Privacy Policy
What we collect, why, who can see it, how long we keep it, and the controls you have over all of it.
- Version
- 2026-09-01.1
- In effect from
- 1 September 2026
- When you accept it
- Accepted when you create an account
Template notice. This policy is a working draft. It must be reviewed against GDPR, UK GDPR, CCPA/CPRA, FERPA and any applicable state health-privacy law before launch.
The short version
- Your check-ins, journal entries and wellness data are private to you by default.
- Nobody — not a coach, not your employer, not your university — sees your individual data unless you switch on sharing for that specific person or scope.
- We do not sell personal information, and we do not use your wellness data to target advertising.
- You can export or delete everything, at any time, from Settings.
1. What we collect
You give us:
- Account details: name, email, date of birth band, time zone, chosen track.
- Wellness entries: Inner Map check-ins, mood and stress logs, habits, breathing and relaxation sessions, S.E.W. sentences, journal entries, transformation and coachability responses.
- Care Circle membership, roles and sharing scopes.
- Podcast activity: listens, saves, episode feedback, topic requests and votes.
- Coaching applications, event RSVPs and anything you write in a session note.
- Community posts and replies.
- Optional health-record data if you turn on the Care add-on (see Section 8).
We collect automatically:
- Device and app version, coarse region, crash diagnostics.
- Product analytics events (screen views, feature use). These carry a pseudonymous identifier, not your entries.
We do not collect precise location in the background, contacts, your camera roll, or the content of anything outside the app.
2. Why we use it (and our legal basis)
| Purpose | Data | Basis (GDPR) |
|---|---|---|
| Provide the Service | Account, entries, activity | Contract |
| Personalise your library, podcast feed and plan | Track, situations, activity | Contract |
| Safety escalation where you have asked for it | Circle signals, check-ins | Vital interests / consent |
| Sponsor reporting (aggregate only) | De-identified counts | Legitimate interests |
| Improve the product | Analytics, crash data | Legitimate interests |
| Marketing email | Email address | Consent |
Wellness and mental-health entries are special category data. We process them only on the basis of your explicit consent, given at signup and again for each sharing scope. You can withdraw either at any time.
3. Who can see what
| Who | Can see | Cannot see |
|---|---|---|
| You | Everything in your account | — |
| A Care Circle member | Only the scopes you switched on for them | Journal text, S.E.W. text, notes, anything outside the scope |
| A coach you booked | What you send them, plus wellness trends you explicitly share | Your journal, your circle data, other clients |
| Your employer or institution | Aggregate counts across a cohort of at least 25 people | Anything individual, ever |
| Our staff | Only what is needed to answer a support request you raised, under access logging | Bulk browsing of entries |
4. Sharing with others
We use processors to run the Service: cloud hosting and databases (Google Firebase), email delivery, payment processing, audio hosting, and error monitoring. They act on our instructions under a data-processing agreement and cannot use your data for their own purposes.
We disclose data to authorities only where legally required, and we will tell you unless the law forbids it.
We may disclose the minimum necessary information to emergency services where we reasonably believe there is an imminent risk to someone's life.
5. International transfers
Data is stored in the region shown in your account settings. Where data moves outside your region we rely on Standard Contractual Clauses or an adequacy decision, and we will name the mechanism on request.
6. How long we keep it
| Data | Retention |
|---|---|
| Account record | While active, then 30 days |
| Wellness entries and journals | Until you delete them, or 30 days after account closure |
| Community posts | Until you delete them |
| Coaching records | 7 years, where professional standards require it |
| Billing records | As required by tax law (commonly 7 years) |
| Analytics events | 26 months |
| Backups | Purged within 90 days |
7. Your rights
Access, correction, deletion, portability, restriction, objection, and the right to withdraw consent — exercisable from Settings → Your data, or by writing to privacy@icare-now.com. We respond within 30 days. You may complain to your local supervisory authority.
Export produces a machine-readable archive of everything you have written.
8. The Care add-on
If you turn on Care, you can record medications, doses, glucose readings, vitals and appointments. This data is held under stricter rules than anything else in the product: it is readable only by your own account. It is not visible to coaches, not visible to Care Circle members, and not included in any Sponsor reporting. Turning the add-on off stops collection; deleting it removes the records.
9. Children and young people
Members aged 13–15 are supported only inside a Care Circle with verifiable guardian consent. For those accounts we minimise collection, disable community posting by default, and never show behavioural recommendations based on sensitive inferences. See the Guardian Consent Terms.
10. Security
Encryption in transit and at rest; least-privilege access with audit logging; per-user isolation enforced at the database rule layer, not only in application code; regular third-party penetration testing. No system is perfectly secure — we will notify you and the relevant regulator without undue delay if a breach affects you.
11. Changes
Material changes get 30 days' notice and a fresh consent prompt.
12. Contact
privacy@icare-now.com — Data Protection Officer, iCare Now.