SnooNews

PRIVACY POLICY

Effective Date: March 27, 2026

This Privacy Policy ("Policy") describes how Snoonews LLC ("Company," "we," "us," or "our") collects, uses, discloses, retains, and otherwise processes personal information about users ("you" or "User") of the SnooNews mobile application (the "App") available at www.snoonews.com and any related services, features, or content (collectively, the "Services"). By downloading, accessing, or using the App, you acknowledge that you have read, understood, and agree to be bound by this Policy. IF YOU DO NOT AGREE TO THIS POLICY IN ITS ENTIRETY, YOU MUST IMMEDIATELY DISCONTINUE USE OF THE APP AND DELETE IT FROM YOUR DEVICE.

1. SCOPE AND APPLICABILITY

This Policy applies to all Users of the App worldwide. Our primary market is the United States, including residents of New Jersey, California, Virginia, Colorado, Connecticut, Texas, and all other U.S. states with applicable privacy laws. Where international users access the App, additional rights under laws such as the GDPR (EEA/UK) may apply as described below.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

• Account registration data: name, email address, username, and hashed password.

• Sign-in data: if you use Apple Sign-In or Google Sign-In, we receive authentication tokens and, where permitted, your name and email address.

• Payment information: billing name, address, and payment details, processed exclusively by PCI-DSS compliant third-party processors (e.g., Stripe, RevenueCat). We do not store raw payment card data.

• Communications: messages, feedback, support requests, and survey responses you send to us.

• Content preferences: news topic categories, narrator preferences, ambient sound selections, and language settings you choose within the App.

2.2 Information Collected Automatically When you use the App, we and our third-party service providers automatically collect the following:

• Device identifiers: IDFA (Apple), Google Advertising ID (GAID), device model, OS version, and unique device identifiers.

• Audio playback and listening data: which sleepcast audio tracks you play, playback duration, skip events, completion rates, content categories listened to, and session timestamps. We do not collect biometric data, sleep sensor data, or health-related measurements.

• Usage and navigation data: features accessed, in-app navigation paths, tap events, and session activity.

• Log data: IP address, app version, crash logs, error reports, and request timestamps.

• Coarse location: city or region level derived from IP address only. We do not collect precise GPS location.

• Cookies and similar technologies: as described in Section 6.

2.3 Information from Third Parties

• Apple Sign-In / Google Sign-In: authentication and basic profile data as permitted by the respective platform.

• Analytics providers: aggregated behavioral and engagement data (e.g., Firebase, Amplitude).

• News content APIs and aggregators: publicly available news headlines, summaries, and metadata used solely for sleepcast content generation. No personal user data is shared with news providers.

• Payment processors: transaction confirmation and fraud screening results.

• AI and text-to-speech providers: we use multiple third-party AI providers to generate audio content. These providers process content prompts only; we do not share personal user identifiers with AI providers.

• Advertising networks (if/when ads are activated): device identifiers and listening behavior data, subject to your opt-out rights described in Section 10. 2.4 What We Do NOT Collect We do not collect: biometric data, sleep sensor readings, health or medical data, precise GPS location, or any data from minors under the age of 18. Audio playback data is behavioral usage data only and is not classified as health information.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

• Service delivery: to create and manage your account, generate personalized AI-driven sleepcast audio, deliver news summaries, and provide customer support.

• Personalization: to tailor content categories, narrator selections, ambient sounds, and recommendations based on your listening history and stated preferences.

• Free vs. paid tier management: to enforce content restrictions on the free tier and unlock full access for paid subscribers.

• Analytics and product improvement: to understand App usage, identify technical issues, measure feature engagement, and develop new features.

• Advertising (if/when activated): to serve generic or interest-based advertisements to free-tier users. We will provide advance notice before activating any advertising data sharing. You may opt out at any time as described in Section 10.

• Marketing communications: to send promotional emails, in-app messages, and push notifications about new features, content, or offers, subject to your opt-in consent where required by applicable law, including CAN-SPAM and CASL.

• Safety and fraud prevention: to detect and prevent unauthorized access, fraudulent transactions, abuse, and security threats.

• Legal compliance: to comply with applicable law, respond to lawful government requests, enforce our Terms of Service, and protect the rights, property, and safety of the Company and our Users.

• Business transfers: as described in Section 5.4.

We will not use your information for purposes materially different from those described in this Policy without prior notice and, where required, your consent.

4. LEGAL BASIS FOR PROCESSING (EEA/UK USERS)

If you are located in the EEA or UK, our processing relies on the following lawful grounds under GDPR and UK GDPR:

• Contract performance (Art. 6(1)(b)): processing necessary to provide the Services you have requested.

• Legitimate interests (Art. 6(1)(f)): analytics, fraud prevention, security, and direct marketing of our own products. You may object at any time.

• Consent (Art. 6(1)(a)): marketing communications, non-essential cookies, and advertising data sharing. Consent is freely withdrawable at any time. • Legal obligation (Art. 6(1)(c)): processing required to comply with applicable law.

5. HOW WE SHARE YOUR INFORMATION

5.1 Service Providers We share data with vetted vendors who perform services on our behalf, including: Google Cloud Platform (hosting and infrastructure), analytics providers (e.g., Firebase, Amplitude), crash reporting tools (e.g., Sentry), payment processors (e.g., Stripe, RevenueCat), multiple AI and text-to-speech providers for audio generation, and email delivery services. All service providers are contractually bound to use your data only as directed by us and to maintain appropriate security standards.

5.2 News Content Providers We use publicly available news APIs and aggregators solely to generate sleepcast content. We do not transmit any personal user identifiers to news content providers.

5.3 Advertising and Analytics Partners We currently operate a freemium model and may activate advertising in the future. If and when advertising is activated, we may share device identifiers and listening behavior data with advertising networks for campaign measurement and interest-based advertising. We will provide advance notice before activating any data sharing for advertising purposes. You may opt out at any time via: iOS: Settings > Privacy & Security > Tracking; Android: Settings > Google > Ads; or by contacting us at privacy@snoonews.com.

5.4 Business Transfers In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all of our assets, your information may be transferred as a business asset. We will notify you prior to any such transfer if your data will be subject to a materially different privacy policy.

5.5 Legal Disclosures We may disclose your information if we believe in good faith that disclosure is necessary to: (a) comply with a legal obligation, subpoena, court order, or government request including under New Jersey law; (b) enforce our Terms of Service; (c) protect the rights, property, or safety of the Company, our Users, or the public; or (d) detect and prevent fraud.

5.6 Aggregated or De-Identified Data We may share aggregated, anonymized, or de-identified data that cannot reasonably identify you, for research, industry analysis, or marketing purposes. 5.7 With Your Consent We may share your information with additional third parties when you have provided explicit prior consent.

5.7 With Your Consent We may share your information with additional third parties when you have provided explicit prior consent.

6. COOKIES AND TRACKING TECHNOLOGIES

The App and www.snoonews.com use cookies, mobile SDKs, pixel tags, and similar technologies. Categories: • Strictly necessary: essential to core App functionality and cannot be disabled.

• Performance/analytics: help us understand App usage. Disabled by default for EEA/UK users pending consent.

• Advertising/targeting: used to deliver relevant advertisements to free-tier users. Disabled by default pending consent and will only be activated with advance notice. You may manage preferences via the in-app settings menu or your device's native privacy controls.

7. DATA RETENTION

• Account data: for the life of your account plus 3 years to resolve disputes and comply with legal obligations.

• Audio listening and usage data: 24 months on an identifiable basis, then anonymized for analytical purposes.

• Payment records: 7 years to comply with federal and New Jersey tax and accounting laws.

• Support communications: 3 years. You may contact us at privacy@snoonews.com to request deletion of your account and personal data. We will process verified deletion requests within 30 days, except where retention is required by applicable law.

8. DATA SECURITY

We implement industry-standard technical and organizational safeguards including AES-256 encryption at rest, TLS 1.2+ encryption in transit, role-based access controls, and a documented incident response plan. All data is hosted on Google Cloud Platform infrastructure. HOWEVER, NO SECURITY SYSTEM IS IMPENETRABLE. WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR INFORMATION. In the event of a data breach that poses a real risk of harm, we will notify you and applicable regulators as required by law, including the New Jersey Identity Theft Prevention Act (N.J.S.A. 56:8-163), which requires notification in the most expedient time possible.

9. CHILDREN'S PRIVACY

The App is intended for users aged 18 and older and is not directed to minors. We do not knowingly collect personal information from any person under the age of 18. In compliance with the Children's Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under 13 under any circumstances. If you believe we have collected information from a minor, please contact us immediately at privacy@snoonews.com.

10. YOUR RIGHTS AND CHOICES

10.1 All Users

• Access and portability: request a copy of the personal information we hold about you.

• Correction: request correction of inaccurate or incomplete data.

• Deletion: request deletion of your account and associated personal data, subject to legal retention obligations.

• Opt-out of marketing emails: unsubscribe via the one-click link in any marketing email or via in-app settings. We will honor opt-outs within 10 business days.

• Opt-out of advertising data sharing: via device settings (iOS Tracking / Android Ads) or by emailing privacy@snoonews.com.

• Push notifications: manage via your device's notification settings at any time.

10.2 New Jersey Residents (NJDPA) Under the New Jersey Data Privacy Act (effective January 15, 2025), NJ residents have the right to: (a) access personal data; (b) correct inaccurate personal data; (c) delete personal data; (d) obtain a portable copy; (e) opt out of targeted advertising, sale of personal data, and profiling. Submit requests to privacy@snoonews.com with subject 'New Jersey Privacy Request.' Response within 45 days.

10.3 California Residents (CCPA/CPRA) California residents have the right to: (a) know what personal information is collected, used, or disclosed; (b) delete personal information; (c) correct inaccurate personal information; (d) opt out of the sale or sharing of personal information; (e) limit use of sensitive personal information; and (f) non-discrimination for exercising privacy rights. Submit requests to privacy@snoonews.com with subject 'California Privacy Request.' Response within 45 days.

10.4 EEA/UK Residents (GDPR/UK GDPR) EEA and UK residents may: access, correct, delete, or port your data; restrict or object to processing; withdraw consent at any time; and lodge a complaint with your local supervisory authority. Contact us at privacy@snoonews.com. Response within 30 days. 10.5 Other U.S. State Residents Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), and other states with comprehensive privacy laws may exercise similar rights by contacting us at privacy@snoonews.com.

11. EMAIL MARKETING COMPLIANCE

• CAN-SPAM Act (U.S.): all marketing emails will clearly identify the sender, include a physical mailing address, contain a clear opt-out mechanism, and honor opt-out requests within 10 business days.

• CASL (Canada): for Canadian users, we will only send commercial electronic messages with your express or implied consent, and will honor unsubscribe requests within 10 business days.

• GDPR/UK GDPR: for EEA/UK users, marketing emails require affirmative opt-in consent, which you may withdraw at any time. You may withdraw consent to marketing communications at any time without affecting your access to the App or its features.

You may withdraw consent to marketing communications at any time without affecting your access to the App or its features.

12. INTERNATIONAL DATA TRANSFERS

We are headquartered in New Jersey, United States. All data is primarily processed and stored on Google Cloud Platform infrastructure in the United States. For EEA/UK users, such transfers are governed by Standard Contractual Clauses (SCCs) approved by the European Commission and the UK International Data Transfer Agreement (IDTA). Copies of applicable transfer mechanisms are available upon request at privacy@snoonews.com.

13. NEW JERSEY DATA PROTECTION ASSESSMENTS

Pursuant to the New Jersey Data Privacy Act, we conduct and maintain Data Protection Assessments prior to engaging in processing activities that present heightened risk, including processing data for targeted advertising, sale of personal data, and profiling activities. These assessments are maintained as internal records and weigh the benefits of processing against potential risks to consumers.

14. THIRD-PARTY LINKS AND SERVICES

The App may reference or link to third-party websites, news sources, or services. We are not responsible for the privacy practices of third parties. We encourage you to review their privacy policies independently.

15. AUTO-RENEWAL DISCLOSURE

Paid subscriptions renew automatically at the end of each billing period. The renewal charge will be processed through your Apple ID or Google Play account at the rate confirmed at the time of purchase. You will receive notice of any price changes at least 30 days in advance. To cancel auto-renewal, visit your Apple ID or Google Play subscription settings at least 24 hours before the end of the current billing period. This disclosure is made in compliance with applicable state automatic renewal laws including New Jersey and California.

16. CHANGES TO THIS POLICY

We may update this Policy periodically. Material changes will be communicated via email, push notification, or in-app notice at least 30 days before taking effect, and will be posted at www.snoonews.com/privacy. Your continued use of the App after the effective date constitutes acceptance. 17. CONTACT US For questions, requests, or concerns about this Policy: Snoonews LLC Privacy Officer: privacy@snoonews.com Website: www.snoonews.com We will acknowledge your request within 5 business days and provide a substantive response within 30 days (45 days for NJ/CA requests)

17. CONTACT US

For questions, requests, or concerns about this Policy: Snoonews LLC Privacy Officer: privacy@snoonews.com Mailing Address: 605 N. Atlantic Ave, Collingswood, NJ 08108 Website: www.snoonews.com We will acknowledge your request within 5 business days and provide a substantive response within 30 days (45 days for NJ/CA requests).

18. DATA PROCESSING AGREEMENTS t

We have executed a Data Processing Amendment (DPA) with Google Cloud Platform, our primary infrastructure provider, as required under GDPR Article 28. This agreement governs how Google Cloud processes personal data on our behalf and ensures appropriate contractual safeguards are in place for any EEA/UK user data stored on Google Cloud infrastructure. Copies of applicable agreements are available upon request at privacy@snoonews.com.