Privacy policy

Last updated: 2026-08-14

This policy describes how Mind Guard 365 (“we”, “us”) collects, uses and shares information when you use the Mind Guard 365 mobile application (“App”) and the marketing website at mindguard365.com (“Site”). It is written for users in the United Kingdom and aligns with UK GDPR and the Data Protection Act 2018.

1. Who is responsible

Mind Guard 365 is operated by Mind Guard 365 Ltd, which is the data controller for the App and Site. Our company and governance details are on our company page. For privacy questions or requests use privacy@mindguard365.com.

1.1 Data Protection Officer

The named Data Protection Officer for Mind Guard 365 Ltd is David Roberts. You can contact the DPO for any privacy question, data subject request or complaint about how we handle personal data at privacy@mindguard365.com. Please put "DPO" in the subject line if your request is specifically for the DPO. For any further enquiries about this policy, the same address is monitored and we will respond in the timeframes set out in section 7.

2. Information we collect

2.1 Account and profile

An account is required to use the App. We process identifiers needed to authenticate you (for example email address or tokens issued by our auth provider) and profile fields you choose to provide such as display name, date of birth, country and preferences related to goals, schedules, notifications, gamification and security.

2.2 Mental wellbeing data you enter

When you use the App we process the wellbeing information you choose to enter, including:

• Mood check-ins and how you rate your day
• Notes and journal text you write
• Tags and causes you attach to a check-in (for example what helped or what was hard)
• Programme and exercise progress, reflections and sleep entries
• Usage data such as which tools you open and when (to power your patterns and insights)

This data is synchronised to your private account on our backend so it follows you across devices, and a copy is cached on your device for offline use. Because it relates to your mental wellbeing we treat it as sensitive and handle it with extra care (see section 2a).

2a. Special category data

Some of what you enter (such as mood, notes and tags about how you feel) may be special category data concerning health under UK GDPR. We only process it to provide the wellbeing features you ask for. Our condition for processing it is your explicit consent, given when you choose to use the App and enter this information; you can withdraw it at any time by deleting the data or your account. We do not use this content for advertising and we do not share it with analytics, advertising or crash-reporting vendors. Section 5.1 names who receives data and who does not.

2.3 Purchases and entitlements

When you buy or trial a subscription through Google Play or the App Store, Apple or Google processes payment data. We receive limited purchase and entitlement metadata from our own subscription service after Apple or Google confirms the purchase so we can unlock features in the App. We do not receive your full card number.

2.4 Diagnostics and security

We use error and performance reporting (Sentry) to collect crash logs, device and app version metadata and related diagnostic data to keep the App reliable and secure. Sentry reports are configured to scrub the wellbeing content you enter (for example journal text, notes, tags, causes and reflection answers) and identifiers such as your email, full name and date of birth before they are sent, so those fields should not appear in error reports.

2.5 App analytics (explicit policy)

Analytics is a separate processing activity from the wellbeing features. We treat it that way in the App and in this policy so it is clear what is and is not measured.

What is collected. We use Google Analytics for Firebase in the App to understand aggregate usage, for example which screens are viewed, which features are opened (such as check-ins or tools completed) and app opens. Google may process device identifiers, app version and technical data as described in Google's privacy policy.

What is never collected by analytics. Analytics events do not include the wellbeing content you enter. That means no journal text, no notes, no mood values, no tags or causes attached to check-ins, no programme reflection answers and no other free-text content from tools. Event names describe the type of action (for example "sleep check-in recorded" or "tool completed"), not what you wrote or how you rated it.

Legal basis and your control. Where analytics relies on your consent under UK or EEA law we obtain it through the App's consent flow. You can turn App analytics off at any time from Settings > Data and Privacy in the App. Turning analytics off does not affect features you can use, and does not opt you out of activities we cannot switch off, such as security logging, fraud prevention, crash reporting with scrubbed content or the processing needed to deliver the App and your account.

2.6 Advertising

The App may show ads through Google Mobile Ads (AdMob). Google may use identifiers such as the advertising ID, and technical data including your IP address, to deliver, personalise and measure ads. From around August 2026 Google may also use IP addresses for measurement and ad personalisation for users in the UK, the European Economic Area and Switzerland. We request non-personalised ads by default and apply a child-appropriate content rating, and in the UK/EEA/Switzerland we use Google's consent flow (Google User Messaging Platform) to obtain consent where required. The merged Android manifest for the App may include permissions such as READ_PHONE_STATE where required or declared by the advertising SDK for fraud prevention or measurement. You can limit ad personalisation in your device settings, and change your choice at any time from the App's privacy options.

For details of how Google uses the information it receives from sites and apps that use its services, see How Google uses information from sites or apps that use our services and Google's advertising technologies.

2.7 Local storage and notifications

We cache some data on your device (for example profile or check-ins before they sync to your account) so the App keeps working offline. If you enable reminders we schedule local notifications; content may be processed on-device.

2.8 Website and cookies

The Site is largely informational. We use Google Analytics on the Site to understand aggregate traffic (for example pages viewed, approximate location derived from IP, browser type and referral source). Standard server or CDN logs may also include IP address, user agent and request metadata. We do not use the Site to collect the same structured wellbeing data as the App unless we clearly ask for it on a form.

Cookies and similar technologies used on the Site are covered in a separate cookie policy. In summary, analytics cookies are only set after you accept them in the consent banner, strictly necessary cookies are always set so the Site can work, and you can change your choice at any time using the Cookie settings link in the footer.

2.9 Mind library referral page

If you arrive via our Mind library partner page at /referral/, the URL may include a referral identifier (orcha_uid). We log page visits and optional actions (email capture or store button clicks) to measure referral funnel performance. If you enter your email we send you an invite or sign-in link using the same address. If you later register in the App with that same email we link your account to the referral for aggregate reporting to our Mind library partner. We do not put the referral identifier in the email link itself. We report pseudonymous monthly aggregates to Mind; we do not sell your email to third parties for marketing.

2.10 Employer benefit

If your employer offers Mind Guard 365 as a benefit and you redeem an invite code, we link your account to that organisation so we can grant employer-funded premium access. Your employer does not receive your check-ins, journal entries, mood history, SOS activity or personal app usage.

We may share anonymous, aggregated adoption statistics with your employer, such as how many seats are activated and how many people have used the app in a reporting period. When enough employees are active, we may also share grouped check-in themes (for example counts of supportive or pressure tags chosen during check-ins). These reports are counts only, cannot identify you, and hide tags with very few mentions. Seat counts may be visible even when usage reporting is suppressed because they are administrative rather than wellbeing data.

3. How we use information

• Provide, operate and improve the App and Site
• Authenticate users, sync data and restore access across devices
• Process purchases, trials and premium access
• Show ads where applicable and measure their delivery
• Measure aggregate App and Site usage to improve features
• Detect abuse, fix bugs and improve stability
• Meet legal obligations and respond to lawful requests

3.1 Data minimisation

We collect only the minimum personal data needed to provide the service. Fields are added deliberately, not by default, and optional fields are clearly optional. Where a feature can work without a piece of data (for example a note attached to a check-in) it is optional. Special-category wellbeing content is excluded from analytics, advertising and crash reporting by design.

3.2 No automated decision-making with legal or similar effects

We do not use automated decision-making, including profiling, that produces legal or similarly significant effects about you. The recommendation engine in the App is a transparent, rules-based feature that suggests tools based on the mood, tags and time of day you enter. It does not make eligibility, benefit, employment, insurance or clinical decisions about you.

4. Legal bases (UK GDPR)

Where UK GDPR applies we rely on one or more of the following:

• Contract: providing the App and features you request
• Legitimate interests: securing the service, debugging, App and Site analytics that do not override your rights and direct marketing only where permitted
• Consent: where we ask for it (for example optional marketing or non-essential cookies on the Site if we add them later)
• Explicit consent (special category data): for the mental wellbeing content you enter, our condition under UK GDPR Article 9 is your explicit consent, which you can withdraw at any time
• Legal obligation: where the law requires processing

5. Sharing and processors

This section is the definitive list of who receives personal data from the App or the Site. It is not a set of examples. We do not share data with the organisations below. Those products are not integrated and they are not processors for Mind Guard 365.

• Google Fit
• Google Health Connect
• Facebook or Meta
• Fitbit
• Apple Health or HealthKit
• Apple Watch health feeds
• any other health platform, wearable or social network

5.1 Health and wellbeing data

Physical and mental health content you enter in the App (journal text, notes, mood scores, tags, causes, programme reflections, sleep entries and SOS activity) is not shared with third parties such as Sentry, Google Analytics, Google ads, Resend, Apple, Google Play or your employer as an identifiable record.

That content is processed only by Mind Guard 365 Ltd and our hosting processor Supabase so we can provide the App you asked for, including sync across your devices. A copy is cached on your device for offline use. We do not use it for advertising and we do not send it to crash reporting or analytics vendors.

5.2 Who receives data and what they receive

Other processors receive a limited subset for a specific job. The table below is exhaustive as of the date at the top of this policy. If we add a recipient we will update this list first.

Providers may process data in countries outside the UK. Where required we use appropriate safeguards such as the UK International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses.

Our primary application database is hosted on Supabase Postgres in the EU (Ireland), with managed backups held in the same region. Where cross-region delivery is unavoidable (for example the Google advertising or measurement networks) we rely on the transfer safeguards above.

We do not sell your personal information. We do not share wellness journal content for advertising.

If you join through an employer benefit, we share only anonymous, aggregated adoption statistics and grouped check-in themes with your employer as described in section 2.10. We do not share identifiable wellbeing content with employers.

Some pages on the Site and in the App link out to third-party sites (for example Google, Apple, the NHS or NIMH). Those sites are operated by other organisations and have their own privacy policies. We are not responsible for how they handle your personal data once you leave the App or the Site.

5a. Security, storage and encryption

We use recognised secure storage and transport technologies for the personal data we process. All personally identifiable data that moves between the App or Site and our backend, and between our backend and the processors listed above, is encrypted in transit using HTTPS with TLS 1.2 or higher. This includes account and authentication traffic, sync of check-ins, notes, tags and programme progress, subscription verification and admin traffic.

Non-secure network traffic is not allowed by the App. On iOS this is enforced by Apple's App Transport Security configuration in the App's Info.plist, which sets NSAllowsArbitraryLoads to false. On Android we do not permit cleartext traffic to our own endpoints. The marketing site is served over HTTPS with HSTS.

Personal data at rest is held in recognised secure storage. Cloud-held data uses Supabase Postgres managed encryption at rest in the EU (Ireland) region, behind the access controls of our infrastructure providers. On the device, refresh tokens are stored in the iOS Keychain or Android Keystore where applicable, and other app data sits in the operating system's sandboxed app storage.

On top of the operating system's standard protections, the App offers an optional App Lock. When you turn it on from Settings > Data and Privacy > Lock the app, Mind Guard 365 will ask for your device biometric (Face ID, Touch ID or Android biometrics) or a six-digit PIN before it will open once it has been backgrounded. If you choose PIN, the PIN is stored in the OS keychain / keystore and never leaves the device. App Lock is off by default and never blocks our Help Me Now crisis screen, so you can always reach a helpline even when the app is locked.

5b. Data breach response

We operate a documented data breach response process covering identification, containment, assessment, notification and remediation. Where a personal data breach is likely to result in a risk to your rights and freedoms we will notify the Information Commissioner's Office within 72 hours of becoming aware of it, as required by UK GDPR, and we will notify affected individuals without undue delay where the risk is high. Named responsibilities and steps are set out in our internal incident response procedure and summarised on our risk management page.

6. Retention

We keep information only as long as needed for the purposes above, including legal, tax and dispute resolution needs. In short:

• Account, check-ins, notes, tags and programme progress: kept while your account is active
• Deleted accounts: scheduled for permanent erasure 30 days after you request deletion (a grace period so you can restore by mistake)
• Diagnostics / crash data: retained for a limited period for stability and security
• Server and CDN logs: retained for a short period

You may delete local data from the App where the feature is offered. When you delete your account in the App we schedule permanent erasure after 30 days; you may restore the account by signing in and choosing restore before that date. See our account deletion page for steps. Contact us if you need help with cloud-held data tied to your account.

7. Your rights

Subject to UK law you may have the right to:

• Access, rectify or erase personal data
• Restrict or object to certain processing
• Data portability where applicable
• Withdraw consent where processing is consent-based
• Lodge a complaint with the ICO (ico.org.uk)

Contact privacy@mindguard365.com to exercise your rights. We may need to verify your identity.

We aim to respond to rights requests within one calendar month of receiving a valid request. For requests that are complex or where you have made several requests, we may extend this by up to a further two months as permitted by UK GDPR. If we need to extend the deadline we will tell you within the first month and explain why.

8. Children and young people

Mind Guard 365 is intended for people aged 13 and over. We ask you to confirm your age in our terms; we do not run intrusive age verification. We do not knowingly collect personal information from children under 13, and if you believe a younger child has provided data, contact us and we will take appropriate steps.

Because a wellbeing app may be accessed by people aged 13 to 17, we have considered the ICO Age Appropriate Design Code (the Children's Code). We aim to apply its principles through high-privacy defaults, collecting only what we need, not selling personal data and not serving personalised advertising to users who may be minors. We assess this in our DPIA (see section 10).

9. Users in the United States

If you use Mind Guard 365 from the United States, the following also applies:

• Your choices (CCPA/CPRA and similar state laws): you may request access to, correction of or deletion of your personal information, and you may appeal a decision. We do not sell your personal information and we do not share it for cross-context behavioural advertising; you do not need to opt out of a sale that we do not make.
• Under-16s: we do not knowingly sell or share the personal information of consumers under 16.
• HIPAA: Mind Guard 365 is a direct-to-consumer self-help app. Mind Guard 365 Ltd is not a HIPAA covered entity or business associate, and we do not process protected health information (PHI) on behalf of any healthcare provider, plan or clearinghouse.

10. Data protection impact assessment

Because we process sensitive mental wellbeing data, we maintain a Data Protection Impact Assessment (DPIA) that records the risks of this processing and how we mitigate them. We review it when we make material changes to the service.

11. Medical disclaimer

Mind Guard 365 offers self-help and educational tools. It is not a medical device and does not replace professional advice, diagnosis or treatment. It does not diagnose, treat or monitor any health condition. If you are in crisis use local emergency services or a trusted helpline; see our safety and crisis support page.

12. Changes

We may update this policy from time to time. We will post the new date at the top and, where appropriate, provide additional notice in the App or by email. If the purposes for which we process your personal data change materially, we will update this policy first, and where our legal basis is consent we will ask you for it again before relying on the new purpose.