How HappyMind handles personal data.

1. Controller and contact

Who is responsible for your data

HappyMind Labs Ltd (company number 14537179) is the data controller for the personal data processed through HappyMind. Our registered office is Unit 3b Berol House, 25 Ashley Road, Tottenham Hale, London, United Kingdom, N17 9LJ.

For data-protection and privacy matters, including complaints, contact privacy@happymindlabs.co.uk. We reply to requests and complaints within 30 days. For general product questions, write to info@happymindlabs.co.uk.

2. Data we collect

Information used to deliver the service

• Account details: email, sign-in credentials held by Firebase Authentication, account identifier and name if supplied. The display name is optional in the current experience. The older registration form required a first and last name.
• Your age and terms confirmations, their date and displayed language where recorded. These are separate from your explicit health-data consent. In the current experience, we also store the consent scope, notice version, date, displayed language and account association.
• Questionnaire answers and results, program progress, guided-session content, summaries and work plans (wellbeing information, see section 4)
• Purchase records from Apple or Google Play: product, period, status and a transaction reference, never your payment-card number
• First-party usage events, such as which questionnaire or programme was used or recommended and when. These records exclude your name, email address, account identifier, questionnaire score and conversation text. A programme topic or recommendation can nevertheless reveal information about wellbeing.
• Technical information: IP address, browser/device and app version, request time and status, and error diagnostics. Older Android versions also use installation and notification identifiers (see section 5).
• Support communications and any files or screenshots you choose to send us

3. Why we use data

Processing purposes

• To create and manage your account and deliver HappyMind features
• To personalise exercises, guided sessions and questionnaire feedback using the information you provide
• To keep the app secure, prevent misuse and troubleshoot technical issues
• To provide customer support and billing assistance
• To understand how the product is used and improve it, using the limited first-party usage events described in sections 2 and 5
• To record your account and startup choices and handle privacy requests
• To comply with legal, tax, fraud-prevention and record-keeping obligations

In the current experience, we do not sell personal data or use wellbeing content to target advertising or marketing. Older installations have a different service configuration, described below; this statement does not certify the settings or subsequent uses of legacy third-party services.

4. Sensitive data

Mental wellbeing and related information

HappyMind provides guided self-help for adults aged 18 and over; it is not diagnosis, treatment or a substitute for professional care. Questionnaire answers, conversations, summaries and work plans can reveal sensitive information about your mental wellbeing.

Guided conversations send the context needed for a reply to Google’s Gemini API. This can include the sensitive information you type. We do not add your account email, name or identifier to that request; information you include in your own text can still identify you. Avoid including other people’s personal details.

In the current experience, a separate, initially unchecked consent screen appears before wellbeing questionnaires, guided conversations, personal work plans and related exercises. You can choose not to continue and still use the general information, account and subscription screens. Agreeing to terms or confirming age is not by itself explicit consent to processing health data. In Profile → Privacy you can withdraw consent and delete wellbeing records held in this app while keeping your account and subscription. For older versions, or if the screen is unavailable, contact privacy@happymindlabs.co.uk. Provider records and retention periods are described separately below.

You are interacting with software. Safety checks can interrupt an exercise and show support information, but cannot contact emergency services for you.

5. Sharing and service providers

Who may receive data

The services below receive data for the functions described. App stores and some provider security/account processing operate under those providers’ own terms; not every provider acts only on our instructions.

• Google Firebase and Google Cloud: sign-in, cloud storage, hosting and backend operations. The main database and backend are in the EU; Firebase Authentication processes authentication data in the United States. This is not an EU-only service.
• Google Gemini API: the conversation context needed to generate replies in guided sessions, including wellbeing information you submit.
• Cloudflare email routing and Gmail for support/privacy correspondence; FormSubmit for the website request form. They receive the messages, contact information and attachments you choose to submit.
• Google Fonts on this website; loading a font sends a request from your browser to Google
• Professional advisers, auditors or authorities where disclosure is legally required, or to establish, exercise or defend legal claims
• The Google Play billing component in the Android app may create and send technical diagnostic records to Google when checking billing services. These can include response/error codes and technical messages, together with app and Android versions, device model, language and network type. This processing may also occur when content or Premium access is checked, before you choose to make a purchase.
• Older Android package (version code 10): OneSignal and Firebase Cloud Messaging provide remote notifications. The app initialises OneSignal at startup and links a device identifier. Installation/push identifiers, device and app information, notification interactions and purchase-related information may be processed for delivery, service operation and measurement. Turning off visible notifications does not necessarily stop SDK registration or technical processing. Newer Android 1.6.1 uses local reminders rather than this OneSignal integration.

The older web interface uses Google Tag Manager / Google Analytics to measure page visits, registration, purchase and selected wellbeing topics. Google Analytics derives approximate location, such as city or region, from IP addresses; this does not require GPS permission. This legacy measurement also uses browser or device identifiers to measure advertising conversions.

The older interface also sends page, registration, purchase and test-completion events through Meta's SDK. Meta's terms describe using event data for measurement and for advertising personalisation and delivery. This legacy processing is separate from the current experience described above.

The older contact form sends first name, last name, email, message and Premium status to HubSpot when you submit it, to handle your request. The reviewed current Android package and web interface do not contain these integrations. Updating does not delete records already held by legacy providers.

We use the paid Gemini API. Google’s paid-service terms exclude prompts and responses from general product improvement. Separate abuse monitoring retains prompts, context and responses for 55 days and can involve authorised human review. Processing is not limited to the UK or EU. See Google’s Gemini API terms and abuse-monitoring policy. HappyMind’s saved history is separate from the provider’s records. Gemini API · Abuse monitoring.

Apple and Google Play handle your purchase under their own privacy policies. We receive the purchase record needed to verify and keep your access; we never receive your payment-card number.

We keep a small set of first-party usage events (which feature was used and when) to understand how the product is used. These events carry no name, email address, account identifier, questionnaire score or conversation text. They can include a programme topic or questionnaire-based recommendation, so we do not describe them as free of wellbeing information. A 13-month retention period applies to these events.

6. International transfers

Data hosted outside your country

Your data may be processed outside your country, including in the EU and United States. The EU location of our database does not determine where authentication, AI, notification or email providers process data.

For information about the applicable transfer safeguards, provider arrangements or your rights, contact privacy@happymindlabs.co.uk. This notice does not represent that every service uses the same legal transfer mechanism.

7. Retention

How long we keep information

We keep personal data only as long as it is needed for the purpose it was collected for:

• Account details (email, identifier, display name): while your account exists
• Questionnaire results, session content, summaries and work plans: while the account exists, unless you delete an available item or we complete your deletion/withdrawal request earlier.
• Age/terms confirmations and account preferences: while required for the account or retained on your device. Current health-data consent is kept with the account until withdrawal or account deletion. Minimal withdrawal status, date and revision counters remain until account deletion so an older open screen cannot recreate deleted wellbeing records. We do not operate a separate six-year consent archive.
• Temporary recovery copy of a final free-session response: 30 minutes
• Deletion-tracking record: 7 days after deletion completes
• Limited purchase trace to prevent reuse after account deletion: up to 90 days from the deletion request, without your name, email address or account identifier
• First-party usage events: 13 months
• Support and privacy correspondence: our retention policy is 12 months after closure; payment disputes, refunds or legal matters are reviewed after resolution and may be retained for up to 6 years. This is an operator-managed process, not automatic deletion of every mailbox message.
• In-app subscription and purchase records: used to verify your access while your account exists and removed when account deletion completes, except for the limited purchase trace above. Apple and Google keep their own records under their own privacy policies
• Technical logs under HappyMind’s control: 30 days; a limited audit log that Google keeps for 400 days. This does not set a retention period for technical records sent to Google by the Google Play billing component; the provider’s own retention and deletion terms apply to those records.
• Legacy notification and measurement records are separate from current conversation history. Provider retention and deletion depend on the service; fixed retention periods for all legacy providers have not been verified. You can request identification and deletion of relevant records via our privacy contact.

In-app purchase records are separate from company invoices and payment reports between HappyMind and the app stores. A retention period for company accounting documents does not automatically apply to every record in your HappyMind account.

Deleting data from our systems does not instantly remove copies in our providers' backups, which follow those providers' schedules.

To recover a lost final free-session response after a connection failure, we keep one temporary server-side response record linked to your account, with a protected request digest and an expiry time. This may include sensitive wellbeing content and response state, such as the session summary. It covers the response that ends the free session or reaches its request limit, not intermediate replies. Only the same signed-in account repeating the same request can retrieve it, for 30 minutes after it is stored. Retries do not extend this window. Scheduled cleanup removes the record afterward; outages or a backlog may delay physical deletion, but not extend retrieval. Account deletion also removes this record. This temporary recovery copy is separate from your normal saved conversation history.

In-app account deletion uses a minimal tracking record containing status and timestamps. It contains no email address, conversations, or account details. An unguessable private link permits status-only access without signing in. While deletion is pending, the deletion job references this record. Once complete, the confirmation is accessible for seven days; scheduled cleanup removes it afterward and may be delayed by service outages. The device keeps its tracking link and language preference until you remove the tracking record or clear browser storage. No email or push notification is sent for this in-app confirmation.

8. Your rights

Choices and requests

• Ask whether we process your data and request a copy of it
• Correct inaccurate or incomplete information
• Request deletion, restriction or objection to processing where applicable
• Request export or transfer of your data where legally available
• Use Profile → Privacy in the current experience to withdraw consent and delete questionnaire results, conversations, work plans, cards and programme progress held in the app. Account details and subscription rights stay. Other devices clear their local wellbeing copies when they next connect and check the account; a device that stays offline cannot be cleared remotely. You can also request withdrawal or deletion at privacy@happymindlabs.co.uk, including from an older version. Provider retention is separate; this action does not claim to erase their security records immediately.
• Complain to us first at privacy@happymindlabs.co.uk; we respond within 30 days. You can also complain to the UK Information Commissioner's Office, your local supervisory authority in the EU, or the Personal Data Protection Authority (KVKK) in Türkiye

Send privacy requests to privacy@happymindlabs.co.uk. We aim to respond within the time periods required by law.

To request deletion of your HappyMind account and associated app data through a dedicated web resource, use our account deletion page.

9. Related policies

Other documents

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