Your privacy matters.

MindEmpower is a self-help and wellbeing app operated by RM Digital Services Ltd / MindEmpower.

RM Digital Services Ltd is the data controller for personal data processed through MindEmpower unless otherwise stated.

For privacy questions, data-rights requests or account deletion requests, contact support@mindempower.co.uk.

MindEmpower is an adult self-help and wellbeing application providing CBT-informed educational exercises, reflective tools, planning tools and wellbeing tracking to support users in practising psychological wellbeing skills.

MindEmpower is not intended to diagnose, prevent, monitor or treat a mental-health disorder, provide medical advice, or replace professional assessment or treatment.

MindEmpower is intended for adults aged 18 and over. You should not create an account or use MindEmpower if you are under 18.

Account data

We may process your email address, Firebase Authentication user identifier and other technical account information required to create, authenticate and operate your account.

User content you choose to enter

Depending on the features you use, you may choose to enter information such as:

• CBT exercise entries;
• wellbeing reflections;
• worries and worry diary entries;
• thought records;
• goals;
• personalised CBT vicious-cycle information;
• Behavioural Activation diary information;
• problem-solving entries;
• panic-related exercises;
• exposure plans and records;
• sleep diary information;
• to-do items;
• assertive communication drafts;
• questionnaire responses or scores;
• safety-plan content.

Safety Plan information

Your Safety Plan may contain particularly sensitive information, such as warning signs, coping strategies, people you may contact, safe places or information about what helps you stay safe.

Only enter information that you are comfortable storing in the app. MindEmpower does not monitor your Safety Plan or automatically contact emergency services or support contacts.

Settings and app preferences

We may process settings required to provide the features you choose, such as:

• notification and reminder preferences;
• selected or pinned tools;
• tool-introduction or onboarding flags;
• Daily Mind Practice completion or streak information;
• app-lock preferences;
• other app settings.

Feedback and support

If you submit feedback, a bug report or contact support, we process the information you choose to provide so that we can review your feedback or respond to you.

Technical and analytics information

We may process limited technical and usage information to operate, secure and improve MindEmpower.

Depending on your settings and whether analytics collection is enabled, this may include:

• app opens and sessions;
• general feature or screen usage;
• whether a particular app tool was opened or completed;
• Daily Mind Practice starts or completions;
• general engagement and retention information;
• app version;
• device or operating-system information;
• technical or error information needed to understand reliability problems.

Some information you choose to enter may reveal or relate to your physical or mental health, emotional wellbeing, anxiety, low mood, panic, sleep or safety planning.

This information may constitute special-category personal data under UK data-protection law.

We may use personal data to:

• create and manage your account;
• authenticate you;
• save and retrieve your entries;
• show your saved progress over time;
• provide the CBT-informed and wellbeing features you choose to use;
• provide reminders and settings you request;
• provide Daily Mind Practice and related features;
• provide safety-planning features;
• allow you to export or share information where you choose to do so;
• keep MindEmpower secure;
• prevent or investigate misuse;
• respond to support and data-rights requests;
• identify and fix technical problems;
• understand general app engagement where analytics is lawfully enabled;
• improve MindEmpower's usability, reliability and safety.

MindEmpower does not use your app content to make decisions about your medical treatment or healthcare.

We rely on different lawful bases under Article 6 of the UK GDPR depending on why information is being processed.

Contract

Where processing is necessary to provide features you request through your MindEmpower account, we may rely on performance of a contract.

This may include:

• account access;
• authentication;
• saving and retrieving entries;
• progress tracking;
• settings and requested app functionality.

Legitimate interests

We may rely on legitimate interests where necessary to operate a safe, secure and reliable service.

Our legitimate interests may include:

• preventing misuse or unauthorised access;
• maintaining security;
• investigating technical faults;
• improving reliability;
• responding to support enquiries;
• maintaining proportionate compliance records.

Where we rely on legitimate interests, we consider whether the processing is necessary and balanced against the rights and expectations of users.

Consent

We may rely on consent for optional activities such as voluntary feedback and for non-essential analytics or similar measurement where consent is required.

Legal obligation

We may process limited information where necessary to comply with applicable legal or regulatory obligations.

Where information you choose to enter constitutes special-category health or mental-health data, MindEmpower relies on your explicit consent under Article 9(2)(a) to process that information for the purpose of providing the app features you choose to use.

During account creation, you are asked to separately confirm your explicit consent to the processing of health and wellbeing information that you choose to enter.

You can withdraw this consent. Because many MindEmpower features depend on storing information you have chosen to enter, withdrawing consent may mean that we can no longer provide those features and may require deletion of the relevant information or your account.

Contact support@mindempower.co.uk if you want to withdraw consent or request deletion.

MindEmpower may use Firebase / Google Analytics to understand how people use the app and which features are useful.

Analytics may measure events such as:

• opening the app;
• opening a particular tool;
• completing a tool;
• starting or completing Daily Mind Practice;
• general engagement or return usage.

Analytics events use predefined event names and are not intended to contain the content you type into MindEmpower.

Analytics information is used for product measurement, reliability and app improvement. It is not used to provide personalised medical advice or make healthcare decisions about you.

MindEmpower uses Google Firebase services, including Firebase Authentication and Cloud Firestore.

App data is generally organised under your Firebase user identifier, for example: users/{uid}/....

Firestore Security Rules are used to restrict authenticated app users to their own user data.

Some preferences, tool-introduction flags or temporary information may also be stored locally on your device using storage such as AsyncStorage.

Local information may remain on the device until it is cleared, overwritten, removed through an available app function, or the app/device storage is deleted.

Your app data is intended to be accessible through your authenticated MindEmpower account.

Authorised MindEmpower / RM Digital Services Ltd administrator access may also be possible where reasonably necessary for purposes such as:

• support;
• account or data deletion;
• data-rights requests;
• security;
• technical debugging;
• legal or compliance requirements.

We use third-party services to operate MindEmpower. These may include:

• Google Firebase: authentication, Cloud Firestore database storage, hosting, security and app infrastructure.
• Firebase / Google Analytics: limited app-usage and engagement measurement where enabled.
• Firebase App Check: where enabled, to help protect backend resources from unauthorised access.
• Google Forms: optional feedback and bug-report forms.
• Email provider: where you contact MindEmpower support.
• Apple App Store / Google Play: where applicable for distribution and future subscription or payment processing.

Some service providers may process personal information outside the UK.

Where this occurs, we rely on applicable contractual safeguards and international-transfer mechanisms provided or required under UK data-protection law.

Feedback and bug-report forms are for product improvement and technical feedback only.

They are not monitored as a clinical, crisis or urgent-support channel.

Please do not submit detailed clinical information, crisis information, Safety Plan information or other highly sensitive information through these forms.

MindEmpower may occasionally be evaluated through limited pilots.

Where you are invited to participate in a pilot, you should be provided with information explaining what participation involves and how pilot feedback or usage information will be used.

Participation and optional feedback should be voluntary.

Where a pilot takes place alongside healthcare or guided self-help, choosing not to participate should not affect the healthcare or support you receive.

MindEmpower may allow you to create or share summaries or PDFs containing information you have entered.

Export and sharing actions are controlled by you. Check the intended recipient carefully before sending sensitive information.

If you enable reminders or notifications, notification information may be displayed by your device, including on the lock screen depending on your device settings.

MindEmpower aims to use neutral reminder wording and avoid including sensitive CBT or mental-health content in notifications.

• Account and app content: generally retained while your account is active unless you delete it or request deletion sooner.
• Support emails: normally retained for up to 24 months where needed to respond to and evidence support requests.
• Feedback and bug reports: normally retained for up to 24 months where useful for product improvement.
• Analytics information: retained according to the configured retention period within the analytics service and reviewed periodically.
• Technical and security information: retained only for as long as reasonably required for security, troubleshooting and reliability purposes.
• Backups: deleted information may remain temporarily within backups before being overwritten or deleted through normal provider processes.

You may request deletion of your MindEmpower account and associated personal data through the available account-deletion route in the app or by emailing support@mindempower.co.uk.

We aim to process valid deletion requests without undue delay.

Some limited information may be retained where required for legal, security, dispute-resolution or compliance reasons.

Deleted information may also remain temporarily in provider backups before being removed through normal backup processes.

Depending on the circumstances, UK data-protection law may give you rights including:

• access to your personal data;
• correction of inaccurate information;
• deletion of personal data;
• restriction of processing;
• objection to certain processing;
• data portability where applicable;
• withdrawal of consent where processing relies on consent.

To exercise your rights, contact support@mindempower.co.uk.

Where we rely on your consent, you can withdraw it at any time.

Withdrawal does not make processing that occurred before withdrawal unlawful.

To withdraw explicit consent for processing health or wellbeing information, you can request deletion of your relevant information or account, or contact support@mindempower.co.uk.

If you are unhappy with how we handle your personal information, please contact us first so that we can try to resolve the issue.

You also have the right to complain to the UK Information Commissioner's Office (ICO).

We may update this Privacy Policy as MindEmpower develops or where our processing practices, service providers, legal requirements or app functionality change.

The latest version will be made available through MindEmpower and/or the MindEmpower website.