Pilot privacy notice
DRAFT – FOR LEGAL REVIEW
Updated 21 October 2026
Who is responsible
Tom Mansbridge operates How Are We? and is responsible for how the pilot uses your personal data. ICO registration number: TBC. For privacy questions, access, corrections or complaints, email t.mansbridge@yahoo.co.uk.
What we collect and why
We ask only for a first name or nickname and email for identity. You must separately confirm you are 18 or over. The sign-in service manages your password; it is not stored as readable text. We store pairing requests, daily capacity, optional check-in text, evening preferences, replies, and Podcast-night dates and categories. We do not record Podcast conversations, answers or private notes. We record your consent type, privacy-notice version, grant date and any withdrawal date, plus content-free security events and last activity.
Our proposed lawful basis is contract to provide the app, with separate explicit consent for potentially wellbeing-related content, treated cautiously as potentially special-category data. You can withdraw consent in Settings & privacy; check-in features stop, pairing ends and live shared content is removed. Limited pseudonymous participation metrics and content-free security events support pilot operation and safety under legitimate interests. These proposed bases require legal review, and consent does not override a hosting provider’s restrictions on sensitive data.
Keep messages everyday
Please don't include medical or sexual details. Do not enter health conditions, medication, mental-health details, sexual activity, sexual-orientation details, financial information or private information about another person. Keep messages about ordinary activities and everyday preferences. Capacity and messages may still reveal wellbeing information; warnings alone do not make this service compliant.
Who can see it
Your partner requests to join and you accept before pairing completes. Confirm with them before accepting a request and keep your invite private. Your paired partner sees your first name or nickname, check-ins you actively Share, replies you Send and Podcast-night activity. Unsent text is not saved or shared. Other couples cannot read your records through the app. Either partner may unpair; this deletes the couple’s live history for both partners and removes access. The organiser’s dashboard contains pseudonymous participation counts and dates only, never names, invite codes, scores or messages.
Lovable Cloud hosts the app and sign-in service. Authorised service operators and people with privileged project access can technically access stored data to operate or support the service; ordinary app administrators cannot browse user content. This is not end-to-end encrypted messaging, and a project owner’s privileged access is not blocked by app-level rules. Google or Lovable sign-in, if chosen, also involves that provider’s account service. We do not sell data or send user content to AI.
Keeping and deleting data
Live check-ins, replies and Podcast-night records older than twelve months are removed by a daily cleanup, with up to one day’s delay. You can download your own data as JSON and delete your account from Settings & privacy. Deletion removes your sign-in account and profile, ends pairing and removes the couple’s shared records from the live app. Your partner’s sign-in account stays open. This cannot erase copies your partner has already saved.
The proposed inactive-account policy is a warning at fifteen months and deletion at eighteen months. It is not yet active because a verified sender domain is needed; accounts are not automatically deleted for inactivity currently. Service logs and backups may remain subject to provider retention and legal requirements; the exact backup deletion timetable is unverified.
Hosting and protection
The project’s connection information identifies the database region as eu-west-1, Ireland. App connections use HTTPS. Provider confirmation of encryption at rest, backup locations, suppliers, overseas support access, transfer safeguards and the applicable data-processing agreement remains outstanding. No extra database-level free-text encryption has been added; the app must read shared text and is not end-to-end encrypted. These safeguards and sensitive-data permission must be verified before broader use.
Your choices and rights
Settings & privacy provides Download my data, Withdraw consent, Unpair and Delete my account. Contact us for access, correction, restriction, portability or to object where applicable. Withdrawal does not change the lawfulness of earlier processing. We normally respond within one month and may need to verify identity. You can complain to the UK Information Commissioner’s Office at ico.org.uk.
Browser storage
The app uses browser storage to keep you signed in and remember a pending partner invitation. These support the service you request. Service providers may maintain operational logs. No advertising tracking is added by the pilot.
This is a pilot, not therapy or a crisis service. A message warning does not guarantee that sensitive data cannot be submitted.