Privacy Policy

Healthy Thinking Wellness Ltd ("Healthy Thinking", "we", "us" or "our") provides the Healthy Thinking self-management programme and app.

We are registered in Scotland under company number SC891947. Our registered office is 36 Kirk Street, Edinburgh, EH6 5EZ.

For the purposes described in this policy, Healthy Thinking Wellness Ltd is the controller of the personal data held in individual Healthy Thinking accounts. This means that we decide why and how that information is used.

Our ICO registration reference is ZC174912.

Questions about this policy or our use of personal data can be sent to hellohealthythinking@gmail.com or to our registered office.

This policy applies to adults who create an account, take part in a Healthy Thinking programme or pilot, communicate with us, or otherwise use the Healthy Thinking app.

Healthy Thinking is intended for people aged 18 and over. We do not knowingly collect personal data from anyone under 18.

Where an employer, university or another organisation arranges access to Healthy Thinking, that organisation may process information separately for its own purposes, such as inviting people to participate or administering a pilot. Its own privacy information applies to that processing.

We collect only the information we reasonably need to provide, secure, evaluate and improve Healthy Thinking. The lawful basis depends on the information and the purpose for which it is used.

Account and contact information

What this includes: Your name, email address, account identifier and information needed to create and manage your account.

Why we use it: To create and manage your account, provide access to the programme, communicate with you about the service and respond to account queries.

Lawful basis: Performance of our contract with you and our legitimate interests in operating the service and communicating with users.

Programme and health information

What this includes: Information you choose to provide during onboarding, assessments, daily check-ins and reflections. This may include information about perimenopause or menopause, physical symptoms, sleep, fatigue, stress, emotional wellbeing, lifestyle factors, alcohol, personal stressors, regulators, progress and content preferences. It also includes health-related patterns or insights generated from your responses.

Why we use it: To personalise your programme, select relevant content, provide your check-ins and reports, show your progress and support the self-management features you choose to use.

Lawful basis: Performance of our contract with you under Article 6(1)(b) UK GDPR. Because this information includes special-category health data, we also rely on your explicit consent under Article 9(2)(a) UK GDPR.

Providing health information is optional. You do not have to answer every question. If you provide less information, some personalisation, reports or other features may be limited or unavailable.

Technical and security information

What this includes: Your IP address, device type, browser, operating system, login and authentication records, timestamps, security events, diagnostic information and similar technical data.

Why we use it: To keep accounts and systems secure, prevent misuse, diagnose faults and maintain the availability and performance of the app.

Lawful basis: Our legitimate interests in providing a secure and reliable service and, where applicable, compliance with legal obligations.

Usage information

What this includes: Information about how you use the app, such as logins, completed activities, features used and programme engagement.

Why we use it: To deliver the programme, understand whether features are working, evaluate engagement and improve the service.

Lawful basis: Performance of our contract with you and our legitimate interests in evaluating and improving Healthy Thinking. Where usage information reveals or is combined with health information, we also rely on your explicit consent for that special-category processing.

Messages, feedback and complaints

What this includes: Correspondence you send us, feedback you choose to provide and information connected with a question, complaint or rights request.

Why we use it: To respond to you, investigate concerns, improve the service, establish what was agreed and meet our legal responsibilities.

Lawful basis: Performance of our contract with you, our legitimate interests in managing the service and resolving concerns, and compliance with legal obligations.

Consent and compliance records

What this includes: Records of the privacy information shown to you, the consents you gave or withdrew, and actions taken in response to data-protection requests.

Why we use it: To respect your choices and demonstrate compliance with data-protection law.

Lawful basis: Compliance with our legal obligations and our legitimate interests in keeping appropriate compliance records.

Most information is collected directly from you when you create an account, complete onboarding, use assessments or check-ins, take part in programme activities, provide feedback or contact us.

Technical, security and usage information is collected automatically when you use the app.

A commissioning organisation may provide limited account or eligibility information where this is necessary to arrange your access. Where possible, participants will be invited to register directly so that the commissioning organisation does not need to give us personal information.

If your employer, university or another organisation has commissioned Healthy Thinking, it does not receive access to your individual account, responses, health information, reports or progress data as part of operating or reporting on the programme.

A commissioning organisation may receive aggregated and anonymised information about the group, such as overall participation or general patterns. We do not report separately on groups of fewer than 25 people. We also consider the nature of the information and the risk of identification before releasing any report. We may combine categories, suppress results or withhold a report where a person could otherwise reasonably be identified.

We would disclose identifiable information to a commissioning organisation only if you specifically asked us to do so, or where disclosure was required by law. We do not provide identifiable participant information for employment monitoring, performance management or employment decisions.

Healthy Thinking does not currently use artificial intelligence or machine learning to analyse your identifiable personal or health information, make predictions about you, or generate personalised advice or content.

The app does use rules-based automated processing. For example, information you provide may be used automatically to personalise your programme, select relevant content, calculate progress measures and generate reports or reflections for you. These functions follow predefined rules.

This processing is not used to make decisions that have legal or similarly significant effects on you. Your employer, university or commissioning organisation does not receive the individual results of this processing.

We do not use identifiable personal or health information to train third-party AI models, and we do not permit third-party AI providers to use it for their own model training.

We may in future use information that has first been effectively anonymised, so that individuals can no longer reasonably be identified, to identify general patterns, evaluate and improve Healthy Thinking, develop programme content or support research.

Before introducing any future use of AI involving identifiable personal information, we will assess the data-protection risks, review the suppliers and safeguards involved, and update this policy. We will explain what information is used, the purpose of the processing, how it may affect you and the choices and rights available to you. Where consent or another specific safeguard is legally required, it will be put in place before the processing begins.

We will not use solely automated processing to make decisions about you that have legal or similarly significant effects unless this is permitted by law and the required safeguards are in place, including human review where applicable.

We may use programme information to evaluate and improve Healthy Thinking. Where this involves identifiable health information, we use it only for the purposes covered by your explicit consent and the information given to you when that consent is requested.

We may create aggregated and anonymised statistics from personal information. Anonymisation itself is carried out under the lawful bases applicable to the underlying information. Once information has been effectively anonymised so that no person can reasonably be identified, it is no longer personal data under UK GDPR.

Anonymous information may be retained and used to evaluate the programme, identify population-level patterns, improve content and interventions, and support planning or policy development. It may also be shared with commissioning organisations or research partners, subject to appropriate controls against re-identification.

If a university or another partner undertakes a formal research study involving identifiable or pseudonymised participant information, participants will receive separate information about that study. Where required, participation and research consent will be requested separately from consent to use the Healthy Thinking service. Choosing not to take part in research will not affect access to the programme unless the programme has been clearly offered as a research study and this has been explained before registration.

We share personal information only where it is necessary to operate Healthy Thinking, meet legal responsibilities or provide a feature you have chosen to use.

Technology providers: Providers that host the app, database and authentication systems, currently including Vercel and Supabase, together with providers used for account emails, security, diagnostics and technical support. These providers act under contractual restrictions and may use information only to provide their services to us.

Professional advisers: Our solicitors, accountants, insurers and other professional advisers where this is reasonably necessary and subject to professional or contractual duties of confidentiality.

Commissioning organisations: Aggregated and anonymised reporting only, as described in section 5. Identifiable participant information is not included in ordinary programme reporting.

Research partners: Anonymous information, or other information where a separate lawful arrangement and appropriate participant information are in place.

Authorities and legal recipients: Regulators, courts, law-enforcement bodies or other recipients where disclosure is required by law or necessary to establish, exercise or defend legal rights.

We do not sell personal information and do not share it with advertisers.

We aim to store core account and programme information in the United Kingdom. However, some technology providers or their subprocessors may process limited personal information in other countries, for example when providing support, security, email or infrastructure services.

Where personal information is transferred outside the UK, we will ensure that an appropriate safeguard is in place as required by UK data-protection law. Depending on the destination, this may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful safeguard. Further information about relevant safeguards is available on request.

We use proportionate technical and organisational measures to protect personal information. These include encryption in transit, appropriate protection of stored data, access controls, authentication, supplier controls, backups and procedures for responding to security incidents.

Access to identifiable participant information is restricted to people and service providers who need it for an authorised purpose. They are required to protect its confidentiality.

No online system can be guaranteed to be completely secure. We regularly review risks and take reasonable steps to prevent unauthorised access, loss, alteration or disclosure.

Because Healthy Thinking processes special-category health information, we carry out appropriate privacy and security assessments, including a Data Protection Impact Assessment where required.

If we become aware of a personal data breach, we will investigate it and assess the potential risk to affected people as quickly as reasonably possible.

Where required by law, we will notify the Information Commissioner's Office without undue delay and, where feasible, within 72 hours of becoming aware of the breach. If a breach is likely to create a high risk to your rights and freedoms, we will also inform you without undue delay. We treat any suspected breach involving health information as a high priority.

We keep identifiable account and programme information while you are actively using Healthy Thinking and for up to 12 months after your account is closed or your programme activity ends. This allows us to support a return to the programme, respond to questions and deal with complaints or disputes.

Different information may be kept for a shorter or longer period where reasonably necessary. For example, security logs are retained for an appropriate operational period; complaint, legal and consent records may be retained for as long as needed to demonstrate compliance or deal with a legal claim; and residual copies may remain in protected backups until those backups are overwritten in the ordinary course.

At the end of the relevant retention period, personal information is deleted or effectively anonymised. Information that has been effectively anonymised so that individuals can no longer reasonably be identified may be retained indefinitely for statistical analysis, evaluation, research and service improvement.

Depending on the circumstances, you may have the following rights in relation to your personal information. These rights are not absolute and may be subject to legal exceptions.

Access: To ask for a copy of the personal information we hold about you.

Correction: To ask us to correct inaccurate information or complete information that is incomplete.

Erasure: To ask us to delete personal information where there is no lawful reason for us to keep it.

Restriction: To ask us to limit how we use personal information in certain circumstances.

Objection: To object to processing based on our legitimate interests.

Portability: To receive certain information you provided in a structured, commonly used and machine-readable format, or ask us to transfer it where technically feasible.

Withdraw consent: To withdraw consent at any time where we rely on it. Withdrawal does not affect processing carried out lawfully before consent was withdrawn.

Automated decisions: To obtain the safeguards required by law if you are ever subject to a solely automated decision that has legal or similarly significant effects.

If you withdraw consent to the processing of health information, we will stop using it for consent-based purposes. This may mean that we can no longer provide a personalised programme or some app features. We may retain limited information where this is required by law or needed to demonstrate that consent was withdrawn.

To exercise a right, contact hellohealthythinking@gmail.com. We may need to confirm your identity before acting on a request. We will normally respond within one month, although the law permits additional time for particularly complex requests. We will tell you if this applies.

We currently use only cookies and similar technologies that are necessary to operate the app, maintain security and keep you signed in. We do not currently use advertising cookies or cross-site tracking.

If we introduce optional analytics or other non-essential technologies, we will update our information and request consent where required before using them.

If you are unhappy with how we have used your personal information, please contact us at hellohealthythinking@gmail.com. We would welcome the opportunity to investigate and put things right.

You also have the right to complain to the Information Commissioner's Office. Information about making a complaint is available at www.ico.org.uk. If you live elsewhere in the UK, you may also contact the relevant local ICO office.

We review this policy regularly and will update it when our service, suppliers or use of personal information changes.

If a change materially affects how we use your personal information or your choices, we will give you appropriate notice before it takes effect, for example by email or an in-app notice. Where fresh consent is required, we will request it before beginning the new processing.

Healthy Thinking Wellness Ltd
36 Kirk Street
Edinburgh
EH6 5EZ

Email: hellohealthythinking@gmail.com

ICO registration reference: ZC174912