PRIVACY POLICY
Policy version: 01 June 2026
1 Introduction
This Privacy Policy is provided by HearMeNow.AI Ltd a company incorporated in England and Wales with Company Number 16624622 and registered office address of 8 Cornmill Mews, Leighton Buzzard, United Kingdom, LU7 1FY (‘we’, ‘our’ or ‘us’) for use of our website www.hearmenow.ai (Website) and our Web-App “Hear Me Now” hearmenow.ai (App) (together, the 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) (Privacy Laws).
We are the controller of personal data obtained via the Services, 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 Services only.
The Services 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 Services. 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. Please note that certain sessions and appointments facilitated through the Services may be conducted via third-party video conferencing platforms (such as Zoom or Google Meet). We are not responsible for the collection, use or storage of your personal data by those third-party platforms or for any use of AI tools by your Clinic or therapist in connection with sessions conducted on those platforms. We recommend you review the privacy policies of any such third-party platforms directly.
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 and account data when you create an account on our App | · Your name, phone number and email address · Your account details, such as username and password |
Data collected when you use specific functions in the Services | Data you store online with us using the Services including your usage history or preferences (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) |
Clinical data processed on behalf of your therapist | Messages and communications between you and your therapist; session notes and records; intake and assessment forms; risk assessment plans and safety plans; supervision logs; and any other clinical data uploaded to or generated through the Services, in each case processed solely on the instruction of the relevant Clinic as data controller and in accordance with our Data Processing Agreement |
User-controlled personal data you create independently within the Services | Journal entries, mood tracking data, self-reflection entries and any other personal content you create and store independently within the Services (for which you are the data controller). Where your linked therapist or Clinic leaves the platform, you will be notified and given the opportunity to export this data within the applicable retention period before it is permanently deleted. |
Other data the Services collects automatically when you use it | · Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use · IP address, device type, IMEI 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 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 DATA OR Sensitive Data
Certain personal data we collect is treated as a ‘special category’ to which additional protections apply under applicable Privacy Laws. This is also known as ‘Sensitive Data’. Where we process such Sensitive Data, including details about your health, we collect and use this Sensitive Data only on the instruction of your relevant Clinic (as defined in the Platform Terms and Conditions) who is the controller of such data for the purposes of the Privacy Laws. We act solely as the data processor in respect of such data and shall process it only as set out in our Data Processing Agreement available here: https://hearmenow.ai/data-processing-agreement . We do not use Sensitive Data for our own purposes, and we do not make any automated decisions based on Sensitive Data. For the avoidance of doubt, we do not record therapy sessions or use AI transcription tools on session content.
5 How your personal data is collected
We collect personal data from you directly when you sign up for an account, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using our Services.
We may also collect or process personal data about you from third parties, including:
(i) when you provide your personal data or sensitive data to a Clinic (as defined in the App Terms & Conditions);
(ii) if you use our social media sites or applications or other third party products and services that interact with, or connect with, the Services.
(iii) if third party payment processors are used by us to process payments made by you.
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 |
Create and manage your account with us | To perform our contract with you or to take steps at your request before entering into a contract |
Providing the App 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 App) |
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 Services 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 products, App and other 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 Services) · 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 (in this case, the contract means the Terms and Conditions which apply to the App) · 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 Marketing
We intend to send you email marketing to inform you of our services such as promotions.
We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
o contacting us at support@hearmenow.ai
o using the ‘unsubscribe’ link included in all marketing emails you may received from us
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
8 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 Services, including developers and cloud storage providers.
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
§ in the event that a Clinic or therapist using our Services becomes incapacitated or passes away, their nominated executor may contact us to request access to data held on the platform. We will only grant such access following receipt of satisfactory verification documents, which will include (as applicable) a copy of the clinical will, a death certificate, and the executor’s identification documents. Any such access will be limited to the data retained within the applicable 6-month retention window. Where a therapist has not nominated an executor, or where the executor does not contact us within the 6-month retention period, the account will be subject to our standard data deletion process as described above. You acknowledge and agree that in such circumstances your data (including clinical records) may be shared with the verified executor of your therapist or Clinic.
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.
9 How long your personal data will be kept
(a) We will keep your personal data for as long as you have an active account with us. The retention period that applies to your personal data will depend on the capacity in which we hold it:
(i) Data held as Data Controller (therapist account and profile data, subscription and financial records): we will retain this data for a period of up to 6 years following account closure to comply with applicable accounting, tax and legal obligations including in the event of the pursuit or defence of legal claims. Please note that therapists are individually subject to professional and regulatory obligations to maintain clinical records for a minimum period of 8 years (or longer where required by applicable professional body guidelines or law). This obligation rests with the therapist personally and is independent of our retention practices as Data Controller. Therapists are responsible for exporting and retaining any clinical records they are required to preserve under such obligations prior to account closure or the expiry of the applicable data retention period.
(ii) Data held as Data Processor (client and patient records, session notes, intake forms, messages and other clinical data processed on the instruction of a Clinic): we will retain this data in accordance with the instructions of the relevant Clinic (data controller) and the terms of our Data Processing Agreement. Where a Clinic’s subscription lapses or is terminated, the following process will apply: (A) during a 14-day grace period following non-payment, the account will be suspended but all data will be retained and the Clinic may reinstate their account by settling payment; (B) following expiry of the grace period, data will be retained for a further period of 6 months from the date of last payment; (C) at the end of that 6-month period, a formal written notice will be sent to the Clinic’s registered email address giving 30 days to export their data; and (D) if no action is taken within 30 days of that notice, all associated data will be permanently deleted and a deletion log will be created. Monthly reminders will be sent to the Clinic during the 6-month retention period.
(b) Following the end of the applicable retention period described above, we will delete or anonymise your personal data in accordance with our obligations under UK GDPR.
10 FOR USERS IN THE UNITED KINGDOM
10.1 TRANSFERRING YOUR PERSONAL DATA 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 an appropriate safeguard 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.
10.2 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 Services. |
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.
For Users in the United Kingdom, 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 Services 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: