Privacy Policy

1. Who we are

Empath is operated by Empath Ltd, 47 Meadway, London, N14 6NJ, United Kingdom. Empath Ltd is the data controller. Data protection lead: Dr Rohan Choudhari. Contact: help@empathapp.co.uk.

2. What we collect

• Sign in with Apple identifier (to create and secure your account)
• Device identifiers (used for safety enforcement, e.g. blocks and bans)
• Email address (from Apple; may be an Apple private-relay address)
• Date of birth and age declaration (to verify you are 18+)
• Free-text matching prompts (analysed for matching, then deleted)
• Anonymised matching data (numeric representations of your text, topic categories and match-quality scores, used to improve matching accuracy)
• Chat messages (text and voice notes), encrypted at rest
• Crisis-signposting event logs (recording that a safety keyword was detected, without storing the full message)
• Session ratings and basic usage analytics

3. Why we collect it and our legal basis

We process your data to provide our peer support matching service.

• Account data (email, nickname): contract (Art. 6(1)(b))
• Device identifiers and IP addresses: legitimate interest (Art. 6(1)(f))
• Chat messages: contract (Art. 6(1)(b))
• Free-text prompts and other special-category data: explicit consent (Art. 9(2)(a))
• Age verification: legal obligation (Art. 6(1)(c))

Before you can be matched or chat, the app asks for your explicit consent to this processing, including by our AI provider. If you do not agree, you can still use your account, but you cannot be matched or chat. You can give or withdraw consent at any time in Profile. Voice notes and message translation are optional and ask for your permission separately when you first use them.

4. Who we share it with

• Your matched peer sees your messages, the nickname you choose and a short AI-written summary of what you shared. They never see your name, email or Apple ID.
• Our trained moderators may review a conversation that you or your peer reports, or one preserved for a safety review (limited, logged access).
• Law enforcement, only where we are legally compelled.

We use a small number of processors. We do not sell your personal data.

Empath can technically read message content. Messages are encrypted in transit and at rest, but they are not end-to-end encrypted. This is what makes pre-delivery moderation, crisis signposting and reporting possible.

5. International transfers

The only routine transfer outside the UK is to our AI provider, OpenAI, whose servers are in the United States: an identity-stripped version of your matching text (for matching), the full content of each chat message (for the pre-delivery safety check), voice-note audio (transcribed for that check, then discarded) and, only if you turn on auto-translate, your chat messages for translation. These transfers are protected by Standard Contractual Clauses.

6. How long we keep it

• Free-text prompts: deleted after matching (within minutes)
• Chat messages, including voice notes: encrypted at rest and automatically deleted after 7 days. They are kept longer only in two bounded cases: while a report about the conversation is open (until it is resolved), or under a moderator safeguarding escalation (up to 90 days). Automated crisis-keyword detection alone does not extend message retention. Deleted immediately when you delete your account.
• Voice-note safety transcripts: discarded immediately after the check, never stored
• Anonymised matching data (numeric text representations, category and quality scores, and derived match context): deleted or anonymised after 180 days
• Translated text (auto-translate users only): encrypted cache for up to 24 hours
• Crisis-signposting event logs: 12 months
• Session ratings and usage analytics: anonymised within 90 days
• Account data: until you delete your account
• Device identifiers and IP addresses: lifetime of the account, deleted within 30 days of account deletion

After account deletion we keep only what the law requires: terms-acceptance records (2 years), consent records (6 years) and report records (12 months from resolution). Everything else is deleted within 30 days.

7. Automated decision-making

We use AI to analyse your free-text prompt to find a relevant match. This analysis extracts themes and keywords. It does not diagnose or categorise health conditions, and you are never shown to a match based on a health label.

8. Sign in with Apple and account deletion

You can delete your account in the app (Profile → Delete Account). We erase your personal data immediately (subject to the legal-retention items above) and attempt to revoke Sign in with Apple access on Apple's side. If we cannot complete that automatically, the app tells you and gives you the manual steps (Settings → your name → Sign in with Apple → Empath → Stop Using Apple ID). We never tell you Apple access was revoked when it was not.

9. Provider retention

We are seeking written confirmation of OpenAI's data-processing terms and zero-data-retention for the moderation, transcription and translation endpoints. Until that is confirmed, we do not claim that providers immediately delete inputs.

10. This website

This website does not require an account and does not use advertising or tracking cookies. Our hosting provider processes standard technical data, such as your IP address, to deliver the site.

If you joined our waitlist here, we hold your email address, with your consent (Art. 6(1)(a)), to send you updates about Empath. It is stored with our database provider (Supabase), and confirmation emails are sent through our email provider (Resend). We keep it until you unsubscribe or ask us to delete it. Email help@empathapp.co.uk to be removed.

11. Your rights

Under UK GDPR you have the right to:

• Access your personal data
• Correct inaccurate data
• Delete your data (including via in-app account deletion)
• Restrict processing
• Data portability
• Object to processing
• Withdraw consent at any time

To exercise any of these rights, contact help@empathapp.co.uk.

12. How to complain

If you are unhappy with how we handle your data, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113.

13. Changes to this policy

We will notify you of material changes in the app and update the "Last updated" date at the top of this page. See also our Terms of Service.