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Privacy Policy

Last updated: 9 May 2026

Version: 1.1.0 (Corporate Transition)

This Privacy Policy describes how JackiePoot Creations Ltd ("we," "us," or "our") collects, uses, and shares your information when you use the Cuppi mobile application (the "App").

1. OUR PRIVACY PHILOSOPHY

We believe your data belongs to you. Our App is designed with a "Local-First" approach, meaning we aim to process as much data as possible on your device rather than on our servers.

2. WHAT DATA WE COLLECT

A. Personal Data You Provide

  • Account Information: When you register, we collect your email address and username.
  • Subscription Data: Purchases are handled by the Apple App Store. We receive confirmation of your subscription status and an anonymous transaction ID to prevent fraud, but we do not see or store your credit card numbers or billing address.
  • Authentication Data: If you enable 2-Step Verification, we process this via a standard authenticator app (TOTP). We do not collect or store your phone number for this purpose.

B. App Data (Cloud Sync) To provide features like the Household Feed and multi-device syncing, the following data is encrypted in transit and synced to our secure servers located in the United Kingdom:

  • Household names, unique Household IDs, and member lists.
  • Budget entries, transaction titles, and household income/salary configurations.
  • Receipt scans, itemised lists, and categorised spending.
  • Pet profiles, including medication logs, vaccination history, microchip numbers, and veterinary health plan details.
  • Shared notes or calendar entries created within the App.

C. Automated Assistant Data ("The Companion") The "Companion" is an automated feature that aggregates your household data (like birthdays, bin days, and pet medications) to generate helpful reminders. This relies on deterministic code, not generative AI. We do not use your household data to train any machine learning models.

D. Anonymous Usage Data (Analytics) To help us improve Cuppi, we collect anonymous analytics regarding how you navigate the app. This contains no personally identifiable information. You can opt out at any time via the Privacy section in your Security Centre.

3. HOW WE USE YOUR INFORMATION

We use your information solely to:

  • Provide and maintain the Services.
  • Synchronize your data across your logged-in devices.
  • Generate automated household insights and notifications.
  • Manage your account, verify subscription status, and provide customer support.

We process your data based on:

  • Contractual Necessity: To sync your data and manage your subscription.
  • Legitimate Interests: To secure the app, prevent fraud, and improve the user experience.
  • Consent: For anonymous analytics (Adult users only).

4. SHARING YOUR INFORMATION

We do not sell your data. We only share information in the following limited circumstances:

  • Google (Firebase/Google Cloud): Data storage and authentication. Data is stored on servers located in the United Kingdom.
  • Apple Inc.: App Store processing and subscription management.
  • Legal Requirements: If required by UK law or to protect our legal rights.

5. DATA STORAGE AND SECURITY

  • Location: Your synced data is stored on secure servers located in the United Kingdom.
  • Encryption: We use industry-standard encryption (SSL/TLS) during transfer. Local caches on your device utilize iOS system-level File Protection, meaning they are encrypted at rest when your device is locked.
  • Retention: We keep your data as long as your account is active. If you delete your account, your profile and cloud data are securely deleted from our active servers.

6. YOUR RIGHTS (UK GDPR)

As a UK resident, you have the right to:

  • Access/Correction: Request a copy of or fix your data.
  • Deletion: Request that we delete your account (initiated directly within the App).
  • Restriction/Objection: Object to our processing or ask us to restrict it.
  • Portability: Request a transfer of your data.

7. DATA CONTROLLER & CONTACT US

For the purposes of UK data protection law, the Data Controller responsible for your personal data is:

JackiePoot Creations Ltd Company Number: 17206871

Registered Office: 124 City Road, London, EC1V 2NX, United Kingdom

Email: support@cuppi.co.uk

ICO Registration Number: ZC143045

8. YOUR RIGHT TO COMPLAIN

If you feel we have not resolved a concern, you have the right to complain to the Information Commissioner's Office (ICO): Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline: 0303 123 1113 | Website: www.ico.org.uk