Privacy policy
Draft for review. Items in [square brackets] must be completed, and this policy should be checked by a data protection specialist and matched to your DPIA before launch.
SteadySelf ("SteadySelf", "we", "us") is run by [Company name], [registered address]. We are the data controller for the information you give us. You can contact us about privacy at privacy@steadyself.app. Our ICO registration number is [number].
The short version
- We collect only what SteadySelf needs to work: your account details and the entries you choose to write.
- What you write is encrypted before it's stored. We don't read it, sell it or use it for advertising.
- You can download everything or permanently delete your account at any time from Your data in the app.
What we collect and why
| Information | Why we use it | Lawful basis |
|---|---|---|
| Name, email address and a securely hashed password | To create your account and let you sign in | Contract (UK GDPR Art. 6(1)(b)) |
| Your entries: mood ratings, emotions, notes, thought records, activities, exposure ladder steps, mindfulness practices (which practice, how long, how settled you felt before and after, and any note), your progress and reflections in the Steady foundations course, your staying-well plan, your weekly reviews, how strongly you believe past thoughts when you re-rate them, your evening three good things, how much you moved each day and, if you note them, your meals, late caffeine and alcoholic drinks each day (never what you ate, calories or weight), the habits you're starting or stopping (what they are, your plan, and each day's tick), worries you park until the next morning, and what you write in the self-esteem tools (beliefs about yourself and how strongly you hold them, evidence, replies to your inner critic, experiments, qualities, rules for living and course reflections) (kept until you let them go), the days you mark today's step as done, your progress through first steps (which of the three days you've done, and whether you skipped them), and, if you choose to answer it, the wellbeing check-in (your answer to each of its seven questions and the total) | To store your entries and show them back to you, including your Insights | Your explicit consent (Art. 9(2)(a)), given when you first start using SteadySelf |
| If you choose one: your answer to "What brings you here?" (for example "Worry" or "Winding down at night"), and whether personal suggestions are on | To choose which tools SteadySelf shows you first, and to remember your choices | Contract (Art. 6(1)(b)); because it can relate to your mental health, also your explicit consent (Art. 9(2)(a)) |
| If you turn on reminders: your chosen time, days and type, and for each device a push address and keys supplied by your browser, plus a device name such as "iPhone (Safari)" | To send the reminders you asked for | Your consent (Art. 6(1)(a)), which you can withdraw by turning reminders off |
| In the SteadySelf iPhone and Android apps, only if you switch each one on: a daily total of your sleep (hours), steps and active minutes, read from Apple Health or Health Connect, and which of these you've switched on | To show your sleep, steps and activity next to your mood in Insights | Your explicit consent (Art. 9(2)(a)), given separately for each type, which you can withdraw by switching it off |
| If you turn on the app lock: a one-way hash of your passcode (never the passcode itself), the lock timing you chose, and a count of recent wrong attempts | To hide the app until the passcode is entered | Contract (Art. 6(1)(b)) |
| The date and time you gave consent | To show we have your consent | Legal obligation (Art. 6(1)(c)) |
| Failed sign-in attempts (a one-way hash of the email entered and your IP address), kept for up to 24 hours | To protect accounts from password guessing | Legitimate interests (Art. 6(1)(f)) |
Information about your mental health is "special category" data under UK data protection law. We process it only with your explicit consent and only to provide the service to you. You can withdraw consent at any time by deleting your account.
How we protect it
- Free-text entries are encrypted with AES-256 before they reach our database, and the encryption key is stored separately.
- All traffic to SteadySelf uses HTTPS. Passwords are stored only as secure hashes.
- Pages containing your entries tell browsers not to keep copies, and the installed app never stores your entries for offline use. The only things kept on your device are the app's styles and icons, and any practices you save for offline use (their text and recorded voice), which contain nothing about you. Your preferences for voice guidance and for the unguided timer (its bells, settling-in time, bell sound and any presets you save) are also remembered on the device and never sent to us.
"You're not the only one"
On the Practise page we sometimes show how many people took a pause in SteadySelf today, for example "214 people took a pause today". It's a single total worked out on our server from the number of accounts that saved a practice today. It never identifies anyone: there are no names, places, profiles or comments, nothing about you is shared with other people, and the number is only shown once at least 25 people have practised that day, so a small total can't hint at who they were.
Your focus and personal suggestions
When you join, and at any time under More → Your focus, you can tell us what brings you here, such as everyday stress, worry, low mood or winding down at night. It's optional and you can choose more than one or none. It's a preference, not an assessment: there are no scores or labels, and we only use it to choose which tools to show you first.
When SteadySelf suggests a practice, it can put first the one that has helped you most at similar times. This is worked out on our server, using a few fixed rules, from your own "settled" ratings before and after past practices and the check-ins you made that day. It doesn't use artificial intelligence or any other company, it isn't shared with anyone, and it only re-orders practices that already fit the moment. Your safety features always come first. It's on by default and you can switch it off under More → Personal suggestions; your ratings are still kept as part of your entries until you delete them.
The wellbeing check-in
The wellbeing check-in is optional and you can skip it every time, or ask us not to offer it again. Your answers are fixed choices (from "none of the time" to "all of the time"), stored as numbers so they can be shown back to you as a chart in Insights. They're only used to show you how things change over time: they aren't used to diagnose anything, they don't change what SteadySelf offers you, and nobody else sees them. If you skip it, we note that you skipped so we don't keep asking.
Apple Health and Health Connect
In the SteadySelf iPhone and Android apps you can choose to connect SteadySelf to Apple Health (iPhone) or Health Connect (Android). It's off until you switch it on, and each part is a separate choice under More → Apple Health (or Health Connect). It isn't available on the website or in the teen edition.
- Mindful minutes. When you finish a practice, the app saves its start and end time to your phone's health app as a mindful session. This goes from the app to your phone, not to us, and nothing else is included: not which practice, your ratings or notes.
- Sleep, steps and active minutes. For each type you switch on, the app reads one total per day from your phone and sends it to us, for up to the last 30 days. We store only those daily totals, as numbers, to show them next to your mood in Insights. We don't read heart rate, heart rate variability or anything else, and we never use this information to work out stress or any health condition, or to diagnose anything.
Health information is special category data. We use it only to show it back to you, never for advertising or marketing, and we never share it with anyone else. Switching a type off deletes what we hold for it straight away, and you can switch everything off and delete it under Your data, even without your phone. To stop your phone sharing as well, also turn SteadySelf off in the Health app or in Health Connect. It's included when you download your data and deleted when you delete your account.
AI weekly reflections
If you choose to turn them on, under More → AI weekly reflections, you can ask for a short reflection on your week in your weekly review. It's off until you turn it on, and it isn't available in the teen edition.
- What we send. Only numbers and fixed choices from that week: mood ratings by day, the feelings and thinking traps you picked, how many activities, practices, thought records and good things you noted and how you rated them, and your movement and meal days. We never send anything you've written, your name, email or any other way of identifying you. The page where you turn it on shows exactly what would be sent.
- Who. The reflection is written by Claude, an AI model made by Anthropic, which processes this information on our behalf as our processor, in the United States, under a data processing agreement and [UK international data transfer safeguards]. Anthropic doesn't use it to train its models [confirm against the current Anthropic commercial terms and DPA before launch], and keeps it only for [the period in Anthropic's terms] for safety and abuse monitoring.
- What we keep. The reflection and the tools it suggests, encrypted, until you delete it or turn reflections off. Turning them off deletes all of them straight away. They're included when you download your data.
- Safety. No reflection is written for a week that looks very hard, and every reflection is checked before you see it. It's automated, but it never makes decisions about you: it's a suggestion you can ignore.
Lawful basis: your explicit consent (Art. 9(2)(a)), given separately when you turn reflections on. You can withdraw it at any time.
Safety features
If something you write suggests you might be at risk of harming yourself, SteadySelf shows you crisis support services before saving. This check happens automatically on our server. Nobody is alerted and no person reviews your entries. SteadySelf is not an emergency service.
Reminders
Reminders are optional and off until you turn them on. They're delivered through your browser or phone maker's push service (for example Google, Apple or Mozilla). Each reminder is encrypted so that only your device can read it, and by default it says only "A gentle reminder", so nothing about your mental health appears on your lock screen. In the SteadySelf phone apps, reminders are scheduled on the phone itself and nothing is sent. Turn them off on the Reminders page, or by deleting your account.
Summaries you share
You can make a printable summary of your entries to share with a therapist or GP. It's made only when you ask for it and shown only to you; SteadySelf doesn't send it to anyone. Who you share it with is up to you. You can choose to leave out everything you've written yourself.
Cookies
We use only cookies that are strictly necessary for SteadySelf to work: a session cookie that keeps you signed in while you use the app, and, if you choose "Keep me signed in", a cookie that lasts up to 30 days. We don't use analytics or advertising cookies.
Who we share it with
We don't sell your information or share it for marketing. We use these service providers, who process data only on our instructions:
- [Hosting provider], which stores our servers and database in [the UK / location].
- Anthropic, which writes AI weekly reflections, only if you turn them on (see AI weekly reflections).
- Google Fonts, which supplies the typefaces used on the site. Your browser requests them directly, which shares your IP address with Google. [Remove this line once fonts are self-hosted.]
We may disclose information if the law requires it.
How long we keep it
We keep your account and entries until you delete them or your account. When you delete your account, everything is removed from our live database straight away and from backups within [30] days.
Your rights
You have the right to access, correct, download, restrict or delete your information, to object to how we use it and to withdraw consent. You can download and delete your data yourself in the app, or email us at privacy@steadyself.app. We'll respond within one month.
If you're unhappy with how we've handled your information, you can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
Age
SteadySelf is for people aged 16 and over.
Changes
If we make significant changes to this policy we'll tell you in the app before they take effect.