HappyMe Privacy Policy

1. Who we are

HappyMe is developed and operated by Happy Solutions Limited, a company registered in the Isle of Man with company number 131430C, whose registered address is Glen Wyllin Lodge, Glen Wyllin, Kirk Michael, IM6 1AN, Isle of Man.

Happy Solutions Limited is the data controller for the personal information you provide to us. This means we determine the purposes for which, and the way in which, your personal information is processed. We are registered with the Isle of Man Information Commissioner (registration number R819352).

Our software is developed and maintained in-house and self-hosted on our own Amazon Web Services account, which means we retain full control over how your personal information is handled and keep the number of third parties involved to a minimum.

2. The information we collect

Information you provide to us

• Email address when you register for an account, contact us, or subscribe to updates. This is the only personal identifier we require.
• Content you choose to enter in optional features such as journaling, mood tracking or exercises. Entering this text is never required for the app to work. It is encrypted on your device before it reaches us (see ‘Sensitive information’ below).
• Self-assessment responses, where you choose to complete a reflective questionnaire (for example about anxiety or burnout). These are reflective tools, not clinical diagnoses.
• Messages you send in the AI chat, if you choose to use it. These are processed to reply to you and are not saved (see ‘AI chat’ below).
• Any information you include when you contact us by email or through our support channels.

Information collected automatically

When you use the app, we automatically collect limited technical data so that the service works and we can fix problems. This may include your device’s IP address, device type and version, your activity within the app, and, if the app encounters an error, technical details about that error. This data is processed on a first-party basis and is not shared with any third-party analytics or advertising provider.

Sensitive (special category) information

Some of the content you may enter in the app relates to your state of mind or mental health. This is ‘special category’ data under data protection law and is given a higher level of protection.

We do not ask for health information for diagnosis or analysis, and we do not analyse or use the content you save for any purpose. It is encrypted on your device before it is saved to our backend, and is decrypted only within the app when you ask to see it again. When our developers view the database they see encrypted text, not what you actually wrote. We rely on your explicit consent to store this content, and entering it is entirely optional.

This applies to content you save in the app. The AI chat works differently, because the AI needs to read your messages to reply to them. See ‘AI chat’ below.

AI chat

HappyMe offers an optional AI chat that helps you check in with how you are feeling, learn about wellbeing topics, and find relevant exercises, episodes and help pages in the app. You are always talking to an AI, not a person. It is not a therapist, counsellor or medical service. It cannot diagnose conditions and is not a substitute for professional advice.

Who can use it

The AI chat is available only to users who selected an age range of 18 or over at registration. Before your first chat, the app explains how the chat works and how your messages are processed, and asks you to agree before anything is sent.

What is processed

When you send a message, the app sends the following to our backend over an encrypted connection:

• the conversation so far (up to the last 12 messages, each limited in length);
• which part of the app you are chatting from.

To make suggestions relevant, our backend also uses information we already hold: the emotion and improvement categories from your most recent check-in, the content you have already completed, the tasks you have done today, and whether you have a subscription. It does not read your journal or other encrypted entries.

How it is processed

Your messages are processed by Amazon Bedrock, a service of Amazon Web Services that we use within our own AWS account. The AI model is Claude, developed by Anthropic, and runs on Amazon Bedrock. Anthropic does not receive your messages. Amazon Bedrock does not store your messages or the AI’s replies, and does not use them to train any AI model. Processing takes place in data centres within the European Union.

What we keep

We do not store your chat messages. They are not saved to our database, file storage or logs, and they are not included in analytics. The conversation exists only on your device while the chat screen is open, and is discarded when you leave it. The only records we keep are:

• a record that you agreed to the AI chat notice, which version of it you agreed to, and when, kept while your account is open;
• a count of how many messages you have sent today, used to apply daily limits, which is deleted automatically after 2 days;
• technical log entries that record outcomes (for example, that a message was answered or that the chat ended for safety reasons), never what you wrote.

Safety measures

The AI chat is designed with these protections:

• Every message you send is checked before the AI replies, by an automated content filter (Amazon Bedrock Guardrails) and by a separate AI safety check. Every reply is checked again before it is shown to you.
• If a message suggests that you or someone else may be at risk of harm (for example, thoughts of suicide or self-harm, abuse, or harm to others), the chat ends and directs you to our What to do in a Crisis page, which lists services that can help. If a safety check cannot be completed, the chat ends and shows the same support.
• If you ask for a diagnosis, or for help with something unrelated to wellbeing or HappyMe, the AI explains what it can help with. If you ask again, the chat ends.
• Attempts to make the AI ignore its instructions end the chat.
• The AI only recommends content from the HappyMe library.
• Daily message limits apply.

These checks are automated and run only during the chat. Ending a chat does not affect your account, your subscription or your access to the rest of the app, and no record is kept of why a chat ended. You can start a new chat at any time.

Reporting a reply

You can report any AI reply you think is harmful, inaccurate or inappropriate. If you do, we store the reply, the message you sent just before it, the reason you chose, any note you add, and your account identifier, so a member of our team can review the report and improve the service. This is the only case where chat text is stored, and only because you chose to send it. The report is held in our database for up to 72 hours while it is transferred to our internal review system, where it is kept for 90 days and then deleted automatically. Because we need to review and act on what was reported, a report already in our review system is kept for the rest of those 90 days even if you delete your account.

Your choices

The AI chat is optional. You can use every other part of HappyMe without it.

Referral source

If you were referred to HappyMe by a partner organisation, we tag your account with that referral source. We use this to recognise the referral and to show you relevant signposting within the app, such as a route back to that organisation’s support. This tag is held by us and is not routinely shared. Where you have been referred by a partner organisation, we may share information about your use of HappyMe with that organisation only where you have consented, or where it is necessary to protect you or someone else from harm (safeguarding).

3. How and why we use your information

We only use your personal information where we have a lawful basis to do so. We use it to:

• provide the app’s core features and secure your account;
• personalise your experience of the app;
• provide the optional AI chat, including its safety checks and content suggestions;
• review AI chat replies you report to us;
• contact and communicate with you, including sending service messages;
• send you marketing emails, where you have opted in;
• keep the service secure and prevent misuse;
• operate, maintain and improve the app using first-party analytics.

Our lawful bases, depending on the feature and how you use it, are:

• Consent – for example to store the optional content you enter, and to send you marketing emails. You can withdraw consent at any time.
• Performance of a contract – to create and operate your account and provide the service you have signed up for.
• Legitimate interests – to keep the service secure, to apply safety checks and daily limits to the AI chat, to review reported AI chat replies, and to understand and improve how the app is used, balanced against your rights.
• Explicit consent (Article 9) – for any health-related content you choose to enter, including anything about your mental health that you choose to share in the AI chat.
• Legal obligation – where we are required to keep certain information, for example financial records.

Automated decision-making

The AI chat uses automated safety checks that can end a conversation. We do not make any decision based solely on automated processing that has a legal or similarly significant effect on you. Ending a chat does not change your account, access or subscription.

4. Who we share your information with

We do not sell your personal information, and we do not use third-party advertising or tracking in the app. We share personal information only with the service providers we rely on to run HappyMe, and only to the extent they need it:

• Amazon Web Services (Ireland) – hosting of our database, application programming interfaces, authentication, storage, backups and transactional email, and AI processing for the optional AI chat through Amazon Bedrock (see ‘AI chat’ in section 2).
• Brevo (France) – sending automated transactional emails and, where you have opted in, marketing emails. Brevo receives your email address. It is the only third party that can access this personal data, and only for the purpose of sending email.
• Google Firebase – delivering push notifications to your device.
• Google Workspace – our internal email and support mailboxes.
• Apple and Google – processing subscription payments made through the App Store or Google Play. We do not receive or store your payment card details.
• Google Analytics – anonymised website analytics only, subject to cookie consent. Google Analytics is not used within the app.

We may also disclose personal information where required by law, to establish or defend legal claims, to protect someone from harm (safeguarding), or in the event that our business is transferred to another owner, in which case any new owner would be bound by this policy.

5. How we keep your information secure

• Encryption in transit: all traffic between the app and our backend is protected with TLS.
• Encryption at rest: our database, storage and backups are encrypted using our hosting provider’s encryption.
• On-device encryption: content you save in the app (journals, mood entries, exercises) is encrypted on your device before it reaches us, so we cannot read it. AI chat messages are protected in transit by TLS but are not encrypted on your device, because the AI must read them to reply. They are never saved (see ‘AI chat’ in section 2).
• Passwordless login: we use a passwordless login, where you receive a code to enter to complete sign-in. Please keep your email account secure, ideally with two-factor authentication, as it is the key to your account.
• Restricted access: access to our systems is tightly restricted, and our internal reporting portal is protected by multi-factor authentication.

No method of electronic transmission or storage is completely secure, but we protect your information using appropriate technical and organisational measures.

6. How long we keep your information

We keep your personal information only for as long as we need it:

• Active accounts: we retain your account information for as long as your account is active.
• Inactive accounts: if your account is inactive for 12 months, we email you to ask you to log in to keep it. If you do not, we permanently delete your account and data 7 days later.
• Deletion on request: you can delete your account at any time from within the app, or request deletion via myhappyme.co.uk/deletion-request. We delete your data immediately on request, and check that any residual data is removed from the third-party services we use. The only exception is any AI chat reply you reported, which is kept in our review system until its 90 days have passed (see ‘AI chat’ in section 2).
• AI chat: chat messages are not stored. Daily message counts are deleted after 2 days. Your agreement to the AI chat notice is kept while your account is open. Replies you report are deleted from our database within 72 hours and from our review system after 90 days, including when you delete your account before then.
• Legal retention: where the law requires it, for example financial or accounting records, we may retain certain information for up to 7 years.

7. International transfers of your information

Your personal information is stored within the European Economic Area, in our hosting provider’s Ireland region. The Isle of Man and the United Kingdom recognise the EEA as providing an adequate level of data protection.

AI chat messages are processed by Amazon Bedrock in data centres within the European Union. To manage capacity, a request may be processed in an EU region other than Ireland, but it is not processed outside the EU.

Some of the service providers we use (such as Google) are based in, or transfer data to, the United States. Where personal information is transferred outside the Isle of Man, UK or EEA, we ensure it is protected by an appropriate safeguard, such as the EU-US Data Privacy Framework and its UK extension, or Standard Contractual Clauses and the UK International Data Transfer Addendum.

8. Your rights

You have the following rights over your personal information:

• Access – request a copy of the information we hold about you.
• Rectification – ask us to correct information that is inaccurate or incomplete.
• Erasure – ask us to delete your information (subject to any legal reasons we must keep it).
• Restriction – ask us to limit how we use your information in certain circumstances.
• Objection – object to processing based on our legitimate interests.
• Portability – ask for a copy of the information you gave us in a machine-readable format, or ask us to transfer it, where technically feasible.
• Withdraw consent – where we rely on your consent, withdraw it at any time.

To exercise any of these rights, contact us using the details below. We will respond within one month. Using HappyMe is free of charge and we do not charge a fee for exercising your rights.

Complaints: we would like the chance to resolve any concern first, so please contact us. You also have the right to complain to the Isle of Man Information Commissioner, the supervisory authority for data protection in the Isle of Man (inforights.im), First Floor, Prospect House, Prospect Hill, Douglas, Isle of Man, IM1 1ET.

9. Children’s privacy

HappyMe is intended for users aged 13 and over, and is rated accordingly on the App Store and Google Play. At registration we ask users to select an age range. HappyMe is not intended for children under 13, and anyone selecting the under-13 range is not permitted to create an account. We do not knowingly collect personal information from children under 13, and if we become aware that we have, we will delete that account and information.

The AI chat is available only to users aged 18 and over.

We design HappyMe with regard to the Information Commissioner’s Age Appropriate Design Code (the Children’s Code), including considering the best interests of the child, applying privacy-protective settings by default, and collecting the minimum personal information necessary.

We never direct marketing at anyone under 18. Where consent is our lawful basis and a user is under the age at which they can consent for themselves (13 in the Isle of Man and the UK, or 16 in parts of the EU), we will seek the consent of a parent or guardian.

10. Cookies

We use cookies to provide core features, to remember your preferences, and to measure website usage on an anonymised basis. We do not use cookies to serve advertising. You can control cookies through your browser settings. Please see our Cookie Policy for more information.

11. Users outside the Isle of Man, UK and EEA

HappyMe is available internationally. If you use HappyMe from a country whose privacy laws give you additional or different rights (for example in the EEA, United States, Canada or Australia), you may exercise those rights by contacting us, and we will honour the rights that apply to you under the relevant law.

12. Changes to this policy

We may update this policy to reflect changes to our service, practices, or the law. We will post any changes here, and where the changes are significant, or the law requires it, we will contact registered users.

13. Contact us

For any questions about this policy or your personal information, or to exercise your rights, contact our Data Protection Lead: