Policy version: 12 December 2025

1 Introduction

This Privacy Policy is provided by Netarcs Ltd, company number: 04614488 with registered offices located at C/O Mericrest, 8-10 Pembroke Building Cumberland Park Scrubs Lane, London, NW10 6RE, (‘we’, ‘our’ or ‘us’) for use of our website www.happimate.com (Website), the ‘Happimate’ App (App), and services including any applications or software we provide (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2 What this policy applies to

This privacy policy relates to your use of the Website, App and Services only.

The Website may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Website. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

3 Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

Category of data	In more detail
Identity information when you engage us for services	· Your name and email address · Your age and date of birth · Your Gender · Your phone number · Your residential and postal address Your account details, such as username and password
Data collected when you use specific functions in the Website	Data you store online with us using the Website including: · your usage history or preferences · Chat logs and conversations with Coach Mira and Friend Mode · Mood tracking entries and emotional wellbeing reflections · Journal entries and personal reflections shared in the App · Gratitude logs and positive wellbeing notes · Personal notes related to mental health and wellbeing concerns · Information you voluntarily share about your feelings, thoughts, and experiences · History of use and engagement with mental health coaching features (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)
Other data the Website collects automatically when you use it	· Your activities on, and use of, the Website which reveal your preferences, interests or manner of use of the Website and the times of use · IP address, device type, IMEA numbers, MAC address of networks, other unique device identification, device operating system, mobile network information, app version number, storage usage, data usage, time zone settings.
Data collected when you make an enquiry with us	Your name and email address

If you do not provide personal data we ask for where it is required it may prevent us from providing the Website or Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4 Special category personal data or Sensitive Data

Certain Personal Data we collect is treated as a ‘special category’ to which additional protections apply under data protection law. This is also known as ‘Sensitive Data’. Where we process such Sensitive Data, we will also ensure we are permitted to do so under data protection laws, and any such data will be collected on the basis of your consent. Sensitive Data we collect about you, where you choose to give it to us, may include:

(a) Medical information; history and traits, including any particular neurotypes of an individual;

(b) Mental Health history;

(d) Your gender and sex; and

(e) History of drug consumption, medical or recreational.

We collect and use this Personal Data for the purposes described in the section ‘How and why we use your Personal Data’ below.

5 How your personal data is collected

We collect Personal Data from you:

(a) directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase or request services via our Services, engage with our AI Chat bot on the App; and

(b) indirectly, such as your browsing activity while using the Services.

We also use cookies on our Website which may collect personal information about you. Detailed information regarding our use of cookies and similar technologies is available in our cookies policy.

6 How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

(i) where you have given consent

(ii) to comply with our legal and regulatory obligations

(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or

(iv) for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
To provide the Services to you	To perform our contract with you or to take steps at your request before entering into a contract
Providing the Website to you	To perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions which apply to the Website)
Providing you with our products	To perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions which apply to the Website)
To provide mental health coaching and AI-generated responses through ‘Coach Mira’ and ‘Friend Mode’	To perform our contract with you (the Terms and Conditions) and to provide the core services you have requested when you interact with the App's coaching and wellbeing features. Your chat data from Coach Mira or Friend Mode, mood information, journal entries, and gratitude logs are processed to generate personalised wellbeing guidance and supportive conversation. We do not use your chat data to train OpenAI's general language models.
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Website or service or other important notices	Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our Website and Services
Updating and enhancing user records	Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions which apply to the Website) · to comply with our legal and regulatory obligations · where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products
To comply with our legal and regulatory obligations	Depending on the circumstances: · to perform our contract with you or to take steps at your request before entering into a contract ( · to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: · to comply with our legal and regulatory obligations · in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

7 Who we share your personal data with

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Website and App, including programming interfaces, developers, cloud storage providers, and OpenAI. For full details on Open AI’s data practices please see: https://openai.com/en-GB/policies/row-privacy-policy/

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share your personal data with:

§ external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations

§ professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations

§ law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations

§ other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

8 How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.

Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

9 Transferring your personal data out of the UK

As part of providing the Services, we may share your personal data with third parties based outside of the UK.

Under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

§ The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.

§ Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by relying on an Adequacy Decision being in place for that country, or entering into an International Data Transfer Agreement.

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

10 Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use	The right to object: · at any time to your personal data being used for direct marketing (including profiling) · in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by the Website.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please contact us—see below: ‘How to contact us’. When contacting us please:

o provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and

o let us know which right(s) you want to exercise and the information to which your request relates

11 Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

12 How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

13 Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Website or by other means, such as email.

14 How to contact us

You can contact us if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

- privacy@happimate.com

- Netarcs Ltd, C/O Mericrest, 8-10 Pembroke Building

Cumberland Park, Scrubs Lane

London, NW10 6RE, United Kingdom