About this policy
Inner Compass is a wellbeing companion that helps people notice their inner weather, keep gentle recovery plans, and — when they choose — share aggregated, anonymised patterns with the organisation that supports them (an employer, care provider, or health organisation).
This Privacy Policy explains what personal data we collect, why we collect it, how long we keep it, and the rights you have under the EU General Data Protection Regulation (GDPR / AVG). It applies to the Inner Compass web application at innercompass.tech and the Inner Compass mobile app.
1. Who is the data controller
The data controller for personal data processed through Inner Compass is Inner Compass B.V., [PENDING VERIFICATION: legal address], [PENDING VERIFICATION: KvK / trade-register number].
You can contact us about anything in this policy at support@innercompass.tech. For formal data-protection requests you can also write to privacy@innercompass.tech.
2. Personal data we collect
Account and identity
When you create an account we collect your email address, your chosen name, and — if you sign in with Google — the identifiers Google returns to us (your Google account email and profile name). We do not receive your Google password.
If your organisation invited you, we also record the invitation token so we can attach you to the correct workspace.
Wellbeing content you create
- Mood check-ins, energy levels, notes and reflections you write.
- Craving-session logs and night-reflection entries.
- Recovery-plan items you add, tick off or regenerate.
- Memories the Companion has stored on your behalf (you can view and delete them at any time in Settings → Memories).
- Messages you send to the AI Companion, together with the model's replies.
- Emergency-contact details you save so you can alert someone during a difficult moment.
Consent state
Inner Compass never shares individual wellbeing content with your organisation unless you explicitly consent. Your current consent choices (per-topic switches such as "share wellbeing trends", "share mood", "share sleep") are stored so we can honour them across the app.
Technical and log data
To keep the service secure and diagnose problems we log request metadata such as your IP address, timestamps, endpoint accessed, HTTP status and a short user-agent string. This data is separated from your wellbeing content.
3. Why we process this data (legal bases)
- Performance of contract (Art. 6(1)(b) GDPR): running your Inner Compass account, showing your data back to you, delivering the Companion.
- Legitimate interest (Art. 6(1)(f) GDPR): keeping the service secure, preventing abuse, aggregate product analytics that never identify an individual.
- Consent (Art. 6(1)(a) GDPR and Art. 9(2)(a) for health-related data): sharing wellbeing signals with your organisation, storing Companion memories, receiving optional notifications.
- Legal obligation (Art. 6(1)(c) GDPR): tax, accounting, responding to lawful requests from supervisory authorities.
4. Special-category data
The wellbeing content you create is treated as special-category data (health) under Art. 9 GDPR. We only process it with your explicit consent and only for the purpose of giving you a wellbeing companion. We never sell it, and we never use it to train third-party AI models.
5. Who can see your data
You
You always have access to your own account content. You can export or delete individual entries from inside the app.
Your organisation (employer, care provider, GGZ)
If your account is sponsored by an organisation, that organisation can see two things: (1) aggregate, anonymised wellbeing patterns across a group — never fewer than five people, so that no individual can be re-identified; (2) individual signals only for the specific topics you have explicitly toggled on in Settings → Consent. You can revoke consent at any time and the sharing stops immediately.
Your care provider (only if you invited them)
If you accepted an invitation from a GGZ/care provider, that clinician can see the trends and reports you have consented to. You can archive the relationship from your Settings and their access stops.
Emergency contact
If you press "Alert my contact now", we send an SMS to the phone number you saved. We only send this message when you press the button.
6. Subprocessors
We use a small number of trusted subprocessors to run the service. The current list is:
- Hosting & database: [PENDING VERIFICATION: hosting provider + region] — stores account and content data.
- AI Companion: [PENDING VERIFICATION: LLM provider(s) used in production] — receives your messages to generate replies. Data is not used to train third-party models.
- Email: [PENDING VERIFICATION: transactional email provider] — sends invitation and password-reset emails.
- SMS (emergency contact): Bird / MessageBird — sends the SMS alert you trigger.
- Authentication: Google Sign-In (Google Ireland Ltd.) — only if you choose to sign in with Google.
7. Where your data is stored
Personal data is stored inside the European Economic Area wherever technically possible. When a subprocessor operates outside the EEA (for example some AI providers), transfers are covered by the European Commission's Standard Contractual Clauses and additional safeguards. [PENDING VERIFICATION: full transfer mapping.]
8. How long we keep data
- Active account data: kept while your account is active.
- Companion memories: kept until you delete them from Settings → Memories.
- Logs: kept for a short operational period, then deleted or anonymised. [PENDING VERIFICATION: exact retention window.]
- Account deletion: when you delete your account we remove or irreversibly anonymise your personal data. Some records may be kept for a legal minimum period (for example invoicing) and are then deleted.
9. Your rights
Under the GDPR / AVG you have the right to access, correct, delete, restrict or object to the processing of your data, and to receive your data in a portable format. You can also withdraw any consent you gave without affecting past processing.
Most of these rights can be exercised directly inside the app (Settings). To exercise them by email, write to privacy@innercompass.tech. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
10. Deleting your account
You can request account deletion at any time — inside the app (Settings → Delete account) or from our public page at innercompass.tech/delete-account. We verify your identity before we delete anything so your account cannot be deleted by someone else.
11. Children
Inner Compass is not intended for children under 16. If you believe a child under 16 has created an account, please contact support@innercompass.tech and we will remove it.
12. Security
We keep your data on encrypted infrastructure, protect access with least-privilege authentication, and monitor for unusual activity. No system is perfectly secure, so we also let you delete your own content and account whenever you wish.
13. Changes to this policy
We may update this policy when the product changes. Material changes will be announced inside the app and, where required, by email. The date at the top of this page reflects the last update.
14. Contact
General questions: support@innercompass.tech. Privacy requests: privacy@innercompass.tech.