Last updated: 4th August 2026
This policy is from Netarcs Ltd, company number 04614488, registered office C/O Mericrest, 8–10 Pembroke Building, Cumberland Park, Scrubs Lane, London, NW10 6RE, United Kingdom ("we", "our", "us").
It covers our website www.happimate.com, the Happimate mobile app, and related services (together, the "Services"). We are the controller of the personal data collected through all of them — the organisation legally responsible for deciding how and why it's used.
It applies wherever you are. Depending on where you live, extra rights apply — see sections 9 to 11.
Read it alongside our Terms and Conditions and our Generative AI Use Policy. Where those documents describe AI data handling, this policy governs the data protection position.
This policy doesn't cover the app stores you download Happimate from. Apple and Google handle your payment and store account data under their own policies.
| Category | In more detail |
|---|---|
| Account information | Your name; email address; age or date of birth; username and password; anything else you choose to add to your profile |
| What you send to the AI companion | Messages, prompts and voice input; saved preferences and favourites |
| What the AI generates for you | Companion replies, meditation content and sleep stories created for you |
| Usage information | What you do in the App — content played, completed, saved or skipped; session times and frequency |
| Technical information | IP address; device type and identifiers; operating system; app version; time zone; crash logs and diagnostics |
| Subscription information | Subscription status and renewal information from the app store; records of trials, cancellations and refunds |
| Support and safety records | The content of your enquiries; records of content flagged by our safety systems, reports made by or about you, and any action taken |
Payments. We never see or store your card details. Apple and Google handle payment and tell us only whether your subscription is active.
This matters enough to state plainly.
(a) Not a mental health app. Happimate offers relaxation, meditation, sleep content and general companion conversation. It does not provide mental health advice, therapy, counselling, diagnosis or treatment, and it is not a healthcare provider. We hold no medical records and we are not generally subject to healthcare privacy laws such as HIPAA in the United States.
(b) No health questions. We don't ask about conditions, diagnoses, symptoms, medication or treatment, and we don't build a health profile of you.
(c) If something personal comes up in conversation. Companion chat is open-ended, so you might mention how you're feeling. We don't ask you to, we don't analyse it, and we don't use it to categorise you or infer anything about your health. It's treated like the rest of your conversation: used to generate a reply, kept as your conversation history, and deleted when you delete it. Please share only what you're comfortable sharing.
(a) Happimate is for users aged 13 and over. We don't knowingly collect personal data from children under 13.
(b) If you're between 13 and 17, you need a parent or guardian's consent to use Happimate. Some countries set a higher minimum age — see our Terms and Conditions.
(c) If we learn we hold data of a child under 13, or of a young person without the required parental consent, we'll delete it promptly and close the account. If you believe a child has given us personal data, contact privacy@happimate.com.
(d) Parents and guardians can contact us at privacy@happimate.com to ask about, access or delete a young person's data, subject to verification and to the young person's own privacy rights.
We only use personal data where we have a lawful basis. In Europe and the UK those are: performance of our contract with you, our legitimate interests, compliance with legal obligations, and your consent.
| What we use it for | Our basis |
|---|---|
| Providing the App, Website and Services, and running your account | Performance of our contract |
| Generating AI companion replies, meditations and sleep stories | Performance of our contract |
| Remembering your preferences and recommending content | Performance of our contract; legitimate interests in a useful product |
| Processing subscriptions, renewals, cancellations and refunds | Performance of our contract; legal and financial obligations |
| Service messages and notices about changes | Performance of our contract; legal obligations |
| Customer support | Performance of our contract; legitimate interests |
| Keeping the Services safe — moderation, detecting harm, protecting users | Legitimate interests in user safety; legal obligations where they apply |
| Maintaining, testing, debugging and improving the Services | Legitimate interests in improving our products |
| Security, and preventing fraud, abuse and misuse | Legitimate interests; legal obligations |
| Marketing about our Services | Your consent, or legitimate interests where permitted — opt out any time |
| Establishing, exercising or defending legal claims | Legitimate interests; legal obligations |
| Complying with legal and regulatory obligations | Legal obligations |
Where we rely on legitimate interests, you can object at any time. Where we rely on consent, you can withdraw it at any time without affecting what's already happened.
Our Generative AI Use Policy covers this in full. The essentials:
(a) Your messages are sent to OpenAI so the companion can generate a reply. OpenAI processes them on our behalf, under a data processing agreement.
(b) They are not used to train AI models — not OpenAI's, and not ours. Data sent through the OpenAI API hasn't been used to train OpenAI's models since 1 March 2023 unless the customer opts in, and we haven't (OpenAI data controls). OpenAI keeps API data briefly for abuse monitoring, up to 30 days by default.
(c) Aggregated, de-identified analysis — patterns across users that don't identify anyone — is used to improve the Services.
(d) Limited human review. Members of our team may review interactions only to investigate a report, check safety systems, fix a bug, or meet a legal obligation. Access is limited to those who need it. We don't read your conversations for marketing or advertising.
(e) Safety. Where content is flagged as potentially harmful, we may keep and review it — including in identifiable form where necessary — to protect you or others.
(f) No significant automated decisions. We don't make decisions based solely on automated processing that have legal or similarly significant effects on you.
(a) We share personal data with service providers who help us run Happimate:
(b) We only use providers we're satisfied protect your data properly, and our contracts limit them to specified purposes.
(c) We may also share data with professional advisers such as lawyers and accountants; with regulators, courts or law enforcement where the law requires it or to protect someone's safety; and with other parties in a merger, acquisition, asset sale or insolvency.
(d) We do not sell your personal data, and we don't share it for targeted or cross-context behavioural advertising.
| Data | Retention |
|---|---|
| Account and profile | While your account is active, then deleted within 1 year of closure |
| Conversation history and AI-generated content | While your account is active; deleted within 1 year of you deleting it or closing your account |
| Subscription and transaction records | 6 years after the relevant tax year, for accounting and tax |
| Support correspondence | 1 year after the enquiry is resolved |
| Safety and moderation records | 6 years where needed to protect users or meet a legal obligation |
| Technical and diagnostic logs | 1 year |
| Aggregated, de-identified data | Indefinitely — it no longer identifies you |
Deleted content may sit in secure backups briefly before being overwritten. If we need to keep something to defend a legal claim, we keep it only for that purpose.
Wherever you live, you can email privacy@happimate.com to ask what we hold, get a copy, have it corrected or deleted, object to processing, or close your account. You can also delete your conversation history and close your account in the App's settings.
If you're in the EEA, the UK, Switzerland or a country with comparable law, you have these rights, usually free of charge:
| Right | What it means |
|---|---|
| Access | Get a copy of your personal data |
| Correction | Have mistakes corrected |
| Erasure | Have your data deleted, in certain situations |
| Restriction | Limit how we use it, for example while you contest its accuracy |
| Portability | Receive data you gave us in a machine-readable format |
| Object | Object to direct marketing at any time, and to legitimate-interests processing in certain situations |
| Withdraw consent | Where we rely on consent, withdraw it at any time |
| Automated decisions | Not be subject to solely automated decisions with legal or similar effects. We don't make any |
Tell us which right you want to use and enough to identify you. We respond within one month, and will say if we need longer.
Our representatives. Our EU representative. We have appointed NERI RENEE VAT ID: 04420090245 as our representative in the European Union under Article 27 of the GDPR. You can contact them about how we handle your personal data via email at renee@netarcs.com.
Complaints. You can also contact us directly at privacy@happimate.com. You can also complain to your data protection authority — in the UK, the Information Commissioner's Office; in the EEA, the authority where you live, work, or where the issue arose.
Depending on your state, you may have the right to know what we collect, access a copy, correct it, delete it, opt out of sale or sharing and targeted advertising, and not be discriminated against for exercising those rights.
We do not sell personal information, and we do not share it for cross-context behavioural advertising, as those terms are defined under California law. We haven't in the preceding 12 months, including for anyone we know to be under 16.
Some states — Washington, Nevada and Connecticut among them — give specific protections to consumer health data. As set out in section 3, Happimate doesn't track health related data and doesn't build health profiles. We don't sell any such data and wouldn't without the separate authorisation those laws require.
To exercise your rights, email privacy@happimate.com. We'll verify your identity first. You may use an authorised agent with proof of authorisation. If we decline, you can appeal by replying to our response.
If you're elsewhere — including Canada, Brazil, Australia, Japan, South Korea, South Africa or India — you may have rights under local law similar to those above. We'll honour access, correction and deletion requests wherever you live, whether or not local law strictly requires it. Contact privacy@happimate.com.
Happimate is run from the United Kingdom and uses providers in other countries, including the United States, so your data is transferred and processed outside where you live.
Where we transfer data out of the UK or EEA, we rely on an adequacy decision, or on appropriate safeguards — usually the European Commission's Standard Contractual Clauses and, for UK transfers, the UK International Data Transfer Agreement or Addendum, supported by a transfer risk assessment. You can request a copy of the safeguards at privacy@happimate.com.
(a) We use appropriate technical and organisational measures to protect personal data against loss, unauthorised access, misuse, alteration or disclosure. These include encryption in transit and at rest, access controls, and regular review of our practices.
(b) Access is limited to people who genuinely need it, and our staff and providers are bound by confidentiality.
(c) We have procedures to detect, investigate and respond to suspected data breaches, and where the law requires it we'll notify the regulator and affected users without undue delay.
(d) No system is completely secure. Please use a strong, unique password and keep it private.
We may update this policy. Where we make significant changes — particularly to how we use your data, the bases we rely on, or your rights — we'll tell you in advance through the App, the Website or by email, and where the law requires consent, we'll ask. The date at the top always shows the current version.
Privacy queries, rights requests and complaints: privacy@happimate.com
General enquiries: info@happimate.com
Post: Netarcs Ltd, C/O Mericrest, 8–10 Pembroke Building, Cumberland Park, Scrubs Lane, London, NW10 6RE, United Kingdom