Privacy Policy – Sleeping Beagle

Effective Date: 2 September 2025

Entity: SC PRODCOM DROBETA SRL ("Sleeping Beagle", "we", "our", or "us")

Jurisdiction: Romania, EU law applies

1. Introduction

This Privacy Policy explains how Sleeping Beagle collects, uses, stores, and shares personal data when you use our services ("Service"). We are committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR), the ePrivacy Directive, and the California Consumer Privacy Act (CCPA/CPRA).

You must be at least 18 years old to use our Service. We do not knowingly collect or process information from minors.

2. Data We Collect

(a) Account Data

Name, email address, and password (hashed).
Authentication tokens (for session continuity).
Optional: login via Google SSO.

(b) Billing Data

Billing details (via Polar, our Merchant of Record).
We receive payment-related webhooks (confirmation of purchase, subscription status) to provide access to the Service.
We do not store or process full credit card information.

(c) Uploaded Assets & Generated Content

Photos, product images, videos, prompts, and edits you provide.
Stored until account deletion or up to 6 months after subscription ends, whichever comes first.

(d) Technical & Analytics Data

Usage analytics (via PostHog).
Service diagnostics and error logs (via Sentry).
Infrastructure logs (via Cloudflare, PlanetScale).

3. How We Use Your Data

To provide and maintain the Service (contract basis).
To process payments via Polar (legal obligation & contract).
To personalize features and improve the Service (legitimate interest).
To monitor for fraud, abuse, and security breaches.
To comply with legal obligations.

4. AI Processing

Uploaded assets and prompts may be processed by Gemini and OpenRouter solely for the purpose of generating outputs.
We do not train our own models on customer data.
To the best of our knowledge, our providers process inputs solely for inference, not training.

5. Data Retention

Uploaded assets and generated outputs → kept during subscription and for 6 months after cancellation.
Account data (email, password hash) → deleted upon account deletion.
Billing records → kept only as long as legally required by tax/accounting laws, then securely deleted or archived.

6. Data Sharing and International Transfers

We share data with carefully selected processors to run the Service:

Polar (billing & payments – EU)
Cloudflare (infrastructure/CDN/Workers/R2 storage – US transfer)
PlanetScale (database hosting – US transfer)
PostHog (analytics – EU/US depending on cluster)
Sentry (error tracking – US transfer)
Gemini (AI inference – US transfer)
OpenRouter (AI inference – US transfer)

Whenever data is transferred outside the EU/EEA, we rely on Standard Contractual Clauses or equivalent safeguards.

7. Your Rights

Under GDPR (EU/EEA)

Right of access (Art. 15)
Right to rectification (Art. 16)
Right to erasure (Art. 17)
Right to data portability (Art. 20)
Right to restrict or object (Art. 18 & 21)
Right to withdraw consent (Art. 7(3))

Under CCPA/CPRA (California)

Right to know the personal information collected and its use.
Right to deletion.
Right to opt out of sale or sharing of personal information (we do not sell data).
Right to non-discrimination for exercising privacy rights.

8. Exercising Your Rights

Sleeping Beagle provides a self-serve account deletion option in the dashboard.
For other requests (e.g., access, portability), contact us at privacy@sleepingbeagle.app.
We may verify your identity before fulfilling requests.

9. Security

We implement reasonable organizational and technical measures (encryption, access controls, monitoring) to protect data. However, no online system is 100% secure, and we cannot guarantee absolute security.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with a revised "Last Updated" date. Material changes may be notified via the Service.

11. Contact

For privacy matters, you can contact:

Email: privacy@sleepingbeagle.app

Entity: SC PRODCOM DROBETA SRL

Jurisdiction: Romania