Privacy Notice

Before the legal language, the short version.

What you write in your Room is yours. Teri cannot read it. Not by opening a screen, not by running a query, not by asking someone to fetch it. The only thing she ever sees is an Opening, which is a piece of writing you have deliberately chosen to share with her.

We do not sell anything to anyone. We do not track you around the internet. We do not use artificial intelligence to read, score, summarise or tag a single word you write. A real person reads what you share, and that is the whole point.

There is one limit to this, and we would rather tell you plainly than bury it. If something you share makes us seriously concerned that a child or an adult at risk is in danger, we may have to pass that concern on. Section 12 explains exactly how that works.

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1. Who we are and how to reach us

[LEGAL ENTITY NAME] ("The True Self", "we", "us") is the data controller for the personal information described in this notice. That means we decide what is collected and why, and we are accountable for it.

We have assessed whether we need to appoint a Data Protection Officer and concluded that we do not, because of the small scale of what we do. We keep that assessment written down and we will look at it again if the space grows. Teri Potter is personally accountable for data protection here, and she is the person who will answer if you write to us.

Because we handle special category data, we keep an Appropriate Policy Document as required by Schedule 1 of the Data Protection Act 2018, and we have carried out a Data Protection Impact Assessment for this space. You can ask to see either.

Our processor. The space is built and maintained for us by The KBI Group, who act as our data processor under a written contract. They keep the software running and secure. They do not use anything you write for their own purposes, and they are bound by the same confidentiality this notice describes.

2. What this notice covers

This notice covers:

• the public website at thetrueself.app
• A Place to Land, the private space a parent signs into
• emails we send you about your season
• messages you send us by email or through the contact form

It does not cover other websites we link to. If you follow a link to a resource, an organisation or a crisis service, that organisation has its own privacy notice and we have no control over it.

In My Room, the space for young people, is not yet open. When it opens it will have its own notice written for the people who will use it, and this notice will be updated to point to it.

3. Who this space is for

A Place to Land is for adults aged 18 or over who are parenting or caring for a young person. You must be 18 or over to hold an account.

Young people do not have accounts here. That is deliberate, and it is why nothing in this build collects a child's contact details, login or device information.

4. The information we hold

4.1 Information you give us when you join

We do not ask for your surname, your address, your date of birth, your phone number, your child's name or your child's age. We do not need them.

4.2 Information about your season

We never see or store your card details. Payment is taken by Stripe, who are regulated for exactly this. Card numbers go from you to Stripe and never touch our systems. We can see that a payment succeeded or failed, the amount, and the last four digits Stripe shows us. Nothing more.

4.3 What you write

This is the part that matters most, so it gets its own detail.

Your entries. Everything you write in your Room. Stored as text, with the date you wrote it and the date you last changed it.

Your Openings. When you choose to share a piece of writing with Teri, the space takes a copy of those words at that moment and stores it as an Opening. The copy is separate from the original. If you later edit or delete the original entry in your Room, the Opening does not change, because Teri may already have read it and replied to it.

Teri's replies. What she writes back, and when.

Safeguarding records. If a concern is raised, we record the concern, what was done about it and when. Section 12 explains this.

4.4 Special category data, and why we are careful

Under UK GDPR, information about a person's physical or mental health is "special category" data and gets stronger protection.

We cannot know in advance what you will write. Realistically, a parent writing honestly about a hard season may write about their own mental health, their child's, a diagnosis, a hospital appointment, medication, self harm, or a relationship in trouble. Any of that would be special category data.

So we treat everything you write in this space as special category data by default, whether or not it turns out to be. That is why we ask for your explicit consent before you write anything, and why the security described in section 10 applies to every word.

4.5 Information about other people

When you write about your child, your partner, your own parents or anyone else, you are writing personal information about someone who has not given us anything and may not know this space exists.

We handle that carefully:

• We do not build any record about the people you write about. There is no profile of your child anywhere in this system. Their words exist only inside yours.
• We do not ask for their names and we do not index or search on them.
• We do not contact them, ever, unless section 12 applies.
• Their information is kept and deleted on exactly the same terms as yours.

Please write what you need to write. We mention this only so you know what happens to it.

4.6 Technical information

We do not use analytics on the private space. There is no page view tracking, no session recording, no heat mapping and no behaviour scoring of any kind. Nobody is watching how long you spent on a screen.

4.7 If you only visit the public website

If you read the public pages and never sign in, we hold almost nothing about you. The public pages set no cookies at all, as the [Cookie Policy] explains. Nothing counts your visit and nothing knows you were there. If you use the contact form or email us, we hold what you send and our reply.

5. Where the information comes from

Almost all of it comes directly from you. The rest comes from Stripe, which tells us whether a payment succeeded, and when a card fails, and from our own systems, which record technical and security events.

We do not buy data. We do not enrich your record from other sources. We do not use data brokers.

6. Why we are allowed to hold it

UK GDPR requires a lawful basis for ordinary personal data, and a separate additional condition for special category data. Here is ours, in full.

On consent. You give explicit consent when you tick the second box on the join page, which is separate from the box confirming you have read this notice and the terms. That consent is what allows us to hold special category data, and you can withdraw it at any time. Section 11 explains what happens when you do. Withdrawing it does not make anything we did beforehand unlawful, and it does not affect the small amount of information we must keep for tax and safeguarding reasons.

7. What we do with it

• Give you a private place to write, and keep what you write safe
• Let you share an Opening with Teri when you choose to, and deliver her reply back to you
• Take payment for your season and manage seasons and their endings
• Send you the transactional emails listed below
• Give you the resources Teri has made available to you
• Keep the space secure and working
• Meet our legal and professional obligations

That is the whole list. We do not do anything else with it.

7.1 The emails we send

We send only what is necessary to run your season: confirming your email address, confirming you are in, telling you Teri has written back, telling you a period is nearly up, telling you a payment failed, telling you an export is ready.

We never put your words, or Teri's reply, in an email. The notification says something is waiting. It does not say what. Email is not a private enough place for either.

We do not send marketing. There is no newsletter, no offers, no re-engagement campaign. If that ever changes we will ask you first, separately, and you will be free to say no without it affecting anything.

7.2 What we never do

• We never sell, rent or share your information with anyone for their own purposes
• We never use anything you write to advertise, promote or illustrate this space, even anonymised, unless you have separately and specifically agreed in writing
• We never use artificial intelligence, machine learning, sentiment analysis, mood scoring, tagging or automated summarising on anything you write. There is no AI anywhere in the writing side of this space
• We never make an automated decision about you that has a legal or similarly significant effect. Nothing you write is scored, ranked, profiled or assessed, by a machine or by a person
• We never train any model on your writing, and our processors are contractually forbidden from doing so

One honest exception, and it is nowhere near your writing. Stripe runs automated fraud checks on card payments, which is normal and is how card fraud is stopped. That check looks at the payment and the device it came from. It never sees anything you have written, and it cannot. If a payment is ever declined by that check you can ask us to look at it and we will put it in front of a person. Stripe explains its checks at stripe.com/privacy.

8. The privacy wall

This is a promise about how the software is built, not just about how we behave.

• Your entries can be read only by an account signed in as you. This is enforced at the database level by row level security, so the rule holds no matter which screen, query or route is used.
• There is no policy of any kind that grants Teri's account access to your entries. Not a read policy, not a view, not a function that bypasses the rules, not an administrative override in her side of the space, not an export. The build was tested to prove that Teri's own account, querying the entries table directly, gets nothing back while entries exist.
• Teri's side of the space has no route to your private writing, because none was built.
• She sees an Opening only once you have shared it.
• Once an Opening is shared, neither of you can edit it. What was said is said. You can still ask us to erase it under section 11, and we will.
• Every time she opens an Opening or sends a reply, that is written to an audit record.

The one thing we will not pretend. Any system that stores information has somebody who can reach the database underneath it, or the software could never be repaired. That is true here and it is true everywhere, and a policy that claimed otherwise would be lying to you. So, plainly: our engineers at The KBI Group hold infrastructure level access to the database. They use it only to fix a fault or answer a security question, only when there is no other way, under a contract that forbids anything else, and every occasion is logged. They have no interest in your writing and no reason to open it. What we can promise absolutely is that Teri has no such access, and no route to it, which is the promise that actually matters when you sit down to write.

If anyone ever asks for this to be changed so that private entries can be read from Teri's side of the space, the answer is no, and the instruction to refuse is written into the build itself.

9. Who else is involved

We use a small number of carefully chosen suppliers. Each is a processor, which means they act only on our documented instructions and cannot use your information for their own ends. Each is bound by a written data processing agreement.

We do not use Google Analytics, Meta pixels, advertising networks, session recording tools, chat widgets or third party font services on any part of this site.

Others we may have to tell. We may disclose information where the law requires it, for example to a court, the police, a local authority or a regulator, or where section 12 applies. We would tell you if we were allowed to.

If the business ever changes hands, your information could transfer to whoever takes it on. If that ever happens we will tell you before it does, and you will be able to close your room and take everything with you first.

10. Where your information goes, and how it is protected

Transfers outside the UK. Where a supplier processes information outside the UK, we rely on the UK International Data Transfer Addendum to the European Commission's standard contractual clauses, or on UK adequacy regulations where they apply. We keep copies of these arrangements and you can ask to see the relevant one.

Security measures.

• Encrypted in transit (TLS) and at rest
• Row level security on every table, so access rules are enforced by the database rather than by the interface
• Passwords of at least 12 characters, stored only as one way hashes
• Two factor authentication is compulsory on Teri's account, and on any account with administrative access
• Sessions expire after 14 days of not being used
• Resources are held in a private store and served only through links that expire
• An audit trail of every administrative action that touches your record
• Access limited to the smallest possible number of people, which today means Teri and, for maintenance, The KBI Group

Breaches. If something goes wrong and there is a risk to your rights and freedoms, we will report it to the ICO within 72 hours of becoming aware, and we will tell you directly, plainly, and without waiting to be asked, if the risk to you is high.

11. Your rights

You have the following rights over your information. All of them are free to use, and using one will never affect how you are treated here.

How to use them. Do it in the space where you can, or write to [privacy@thetrueself.app]. We will answer within one month. If a request is genuinely complicated we may take up to two further months, and we will tell you within the first month if that happens and why. We will not charge you, and we will not make you justify yourself.

We may need to check you are who you say you are before we act, which usually means replying from the email address on the account. If we have to ask you to confirm who you are, or to tell us more about what you are looking for, the clock pauses until you answer. We will search for what you have asked for in a way that is reasonable and proportionate, which is the standard the law sets.

Erasure, in practice.

• Closing your room deletes your entries, your Openings, Teri's replies and your profile. Properly deleted, not hidden.
• Deletion from the live system happens straight away. Copies held in routine backups cycle out within [30] days, and are never restored except to recover from a failure.
• What survives, and why: the safeguarding record if one exists (see section 12), and the minimum financial record the law requires us to keep for six years, which is the fact of a payment and its amount, not anything you wrote.
• An Opening you have already shared cannot be unshared through the interface, because Teri may already have read it. But your right to erasure still stands, and if you ask us to delete an Opening we will delete it.

Withdrawing your consent. You can withdraw your consent to us holding what you have written at any time, by telling us or by closing your room. Because that consent is what permits us to hold special category data, withdrawing it means we can no longer keep your writing, so we will delete it on the terms below and your season will end. We will refund the unused part of any period you have paid for. We would rather you paused and kept your words waiting for you, but it is entirely your call and we will not argue with you about it.

Your right to complain to us. You have a legal right to complain to us about how we have handled your information, and we have a legal duty to make that easy. Write to [privacy@thetrueself.app] or use the complaints form at [thetrueself.app/complaint]. We will acknowledge within 30 days, look into it properly, and tell you what we have done about it.

Complaining to the regulator. If we cannot put it right, you can complain to the Information Commissioner's Office at ico.org.uk, on 0303 123 1113, or at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. You can go to them directly at any point. You do not need our permission and you do not have to come to us first.

12. Safeguarding, and the limits of confidentiality

We would rather be honest about this in advance than surprise you with it later.

Teri is a qualified family therapist and holds professional obligations that do not switch off because the writing happens on a screen. In a small number of situations she may have to act on something shared with her, including passing a concern to someone outside this space.

When that might happen. Where what you have shared gives serious concern that:

• a child is suffering, or is at risk of suffering, significant harm
• an adult at risk is being abused or neglected
• you or someone else is at immediate risk of death or serious injury
• there is a risk of serious harm to another person
• the law compels disclosure, for example a court order, or the duty that section 38B of the Terrorism Act 2000 places on everyone

How it would happen.

• She would use judgement, not a rule. Writing honestly about how hard things are, about anger, exhaustion, despair or thoughts you are frightened of, is not in itself a safeguarding concern. It is the reason this space exists.
• Wherever it is safe and possible, she would talk to you first, and tell you what she was going to do and why.
• She would share the minimum necessary, with the appropriate service, which might be a local authority safeguarding team, a GP, the emergency services or an appropriate professional body.
• Anything she does is recorded in the safeguarding log: the concern, the action taken, the date.
• A concern can only ever arise from something you chose to share. She cannot see your private entries, so she cannot act on them.

Safeguarding records are kept for [RETENTION PERIOD, TO BE SET AGAINST PROFESSIONAL BODY GUIDANCE] from the date recorded, and they are not deleted when you close your room. They are held separately from everything else, seen only by Teri, and never shared except as described above. We keep them because a safeguarding record that disappears is no use to the person it was meant to protect, and because we may have to account for what we did.

If you are in danger right now, this is not the right place to turn. Call 999. For urgent health advice call NHS 111. Samaritans are on 116 123, day or night. Shout is a text line, text 85258.

13. How long we keep things

If you pause your season, nothing is deleted. Your room and everything in it stays exactly as it is until you come back, or until you ask us to close it.

14. Cookies

The public pages set no cookies at all. Once you sign in, the space uses only what is needed to keep you signed in and to take payment safely. No analytics, no tracking pixels, no advertising, no third party fonts. The full detail is in the [Cookie Policy].

15. Changes to this notice

If we change this notice we will change the version number and the date at the top, and keep the previous versions available.

If a change materially affects what we do with what you have written, we will tell you by email before it takes effect, and where the law requires it we will ask for your consent again rather than assume it.

16. Getting in touch

Please write to [privacy@thetrueself.app], or to [ADDRESS]. A person will read it and a person will answer it.

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The True Self · Privacy Notice · Version 1.0 · [DATE] Related documents: [Terms of Use] · [Cookie Policy] · [Accessibility Statement]