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    Privacy Policy - eMoodie Minds

    Introduction

    This policy (together with our Terms of Use) applies to your use of:

    • eMoodie Minds mobile application (App) available for Android and iOS, once you have downloaded or streamed a copy of the App onto your mobile telephone (Device), and any of the services accessible through the App (Services).

    This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

    Important information and who we are

    eMoodie Limited is the data processor and controller for this App (collectively referred to as "Company", "we", "us" or "our" in this policy) and are responsible for your personal data.

    Contact details

    Our full details are:

    • Full name of legal entity: eMoodie Limited (SC681171)
    • Email address: support@emoodie.com
    • Data Protection Officer Details: Johannes Millowitsch, Chief Financial Officer at eMoodie Limited

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues but we would welcome the opportunity to address any of your concerns prior to a complaint being made to the ICO.

    The data we collect about you

    We may collect, use, store and transfer different kinds of personal data about you as follows:

    • Identity Data e.g. first name and last name.
    • Contact Data e.g. email address.
    • Health Data e.g. any information derived from testing or examination of a body part or bodily substance, including voice recordings and symptom data provided during your use of the App. Data information that you enter into the app may be analysed using natural language processing to improve the way our therapeutic exercises are delivered.
    • Device Data e.g. the type of mobile device you use, mobile network information, your mobile operating system, time zone setting. We use this data for the purposes of preparing crash reports and troubleshooting the App.
    • Profile Data e.g. your username and password, your preferences, feedback and survey responses.

    We collect Health Data which is categorised as a Special Category of Personal Data for the purposes of assessing the therapeutic value of the use of the app and better understand digital markers of symptoms. In providing your consent to the installation and use of the App, you provide consent to our use of Health Data for such purposes.

    Data security

    All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. This includes the secure handling of data when processed by third-party service providers (i.e., Microsoft Azure) under contract, with appropriate encryption and data minimisation safeguards in place. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

    Data retention

    In some circumstances you can ask us to delete your data: see 'Your legal rights' below for further information.

    In all circumstances we will anonymise your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.

    In the event that you do not use the App for a period of one year then we will treat the account as expired and your personal data may be deleted.

    Your legal rights

    You have the right to:

    • Request access to your personal data (commonly known as a "data subject access request")
    • Request correction of the personal data that we hold about you
    • Request erasure of your personal data
    • Object to processing of your personal data
    • Request restriction of processing of your personal data
    • Request the transfer of your personal data to you or to a third party
    • Withdraw consent at any time where we are relying on consent to process your personal data

    Additional Information for Organisational Trials, Pilots and Research Programmes

    This section applies where eMoodie Minds is deployed as part of a pilot, research study, service evaluation, or workforce wellbeing programme delivered in partnership with an employer, public authority, university, healthcare provider, or other organisation.

    1. Controller and Processing Roles

    Depending on the structure of the programme:

    • The partnering organisation may act as a Data Controller for the purposes of service evaluation, workforce wellbeing, research, or public interest functions.
    • eMoodie Limited may act as a Data Processor processing data on behalf of that organisation under a formal data processing agreement.
    • In certain circumstances, eMoodie Limited and the partnering organisation may act as Joint Controllers where decisions about the purposes and means of processing are shared.

    The applicable arrangement will be documented in contractual agreements and made available upon request where legally required.

    2. Lawful Basis for Processing

    Where eMoodie Minds is deployed in an organisational or research context, the lawful basis under UK GDPR may include:

    • Article 6(1)(e) - Processing necessary for the performance of a task carried out in the public interest (where the partner is a public authority).
    • Article 6(1)(f) - Legitimate interests pursued by eMoodie or the partner organisation, subject to appropriate safeguards.
    • Article 6(1)(b) - Performance of a contract, where applicable.

    Where processing includes information concerning health or wellbeing, an additional condition under Article 9 UK GDPR will apply, including where relevant:

    • Article 9(2)(h) - Preventative or occupational health purposes.
    • Article 9(2)(j) - Scientific or statistical research purposes, subject to appropriate safeguards.
    • Article 9(2)(a) - Explicit consent, where consent is relied upon.

    Participation in pilots and research programmes is voluntary unless explicitly stated otherwise in contractual arrangements.

    3. Categories of Data Processed

    In organisational and research deployments, we may process:

    • Basic identifying information (e.g., name, email address, role).
    • App usage data and engagement metrics.
    • Self-reported wellbeing responses, mood indicators, burnout measures, and related health information.
    • Device and technical information necessary for service operation.

    4. Service Evaluation and Research Use

    Data collected during pilots or research programmes may be used for:

    • Service evaluation and impact assessment.
    • Product validation, improvement, and algorithm refinement.
    • Generation of aggregated reports for partner organisations.
    • Academic or scientific research purposes, where applicable.

    Individual-level identifiable data will never be shared with employers, line managers, or commissioning organisations. Reporting is only provided in aggregated (i.e., group/organisational level) or anonymised form.

    5. AI and Automated Processing

    eMoodie Minds incorporates algorithmic and AI-assisted systems to provide insights and relevant information.

    • Where third-party AI service providers are used, data processing is governed by contractual safeguards.
    • Data shared with such providers is minimised and protected by appropriate technical and organisational measures.
    • No solely automated decisions are made that produce legal or similarly significant effects without appropriate safeguards.

    6. Data Sharing

    We may share data with:

    • Partner organisations commissioning or participating in the pilot or programme.
    • Independent evaluators or research partners.
    • Secure cloud hosting and technology providers bound by data protection agreements.

    We do not sell personal data.

    7. International Transfers

    If personal data is transferred outside the United Kingdom, we ensure appropriate safeguards are in place, including UK adequacy regulations or approved Standard Contractual Clauses.

    8. Data Retention

    Data collected in pilot or research contexts will be retained only for as long as necessary to fulfil contractual, regulatory, research, and audit obligations. After programme completion, data may be securely deleted or anonymised for research and product improvement purposes.

    9. Participant Rights

    Participants have the right to:

    • Access their personal data.
    • Request rectification of inaccurate data.
    • Request erasure where applicable.
    • Object to processing based on legitimate interests or public task (subject to legal limitations).
    • Lodge a complaint with the Information Commissioner's Office (ICO).

    To exercise your rights, please contact: support@emoodie.com

    10. Employment Safeguards

    Where eMoodie Minds is deployed within an employment context, participation will not be used for individual performance management or disciplinary purposes. Individual wellbeing data is never shared with employers.