify individual users and is used in a manner consistent with applicable data protection laws.
Data Lifecycle Management
Snowie applies internal controls throughout the data lifecycle—from collection to storage, use, and deletion—to ensure that personal data is handled responsibly. This includes limiting access to data based on role, minimizing the amount of data retained, and regularly reviewing retention practices.
Security Measures
We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration. These measures include:
Encryption of data in transit and, where appropriate, at rest
Access controls and authentication mechanisms
Monitoring systems to detect and respond to potential security incidents
Secure infrastructure provided by trusted service partners
While we take reasonable steps to protect your data, no system can be guaranteed to be completely secure.
7. Children’s Privacy
Snowie is not intended for use by individuals under the age of 18, and we do not knowingly collect or process personal data from minors.
If we become aware that personal data has been provided by an individual under the age of 18, we will take reasonable steps to investigate and, where appropriate, delete such information in accordance with applicable laws.
If you believe that a minor has provided personal data to Snowie, please contact us at: 📩 privacy@snowie-ai.com
8. Updates to This Privacy Policy
We may revise this Privacy Policy from time to time to reflect changes in our Services, legal requirements, or data practices.
Where updates are material, we will take appropriate steps to inform users, which may include in-product notifications or updates on our website. The “Effective Date” at the top of this Privacy Policy will indicate when the latest version takes effect.
We encourage you to review this Privacy Policy periodically to stay informed about how we handle your personal data.
9. Contact Information
Snowie AI is operated by Heartware AI Co., Limited (“Snowie”, “we”, “us”, or “our”).
For the purposes of applicable data protection laws, Snowie acts as the data controller in relation to your personal data, unless otherwise stated.
If you have any questions about this Privacy Policy, or wish to exercise your data protection rights, you may contact us at:
📩 Email: privacy@snowie-ai.com 🌐 Website: snowie-ai.com
Regional Information
Depending on your location, you may have the right to contact or lodge a complaint with your local data protection authority.
If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the right to lodge a complaint with your local supervisory authority.
If you are located in Brazil, you may contact the Brazilian Data Protection Authority (ANPD).
If you are located in Australia, you may contact the Office of the Australian Information Commissioner (OAIC).
If you are located in other jurisdictions, you may contact your local data protection or privacy regulator where applicable.
We encourage you to contact us first so we can address your concerns directly.
10. Legal Basis for Processing
Snowie processes personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR). The legal basis we rely on depends on the specific way your data is used within the Services.
Performance of a Contract (Core Snowie Functionality)
We process personal data where it is necessary to deliver Snowie’s core experience as your AI relationship copilot.
This includes:
analyzing conversations and chat content to generate relationship insights
identifying communication dynamics, including potential red flags such as manipulation or PUA-related behaviors
maintaining separate Relationship Profiles so different people in your life are not mixed
generating emotional summaries, conflict analysis, and personalized guidance
managing your account, access, and subscription
Without this processing, Snowie would not be able to provide its core functionality.
Legitimate Interests (Improving Emotional Intelligence Systems)
We process personal data where it is reasonably necessary to improve Snowie, provided your rights are respected.
These interests include:
improving the accuracy of emotional and relationship analysis
strengthening detection of unhealthy interaction patterns (e.g., gaslighting, control dynamics, emotional imbalance)
refining features such as trigger identification, conflict repair suggestions, and communication guidance
ensuring platform safety, preventing misuse, and maintaining system integrity
understanding how users interact with Snowie to improve product design and experience
Because Snowie works with highly sensitive interpersonal data, we apply additional safeguards and minimize identifiable data wherever possible.
Consent (User-Controlled Sharing)
In certain situations, we rely on your consent.
This applies when:
you choose to upload or share conversations, screenshots, or sensitive personal content for analysis
you provide feedback, ratings, or additional context voluntarily
specific permissions are required (e.g., certain tracking technologies)
You remain in control of what you choose to share with Snowie, and you may withdraw consent at any time where applicable.
Legal Obligations
We may process personal data where required to comply with legal or regulatory obligations, including:
responding to lawful requests from authorities
complying with financial, tax, or reporting requirements
enforcing our Terms of Service and protecting legal rights
Safety and Responsible AI Processing
Given the nature of Snowie’s Services, certain processing is necessary to maintain a safe and responsible environment.
This includes:
reviewing content that may indicate harmful or abusive behavior
improving detection systems for manipulation, coercion, or emotional harm
enforcing platform policies and protecting users from misuse
This processing is conducted with strict safeguards and only where necessary.
点击图片可查看完整电子表格
11. Sensitive Data and Relationship Information
Snowie is designed to analyze real human interactions. As a result, the information you choose to share may include content that is considered sensitive in nature, such as personal communications, emotional experiences, or details about your relationships with others.
User-Controlled Sharing
Snowie does not access your personal conversations unless you actively choose to provide them. You remain in control of what content is shared with the Services, including messages, screenshots, and contextual information about individuals in your life.
Purpose-Limited Processing
Sensitive information is processed solely for the purpose of providing Snowie’s core functionality, including:
generating relationship insights and emotional summaries
identifying communication patterns and potential areas of concern
supporting features such as conflict analysis, trigger detection, and repair guidance
Snowie does not use this information for unrelated purposes such as advertising.
Minimization and Separation
We apply data minimization principles when processing sensitive content. Where possible:
data is limited to what is necessary to generate relevant insights
Relationship Profiles are used to keep information about different individuals separate
identifiable data is reduced or de-linked when used for system improvement
Safety and Responsible Use
Given the potential for sensitive or harmful dynamics in relationship data, Snowie implements safeguards to:
detect patterns associated with harmful or manipulative behavior
prevent misuse of the Services
ensure outputs are generated in a responsible and supportive manner
Confidentiality and Protection
We treat relationship-related content with a high level of confidentiality and apply technical and organizational safeguards to protect it from unauthorized access, disclosure, or misuse.
User Expectations and Transparency
Snowie is built around trust. We aim to ensure that users understand:
what data is being used
why it is being used
and how it contributes to the insights provided
12. Regional Supplemental Disclosures
Supplemental Disclosures for Residents of Canada
This section provides additional information for individuals located in Canada and should be read together with the rest of this Privacy Policy. In the event of any inconsistency, this section will apply to the extent required by applicable Canadian laws.
Consent
Snowie primarily relies on your consent to collect, use, and process your personal data, except where otherwise permitted or required by law.
By using Snowie or providing your personal data, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your information as described herein.
Given the nature of Snowie’s Services—such as analyzing conversations and generating relationship insights—your consent may be:
Express, for example when you actively submit messages, screenshots, or other content for analysis
Implied, based on your continued use of the Services in circumstances where such consent is appropriate under applicable law
You may withdraw your consent at any time, subject to legal or contractual limitations and reasonable notice. Please note that withdrawing consent may limit or prevent your ability to use certain features of Snowie.
Cross-Border Data Transfers
Snowie operates on a global infrastructure. As a result, your personal data may be processed or stored outside of Canada, including in jurisdictions such as the United States or other countries where our service providers operate.
By using Snowie, you acknowledge that your data may be transferred to and processed in these jurisdictions, where data protection laws may differ from those in Canada.
We take appropriate measures to ensure that your personal data remains protected in accordance with applicable laws, including through contractual safeguards and responsible data handling practices.
In certain cases, personal data may be disclosed to foreign authorities where required by applicable laws or legal processes.
Contact
If you have any questions about how Snowie processes your personal data, or if you wish to exercise your rights, please contact us at: privacy@snowie-ai.com
Supplemental Disclosures for Residents of Brazil
This section provides additional information for individuals located in Brazil and should be read together with the rest of this Privacy Policy. In the event of any conflict between this section and the main Privacy Policy, this section will prevail to the extent required under the Brazilian General Data Protection Law (LGPD).
Legal Bases for Processing
Depending on the purpose of processing, Snowie may rely on different legal grounds as permitted under LGPD.
These may include, for example:
performance of a contract, where processing is necessary to provide Snowie’s core services (such as conversation analysis and relationship insights)
consent, where you choose to provide data voluntarily (such as submitting conversations or feedback)
legitimate interests, where processing is necessary to improve service quality, enhance safety features, or prevent misuse
exercise of legal rights, including where processing is required to handle user complaints, resolve disputes, or enforce our Terms of Service and platform policies
Your Rights Under LGPD
Under LGPD, you have certain rights regarding your personal data. Snowie will respond to such requests in accordance with applicable law.
These rights include:
Confirmation of Processing You have the right to request confirmation of whether we process your personal data.
Access to Your Data You may request information about the personal data we hold about you.
Correction of Data You may request correction of incomplete, inaccurate, or outdated personal data.
Anonymization, Blocking, or Deletion You may request that data that is unnecessary, excessive, or processed in violation of applicable law be anonymized, blocked, or deleted.
Data Portability You may request the transfer of your personal data to another service provider, subject to applicable limitations and protection of trade secrets.
Information on Data Sharing You may request information about the public or private entities with which we have shared your data.
Information About Consent You may request information about the possibility of denying consent and the consequences of such denial, where applicable.
Withdrawal of Consent You may withdraw your consent at any time. Such withdrawal will be processed free of charge, subject to legal or operational limitations.
Review of Automated Decisions You may request a review of decisions made solely based on automated processing that affect your interests.
Please note that these rights are not absolute. In certain circumstances, Snowie may retain or continue to process personal data where required to comply with legal or regulatory obligations, protect rights, or defend against claims.
International Data Transfers
Snowie operates on a global infrastructure. As a result, your personal data may be transferred to and processed in countries outside of Brazil, including jurisdictions that may not offer the same level of data protection.
Such transfers may occur when:
you use Snowie through its web platform or messaging integrations (e.g., WhatsApp or Telegram)
data is processed by our service providers located in other regions
Where required under LGPD, Snowie adopts appropriate safeguards for international transfers, including the use of Standard Contractual Clauses (SCCs) or equivalent mechanisms approved by the Brazilian Data Protection Authority (ANPD).
These measures are designed to ensure that your personal data continues to receive an adequate level of protection, even when transferred internationally.