Version 3 - September 2026

Effective date: 28 September 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.

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, first name and email address
• Age or date-of-birth information, and sex where requested
• Country or general location
• Profile and onboarding information, including profile photo where provided
• Bone-health condition, fracture history and other health conditions you choose to record
• DEXA scan information and historical results
• Official FRAX results entered by you
• Information used to generate or display a general Risk Estimate, including relevant lifestyle questions and the height and weight used for it
• Height and weight records
• Medication and supplement information
• Nutrition and daily-intake information, targets and dietary preferences
• Exercise, activity, movement and mobility information
• Wellness, breathing and meditation activity, including wellness-session streaks
• Falls, sleep, stress and mood check-ins where available
• Learning-pathway activity and progress
• Goals, outcomes and self-reported wellbeing information
• Bone Buddy conversations and information used to personalise Bone Buddy replies
• Phone number where provided for an expert-support or consultation request
• Coaching, expert-support and consultation requests
• Feedback, testimonials and customer-support communications
• Consent, notification 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, fracture history, other conditions, height and weight history, activity, nutrition, wellness 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.

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 where you have given the required permission
• 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 processing personal information. Depending on the activity, we process information where it is necessary to perform our contract with you, to comply with legal obligations, for our legitimate interests where those interests are not overridden by your rights, or with your consent where consent is appropriate.

Where we process special category health information, an additional condition under Article 9 of the UK GDPR is required. Where SNAP Life relies on explicit consent for a particular use of health information - including the sharing of relevant information with OpenAI for Bone Buddy where applicable - we request that consent through a clear affirmative choice. You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

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

7. Bone Buddy and OpenAI

Bone Buddy is an AI-supported educational and wellness companion. 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.

Who receives your data

Bone Buddy's replies are generated by OpenAI, L.L.C., a technology provider based in the United States that processes this information on SNAP Life's behalf. We ask for your permission in the app before Bone Buddy sends anything to OpenAI. If you do not give permission, Bone Buddy is unavailable and nothing is sent; the rest of SNAP Life works as normal.

What is sent

When you use Bone Buddy we send OpenAI your messages to Bone Buddy and the information you have recorded in SNAP Life that Bone Buddy uses to personalise its reply:

• Your first name, age and sex
• Your bone-health condition
• Your DEXA results, official FRAX results and Risk Estimate, including the height and weight used for it
• Your nutrition intake and targets, supplements and dietary preferences
• Your activity
• Your wellness sessions and mood check-ins

If you have turned on the daily Bone Buddy nudge, we also send your first name and wellness-session streak to write that message.

We do not send your email address, password or payment details.

How it is used and protected

OpenAI uses this information only to generate Bone Buddy's replies for SNAP Life. Under OpenAI's API terms it does not use it to train its models, and it may keep it for up to 30 days to detect abuse before deleting it. OpenAI processes the information under a data processing agreement that requires protection equal to that described in this Policy.

Withdrawing permission

You can withdraw your permission at any time in Profile → Privacy & Data. Nothing further is sent to OpenAI after that.

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.

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.

10. Sharing Personal Information

We do not sell personal information.

We may share personal information with service providers where necessary to operate SNAP Life. These may include:

• Authentication and identity providers
• Cloud hosting and database providers
• AI service providers (currently OpenAI)
• 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.

11. Data Storage and International Transfers

SNAP Life's core application data is stored in the United Kingdom. Some technology providers may process personal information outside the United Kingdom or the country in which you live. In particular, information sent to OpenAI for Bone Buddy is processed by OpenAI, L.L.C. in the United States as described in section 7.

Where UK data-protection law requires safeguards for an international transfer, SNAP Life will use an appropriate lawful transfer mechanism and contractual safeguards applicable to the relevant transfer. You may contact us for further information about safeguards relevant to your personal information.

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.

• Account, health, wellness and Bone Buddy data: kept while your account is active and deleted within 30 days of account deletion.
• Purchase and subscription records: kept for 6 years for UK tax and accounting requirements.
• Emails and support requests: kept while your account is active, then deleted with the account.
• OpenAI processing for Bone Buddy: OpenAI may retain information for up to 30 days for abuse detection before deletion, as described in section 7.
• Backups: overwritten on the relevant provider's normal backup cycle.

Where information must be retained for a legal obligation, dispute or other lawful reason, we may retain the minimum information necessary for that purpose for the required period. When information is no longer required, we delete it, anonymise it or place it beyond ordinary use in accordance with our retention and backup processes.

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.

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.

Right to object

Where we process personal information on the basis of legitimate interests, you may have the right to object to that processing. You always have the right to object to processing for direct marketing.

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.

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 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 provide an appropriate choice mechanism. Website cookie information may also be provided in a separate Cookie Policy or consent interface.

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 disclosures reflect the service-provider arrangements used by SNAP Life and will be updated where required as those arrangements or launch markets change.

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 at the beginning of this Policy shows 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.

24. SNAP Life Brand and Intellectual Property

SNAP Life and associated SNAP Life product and service names, branding, designs and original content are the property of SNAP Life Ltd except where otherwise stated. Third-party names, trademarks, products and services referred to in this Policy remain the property of their respective owners. References to third-party services do not transfer any ownership or intellectual-property rights to SNAP Life.

© 2026 SNAP Life Ltd. All rights reserved.