Platform privacy policy
Effective date: 1 October 2026. How Humainly handles your personal data when you use the app, including your coaching conversations.
Scope. This policy covers the Humainly platform at app.behumainly.com and the Humainly mobile applications. It applies to individuals who register directly and to people given access by an employer. Processing specific to social-care customers is covered by the Humainly Care Services Privacy Supplement. The website at behumainly.com has its own notice.
Where Humainly operates. The platform is offered in the United Kingdom, the United States and India. Humainly is established in the United Kingdom and processes personal data under the UK GDPR wherever you are. People in India have further rights under the Digital Personal Data Protection Act 2023. People in some United States states have rights under their own state privacy laws. Humainly honours those rights on request through privacy@behumainly.com. Humainly does not offer the platform to individuals in the European Economic Area.
1. INTRODUCTION AND SCOPE
1.1 This privacy policy (the “Policy”) is issued by Humainly Ltd, a company incorporated in England and Wales with company number 17279934 whose registered office is at 11 Broadgates Avenue, Barnet, England, EN4 0NU (“Humainly”, “we”, “us” or “our”). Humainly is registered with the Information Commissioner’s Office (the “ICO”) under registration number CSN0826634.
1.2 This Policy explains how Humainly collects, uses, discloses and protects personal data in connection with:
(a) the Humainly workplace development platform, comprising coaching delivered by artificial intelligence by means of text chat and live voice, human coaching (including booking, video sessions and messaging), structured development programmes incorporating written reflections, podcasts, progress tracking, and the associated portal made available to professional coaches (together, the “Platform”);
(b) the website at behumainly.com (the “Website”); and
(c) other interactions between you and Humainly.
1.3 This Policy should be read together with the Humainly Cookie Notice, the Humainly Data Retention Policy and, where your organisation is a social-care provider, the Humainly Care Services Privacy Supplement (the “Care Supplement”).
1.4 Humainly processes personal data in accordance with the UK General Data Protection Regulation (the “UK GDPR”), the Data Protection Act 2018 and, where applicable, Regulation (EU) 2016/679 (the “EU GDPR”) (together, the “Data Protection Legislation”).
2. DEFINITIONS
2.1 In this Policy, the following terms have the following meanings:
| Term | Meaning |
|---|---|
| Coach | A professional coach who provides human coaching services to Users through the Platform. |
| Coaching Content | A User’s coaching conversations with the artificial intelligence coach, transcripts of voice coaching sessions, messages exchanged with Coaches, written reflections, goals, commitments and progress records. |
| Customer | The organisation (for example, an employer or a social-care provider) which has entered into an agreement with Humainly for the provision of the Platform. |
| DPF | The EU-US Data Privacy Framework operated by the United States Department of Commerce. |
| SCCs | The standard contractual clauses for the transfer of personal data to third countries adopted by the European Commission, as supplemented where applicable by the UK International Data Transfer Addendum issued by the ICO (the “UK Addendum”). |
| Sub-processor | A third party service provider engaged by Humainly to process personal data in connection with the Platform, as listed in Schedule 1. |
| UK Extension | The UK Extension to the DPF, given effect in the United Kingdom by the Data Protection (Adequacy) (United States of America) Regulations 2023. |
| User | An individual authorised to use the Platform, including an employee or caregiver of a Customer. |
3. ROLES AND RESPONSIBILITIES
3.1 In the ordinary course, a User is granted access to the Platform pursuant to an agreement between Humainly and the Customer.
3.2 Coaching Content is processed by Humainly on the Customer’s behalf solely for the purpose of providing the Platform to the User, subject to a standing confidentiality instruction in the agreement between Humainly and the Customer under which the Customer has no access to Coaching Content, as further described in clause 8.
3.3 Account data (such as a User’s name, email address and role) is processed by Humainly and by the Customer in connection with the administration of the User’s access to the Platform.
3.4 The allocation of controller and processor responsibilities as between Humainly and the Customer in respect of each category of personal data is recorded in the agreement between Humainly and the Customer.
3.5 Where an individual registers for the Platform directly, and not through a Customer, Humainly is the controller of that individual’s personal data.
4. CATEGORIES OF PERSONAL DATA
4.1 Account data. Name, email address, organisation, role and profile information. Sign-in credentials are managed by Humainly’s authentication Sub-processor (Clerk); Humainly does not have access to User passwords.
4.2 Coaching Content. As defined in clause 2.1.
4.3 Voice data. Where a User dictates a message rather than typing it, the recording is sent for transcription and the text is kept; the audio is not stored by Humainly at any point. Transcription providers may retain submitted audio transiently, for up to approximately 30 days, for abuse monitoring under their own controls. Live spoken coaching sessions are not currently offered. If they are introduced, speech will be transcribed in real time and the audio will not be written to storage.
4.4 Human coaching data. Booking and scheduling records and participation in video sessions. Live video and voice sessions are transmitted in real time through Humainly’s infrastructure Sub-processor (LiveKit) and are not recorded.
4.5 Calendar data (optional). Where a User connects a calendar, Humainly processes calendar event data to support scheduling. Connection tokens are encrypted using AES-256-GCM. Calendar event data is retained for no more than 30 days.
4.6 Analytics data (opt-in only). Humainly collects product analytics, including session replay, only where the User has given consent through the consent banner or the settings within the Platform. Where consent has not been given, no analytics data is collected. Analytics data is hosted within the European Union by Humainly’s analytics Sub-processor (PostHog).
4.7 Technical data. Error reports, which may incidentally contain personal data, and security audit logs recording administrative and account actions.
4.8 Payment and subscription data. Where an individual buys a subscription, Humainly records what was bought, the price, the currency, the billing period, the renewal date and whether the subscription is active, cancelled or in arrears, together with the identifiers its payment Sub-processor uses for the customer and the subscription. Card numbers are entered directly with Stripe and are never received, seen or stored by Humainly. Billing name, billing address and the last four digits of the card are held by Stripe and are visible to Humainly only through Stripe's own dashboard.
4.9 Referral data. Where a member invites somebody on their own invite link, Humainly records the code, who invited whom, when the invitation was taken up and the coaching minutes credited to each side. The person invited is told who invited them. The person inviting is told how many people have joined, and is not told anything else about them.
4.10 Feedback. Where a User answers a question after a session, rates a reply, or writes to Humainly through the feedback door, Humainly records the answer, any words written, which session or coach it concerned, and whether the User marked it as something Humainly should know about. Feedback about a coach is read by Humainly staff only. It is never shown to another member, never shown to that coach as a score, and is never used to rank or rate coaches anywhere in the product.
4.11 Saved items. The coaches, topics, programmes and library pieces a User has bookmarked.
5. SPECIAL CATEGORY DATA
5.1 Coaching conversations are personal in nature. A User may choose to raise matters concerning their health or mental wellbeing, which constitute special category data within the meaning of Article 9 of the UK GDPR.
5.2 Where Coaching Content includes special category data, Humainly processes that data solely for the purpose of providing the coaching service to the User, subject to the safeguards described in this Policy.
5.3 Where an individual registers directly, Humainly relies on the condition at Article 9(2)(a) of the UK GDPR: the individual's explicit consent, given separately at sign-up, to the processing of Coaching Content that may concern health or mental wellbeing. That consent is requested on its own, is not bundled with acceptance of the Terms of Service, is not pre-ticked, and may be withdrawn at any time in Settings. Withdrawing it means the artificial intelligence coach can no longer be used, because the processing is the service; it does not affect the lawfulness of anything done beforehand, and it does not affect human coaching.
5.4 Where an individual is given access by an employer, explicit consent is not relied upon, because consent given in an employment relationship is not reliably freely given. In that case Humainly does not process Coaching Content by the artificial intelligence systems described in clause 7 unless the individual separately opts in, and the appropriate Article 9 condition for that arrangement is being confirmed before any employer-provided access resumes.
6. PURPOSES AND LAWFUL BASES OF PROCESSING
6.1 Humainly processes personal data for the purposes, and on the lawful bases, set out in the table below.
| Processing purpose | Lawful basis (UK GDPR) |
|---|---|
| Provision of the Platform, including coaching, development programmes and progress tracking | Article 6(1)(b): performance of a contract |
| Processing of Coaching Content by the artificial intelligence systems described in clause 7 | Article 6(1)(b): performance of a contract; in respect of special category data, Article 9(2)(a): explicit consent, as described at clause 5.3 |
| Disclosure of session transcripts or pattern summaries to a Coach | Article 6(1)(a): consent, given separately in respect of each Coach and each booking, and disabled by default |
| Product analytics and session replay | Article 6(1)(a): consent, which may be withdrawn at any time through the Platform settings |
| Service communications, including session summaries, notifications and inactivity warnings | Article 6(1)(b); Article 6(1)(f): legitimate interests |
| Security, audit logging and incident response | Article 6(1)(f): legitimate interests |
| Taking payment, managing a subscription and handling refunds | Article 6(1)(b): performance of a contract |
| Keeping payment and tax records | Article 6(1)(c): legal obligation |
| Operating the invite scheme and crediting coaching minutes | Article 6(1)(b): performance of a contract |
| Reading feedback in order to improve the service and to supervise the quality of coaching | Article 6(1)(f): legitimate interests, being the interest in a safe and competent service. Giving feedback is always optional |
| Compliance with legal and regulatory obligations | Article 6(1)(c): legal obligation |
6.2 Humainly does not use personal data for advertising purposes and does not sell personal data. Coaching Content is not used to train artificial intelligence models, whether by Humainly or by any Sub-processor.
7. ARTIFICIAL INTELLIGENCE PROCESSING
7.1 Generation of coaching responses. A User’s messages are transmitted to Humainly’s artificial intelligence Sub-processor (Anthropic) for the purpose of generating coaching responses, together with relevant context drawn from the User’s coaching history and goals in order to maintain continuity of coaching.
7.2 Voice processing. During live voice sessions, a User’s speech is streamed to a transcription Sub-processor (OpenAI or Groq) and converted to text in memory. The audio is then discarded and is not retained by Humainly in any form. Transcription Sub-processors may retain submitted audio transiently (up to approximately 30 days) for abuse monitoring under their own controls; Humainly is pursuing available zero-retention options. Spoken responses are generated from text by a speech synthesis Sub-processor (OpenAI).
7.3 No model training. Humainly’s artificial intelligence Sub-processors are contractually prohibited from using Coaching Content to train their models.
7.4 Coach access controls. A Coach has no access to a User’s Coaching Content unless and until the User enables such access. Two separate consents apply, each of which is disabled by default:
(a) transcript access, by which the User determines, in respect of each individual booking, whether the relevant Coach may read the transcript of that session; and
(b) pattern summaries, by which the User may permit the artificial intelligence system to notify the User’s Coach of recurring themes. Such summaries are sanitised before disclosure, such that the Coach does not see the User’s actual words, and the User may configure this setting separately in respect of each Coach.
7.5 Automated decision-making. The artificial intelligence coach provides suggestions only. It does not make decisions producing legal effects concerning the User or similarly significant effects within the meaning of Article 22 of the UK GDPR. The Platform is not a substitute for professional medical or mental health advice.
8. CUSTOMER ACCESS TO USER DATA
8.1 The Customer has no access to a User’s Coaching Content, including conversations, transcripts, reflections, messages and goals. This restriction is enforced within Humainly’s application programming interface and not solely within the user interface.
8.2 The Customer receives only anonymised and aggregated engagement information, such as overall usage levels across its workforce.
9. DISCLOSURES AND SUB-PROCESSORS
9.1 Humainly engages the Sub-processors listed in Schedule 1, each of which is bound by a written data processing agreement.
9.2 Humainly will update Schedule 1 and will notify Customers in advance of the appointment or replacement of any Sub-processor, in accordance with the data processing agreement between Humainly and the Customer.
9.3 Humainly may disclose personal data where required to do so by law, regulation, legal process or enforceable governmental request, or where disclosure is necessary to protect the rights, property or safety of Humainly, Users or the public.
10. INTERNATIONAL TRANSFERS
10.1 Personal data is stored primarily within the European Union: Humainly’s primary database is hosted in an EU region.
10.2 Where a Sub-processor processes personal data in the United States, Humainly relies on the following transfer mechanisms:
(a) in respect of Sub-processors certified under the DPF and the UK Extension, the UK Extension (and, in respect of transfers subject to the EU GDPR, the DPF); and
(b) in respect of Sub-processors not so certified (Anthropic, OpenAI and Groq), the SCCs together with the UK Addendum or the UK International Data Transfer Agreement, supported by transfer risk assessments, which are available on request.
10.3 A copy of the relevant safeguards may be requested by contacting privacy@behumainly.com.
11. DATA RETENTION
11.1 Personal data is retained for no longer than is necessary for the purposes for which it was collected, in accordance with the retention periods summarised in Schedule 2 and set out in full in the Humainly Data Retention Policy.
11.2 Retention periods are enforced by an automated process which runs daily, save where Schedule 2 indicates otherwise.
11.3 Records subject to statutory retention obligations in the social-care sector are addressed in the Care Supplement and are excluded from the standard erasure processes described in this Policy.
12. RIGHTS OF DATA SUBJECTS
12.1 Subject to the conditions and exemptions in the Data Protection Legislation, a User has the rights of access, rectification, erasure, restriction of processing, data portability and objection, together with the right to withdraw consent at any time in respect of processing based on consent.
12.2 Access and portability. A User may obtain a complete copy of their personal data in JSON format (a structured, commonly used and machine readable format) at any time by means of the “Export my data” function in the Platform settings, on web and on mobile. The export is generated and made available for download immediately upon request.
12.3 Erasure. A User may delete their account at any time by means of the “Delete my account” function in the Platform settings, on web and on mobile. Upon initiation of deletion:
(a) the User’s records are erased or anonymised across Humainly’s live systems by an audited deletion process;
(b) the User’s sign-in identity is deleted at Humainly’s authentication Sub-processor; and
(c) residual copies held in encrypted backups expire automatically, such that erasure is complete, including in respect of backups, within 30 days.
12.4 Erasure under clause 12.3 is subject to the exemptions in Article 17(3) of the UK GDPR, including in respect of records which Humainly is required by law to retain. Statutory social-care records are addressed in the Care Supplement.
12.5 Coach accounts. The in-application deletion function is not available to Coaches, because Users’ booking records reference the relevant Coach. Coach accounts are offboarded manually upon request to privacy@behumainly.com.
12.6 Rectification. A User may correct their profile information within the Platform settings or by contacting Humainly.
12.7 Consent management. Consents relating to analytics, transcript access and pattern summaries may each be granted and withdrawn at any time through the Platform settings.
12.8 Any other request, or any request by an individual unable to access the Platform, may be made to privacy@behumainly.com. Humainly will respond within one month of receipt of the request, which period may be extended by up to two further months where requests are complex or numerous.
12.9 A User has the right to lodge a complaint with the ICO (ico.org.uk; telephone 0303 123 1113) or, where the EU GDPR applies, with the supervisory authority of the member state of the User’s habitual residence, place of work or place of the alleged infringement.
13. SECURITY
13.1 Humainly implements appropriate technical and organisational measures, including: encryption in transit using TLS 1.3; encryption at rest; AES-256-GCM encryption of integration tokens; role-based access controls enforced within the application programming interface; logical separation of Customer data; tamper-evident, append-only audit logging; and analytics on an opt-in basis only. Further information is available at behumainly.com/security.
14. COOKIES AND SIMILAR TECHNOLOGIES
14.1 The Platform uses strictly necessary cookies and, subject to consent, the analytics described in clause 4.6. The Website does not currently deploy any analytics or advertising trackers. Further detail is set out in the Humainly Cookie Notice.
15. CHILDREN
15.1 The Platform is intended for use by adults in a professional context. Humainly does not knowingly process the personal data of any individual under the age of 18.
16. CHANGES TO THIS POLICY
16.1 Humainly may update this Policy from time to time. Material changes will be notified to Users by email or through the Platform before they take effect, and the updated Policy will be published with a revised effective date.
17. CONTACT
17.1 Questions, concerns and requests relating to this Policy or to Humainly’s processing of personal data should be addressed to privacy@behumainly.com, or by post to Humainly Ltd, 11 Broadgates Avenue, Barnet, England, EN4 0NU.
17.2 Humainly has not appointed a data protection officer. Article 37 of the UK GDPR does not require one: Humainly is not a public authority, and its processing of special category data is not carried out on a large scale within the meaning of that Article. This position is reviewed as the platform grows.
17.3 If you are not satisfied with how Humainly has handled your personal data you may complain to the Information Commissioner's Office at ico.org.uk, by telephone on 0303 123 1113, or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. You may do so without contacting Humainly first, although we would rather have the chance to put it right.
SCHEDULE 1: SUB-PROCESSORS
Each Sub-processor is engaged under a written data processing agreement. “DPF (UK Extension)” indicates certification under the EU-US Data Privacy Framework including the UK Extension.
| Sub-processor | Service provided | Personal data disclosed | Location | Transfer safeguard |
|---|---|---|---|---|
| Clerk, Inc. | Authentication and identity management | Name, email address, sign-in metadata | United States | DPF (UK Extension) |
| Anthropic, PBC | Generation of artificial intelligence coaching responses | Coaching chat messages, transcripts, profile signals | United States | SCCs with UK Addendum; contractual prohibition on model training |
| OpenAI, L.L.C. | Voice transcription for dictation, and speech synthesis for generated audio | Voice audio (transient), transcripts | United States | SCCs with UK Addendum; no use for model training. Submitted data may be retained by OpenAI for up to approximately 30 days for abuse monitoring |
| Groq, Inc. | Voice transcription (alternative processing path) | Voice audio (transient) | United States | SCCs with UK Addendum |
| ElevenLabs, Inc. | Speech synthesis | Text generated by the artificial intelligence coach only; no User content | United States | DPF (UK Extension) |
| LiveKit, Inc. | Real-time voice and video session infrastructure | Real-time audio and video streams (not recorded) | United States | DPF (UK Extension); SCCs with UK Addendum as fallback |
| Resend, Inc. | Transactional email | Email addresses, emailed session summaries | United States | DPF (UK Extension) |
| Neon, LLC (a Databricks company) | Primary database | All Platform data | European Union (EU region hosting) | Data hosted in the EU; DPF (UK Extension) in respect of any United States access |
| Railway Corp | Application hosting | Platform data in the course of processing | United States | DPF (UK Extension) |
| Vercel Inc. | Web hosting | Technical data | United States | DPF (UK Extension) |
| Cloudflare, Inc. | Storage of static assets and podcast audio | No User personal data | United States | DPF (UK Extension) |
| Functional Software, Inc. (Sentry) | Error monitoring | Personal data appearing incidentally in error reports. Request bodies, cookies, authorisation headers and query strings are removed before an error is sent, and the user is reduced to an identifier. No session recording. | European Union (EU region hosting) | Data hosted in the EU; DPF (UK Extension) in respect of any United States access |
| PostHog, Inc. | Product analytics and session replay (opt-in only), and server-side error reports | Usage events and session replays of consenting Users. Unhandled server errors, which may incidentally contain personal data | European Union (EU hosting) | Data hosted in the EU; SCCs in respect of residual United States access |
| Google LLC | Calendar integration (optional) | Calendar event data; encrypted access tokens | United States | DPF (UK Extension) |
| Stripe Payments Europe, Ltd. and Stripe, Inc. | Payment processing for individual subscriptions | Name, email address, billing address, subscription and payment status. Card details are entered directly with Stripe and are never received or stored by Humainly. | Ireland and United States | DPF (UK Extension); SCCs with UK Addendum as fallback |
| TypeSafe AI, Inc. | Typed classification of coaching content to route conversations, rank coach fit, interpret search and select safeguarding signals | Coaching chat messages and transcripts, a User's own description of what they want to work on, search queries. No name, email address or account identifier is sent. | United States | SCCs (Module 2) with UK Addendum; contractual prohibition on model training; zero data retention |
| Slack Technologies, LLC (a Salesforce company) | Internal operational alerting | Name and email address of waitlist registrants; questions asked on the public landing page; member feedback including free text about a session, and the name of the member and the coach | United States | DPF (UK Extension); SCCs with UK Addendum as fallback |
SCHEDULE 2: SUMMARY RETENTION SCHEDULE
The full schedule, including justifications and enforcement mechanisms, is set out in the Humainly Data Retention Policy.
| Category of data | Retention period | Remarks |
|---|---|---|
| Coaching Content (chat records, transcripts, written reflections, messages, goals and progress records) | Duration of the User account | Erased or anonymised upon account deletion or inactivity erasure |
| Voice audio | Not retained | Transcribed in real time; audio is not written to storage at any point |
| Inactive User accounts | 24 months of inactivity, followed by a warning notification and a 30 day grace period, then full erasure | Automated daily process |
| Calendar event data | 30 days | Automated daily process |
| Notifications | 90 days | Automated daily process |
| Security audit logs | 12 months | Append-only, tamper-evident records; trimmed quarterly under manual control |
| Error reports | Up to 90 days | Provider-side retention (Sentry) |
| Analytics data (opt-in only) | 12 months | Deleted by the analytics provider on a rolling 12-month window |
| Encrypted backups | 30 days maximum | Erased data expires from backups within the backup retention window |
| Payment and subscription records | 7 years from the end of the tax year in which the transaction occurred | Required for tax and accounting. Held by Humainly and by Stripe. Not erased on account deletion |
| Referral records | Duration of the account, then erased with it | The credited minutes are part of the account balance |
| Feedback | 24 months | Kept long enough to read quality over time, then erased. Erased sooner on request |
| Saved items | Duration of the User account | Erased on account deletion |
| Coach and administrator accounts | Duration of the agreement with the Customer | Offboarded manually |
| Statutory social-care records | As set out in the Care Supplement | Statutory retention obligations; excluded from standard erasure |
