Privacy Policy

Last Updated: November 12, 2025 (version 1.8.3+)

What changed:

To further protect your privacy, we are removing all personal data from our servers. Only technical identifiers, such as your User ID and subscription status, are now stored in Google Cloud, while all other data remains securely on your device and cannot be accessed by us or anyone else.

To keep improving your app experience whilst protecting your privacy, we integrated two mobile analytics platforms — Appsflyer and Amplitude. They collect anonymized or aggregated usage events that help us understand how the app performs and how to improve it, without relying on any personal information about you. You can opt out anytime in Profile > Manage your data.

INTRODUCTION

Welcome to the Anticipate app and website (“Anticipate”), provided by EMOTION SENSE LTD (“we”, “us”, or “our”). Your privacy matters to us, and
we’re committed to protecting your personal data. This Privacy Policy explains what information we collect, how we use it, and your rights regarding
that information. It’s written to be clear and user-friendly, and aligns with UK data protection laws and guidance from the Information Commissioner’s Office (ICO).

We will never sell or rent your personal data. We only share it with third parties when it’s necessary to deliver our services or when required by law (and where possible, we’ll let you know).

Please read this policy carefully to understand how your data is handled. If you have any questions, contact us using the details in the Contact Us section below.

Key Points (Summary):

• Anticipate processes data such as your sleep, activity, mood, and journal entries to provide the service. All such personal data is stored locally on your phone.
• Only technical details (such as your User ID and subscription status) are securely stored on Google Cloud servers in Belgium (within the EU). We take strong measures to protect this data and ensure all transfers comply with UK law.
• We use two AI services: OpenAI’s GPT for mood analysis and Google’s Gemini for chat. These services act as data processors and only use your data as instructed by us.
• You have rights over your data — including accessing, correcting, deleting it, and withdrawing consent.
• We do not sell your data or share it for third-party marketing. Data is only shared with service providers under strict agreements or when legally required.

WHO WE ARE

EMOTION SENSE LTD (“EMOTION SENSE”) is the company behind Anticipate. We are the data controller for the personal information collected
through the Anticipate app and website. This means we determine how and why your personal data is processed in connection with our services.

• Company Name: EMOTION SENSE LTD
• Registered Address: 71-75 Shelton Street, London, England, WC2H 9JQ
• Company Registration: 15603244
• Contact Email: team@helloanticipate.com

When this policy refers to “we” or “us,” it means EMOTION SENSE LTD as the entity responsible for your data.

WHAT DATA WE COLLECT

We collect and process different types of personal data when you use the Anticipate app or website. This includes:

• Account Information: Anticipate accounts are anonymous, you don’t need an email address or any personally identifiable information to use the app. When you join Anticipate, we generate a random anonymous ID, stored securely in your phone’s Keychain and mirrored on Google Cloud.
  • We do not collect personal identifiers such as your legal name, email address, phone number, or government-issued IDs unless you explicitly provide them in a support request or feedback form. You can use Anticipate without sharing identifying information, fully anonymously.
• Payment Information: When you make a purchase, we record details confirming the existence of a relationship between you and us and confirmation that relationship ended, if applicable (e.g., subscription order, payment confirmation, subscription cancellation, subscription price & duration, if you used the App). All payments are processed through the App Store. We do not collect or store your full payment card details. We only receive confirmation of your subscription status from Apple.
• Health and Environment Data: Anticipate helps you understand your moods by analysing your sleep, activity, and environment (such as sunlight exposure and travel). This data is automatically collected when you grant access to Apple Health, motion sensors, and location. To protect your privacy, all Apple Health, device motion, and location data is stored on your device only. It is never transferred to our servers for storage and remains accessible only to you.
• Mood and Journal Data: When you log moods, feelings, or journal entries — including those shared in the chat — we collect this data. This may include sensitive information about your mental health or life events. To protect your privacy, all self-reported data is stored on your device only. It is never transferred to our servers and remains accessible only to you.
• Usage Information: We collect data on how you use the app and website, such as which features you use, which errors you encounter, how long you spend in the app, and how often you make entries. This helps us improve the service and troubleshoot issues.
• Device and Technical Data: We may collect information about the device and browser you use, such as device type (e.g. phone model), operating system, and app version. This allows us to ensure compatibility, security, and performance.

We only collect the data necessary to provide and improve the Anticipate service. You always have control over what information you share.

However, some features (like mood prediction) may not function properly if you choose not to share certain data.

HOW WE USE YOUR DATA

We use your personal data to provide, maintain, and improve the Anticipate app and website. Our aim is to use your information fairly and transparently. Below are the key ways we process your data:

• To Provide the Service: We use your data to deliver core app features — for example, showing your mood entries in a calendar or journal format, or generating daily mood predictions based on your health, environment, and self-reported data. This also powers features like the Anticipate chat, helping it respond meaningfully. We may also personalize your experience by suggesting tips when you’re feeling low or adjusting the app’s interface based on your usage.
• Daily Mood Predictions (OpenAI GPT): One of Anticipate’s core features is daily mood predictions and insights, powered by OpenAI’s GPT. We securely send a limited set of relevant data (such as recent activity) to OpenAI’s system, which returns a prediction or insight. OpenAI processes this data solely to deliver the requested result and does not use it for any other purpose (like training their models).
• Chat Conversations (Google Gemini AI): The Anticipate chat is powered by Google’s Gemini AI, enabling natural and supportive conversations. When you send a message, the content (and relevant context like recent activity) is securely sent to Gemini AI, which processes it and sends back a response. Google processes this data only to generate the reply and strictly under our instructions.
• Improving the App: We analyze overall app usage to enhance performance and design — for example, by fixing bugs or developing new features. We use analytics tools such as Sentry to track bugs and Amplitude to understand product interactions. We use aggregated or anonymized data that does not identify you.
• Measuring Performance: To promote and measure the performance of our services. We use certain analytics and attribution tools, such as AppsFlyer, to help us understand how our marketing campaigns perform and to promote our services to potential users.
• Communications: Anticipate may send push notifications to remind you to log your mood, track your sleep, or notify you about upcoming
  subscription renewals or trial endings. These are service messages. If we ever send promotional messages via push, we will ask for your
  separate opt-in and give you the option to opt out at any time through the app settings.
• Customer Support: If you contact us for help, we’ll use your contact details and any relevant data (with your permission) to assist. This may include reviewing usage logs to diagnose a problem.
• Legal and Safety Reasons: In rare cases, we may need to use or share your data to meet legal obligations, enforce our Terms, or protect the rights, safety, or property of our users or company. For example, we might respond to a lawful request from authorities or investigate potential fraud.

We will only use your data for the purposes described above. If we need to use it for a new purpose, we’ll update this policy and, if needed, ask for your consent.

Use of Third-Party Service Providers:

In addition to OpenAI and Google, we may also work with other carefully selected third-party providers to support essential services such as infrastructure hosting, analytics, customer support, and error tracking. These providers act as data processors and only handle your data under our instructions and data processing agreements. A list of current third-party processors is available upon request by contacting us at team@helloanticipate.com.

AppsFlyer

We use AppsFlyer, a mobile analytics and attribution platform, to measure and optimize our marketing campaigns. AppsFlyer helps us understand which ads lead to app installs, trial starts, or purchases.

When you install and use the App, AppsFlyer creates a unique identifier (AppsFlyer ID) that lets us analyze aggregated app events (such as launches, and conversions) without directly identifying you. We do not request App Tracking Transparency (ATT) permission or share personal data that directly identifies you.

Processed data may include device and app information, technical identifiers, and non-identifiable app events. Processing is based on our legitimate interest in promoting and improving our Services while safeguarding user privacy. You can opt out of this processing anytime in Profile > Manage your data.

Amplitude

We use Amplitude, a product analytics platform, to measure app usage and performance. Amplitude helps us understand which features are used and how often, allowing us to improve the App based on this information.

When you install and use the App, Amplitude creates a unique identifier (Amplitude ID) that lets us analyze aggregated app events (such as app launches and feature taps) without directly identifying you. We do not request App Tracking Transparency (ATT) permission or share any personal data that directly identifies you.

Processed data may include device and app information, technical identifiers, and non-identifiable app events. Processing is based on our legitimate interest in improving our Services while safeguarding user privacy. You can opt out of this processing anytime in Profile > Manage your data.

LEGAL BASES FOR PROCESSING

Under UK data protection law, we must have a valid legal basis to process your personal data. Depending on the specific context, we rely on one or
more of the following:

• Performance of a Contract: Some of the data we collect is necessary to provide the core Anticipate services you’ve requested, as outlined in our Terms and Conditions (the agreement between you and us). For example, we may process account information, basic usage data, and system-generated identifiers to operate the app and maintain your session. However, many features (like mood insights, journaling, and chat support) rely on additional data that you choose to provide — and where this involves health or sensitive information, we rely on your explicit consent instead.
• Consent: For all optional or sensitive data — especially data related to your health or emotional wellbeing (known as special category data under UK GDPR) — we rely on your explicit consent. You provide this consent in two ways: by granting access through Apple’s native prompts (e.g. when you allow access to: Apple Health (sleep, activity), Device motion, Location data, Push notifications), or by actively entering personal data into the app (e.g. mood entries, triggers or positive events, journal reflections). You can withdraw this consent at any time — for example, by adjusting your device permissions, deleting specific entries, or disabling certain features in the app settings. (Withdrawing consent won’t affect any processing that happened while your consent was active.)
• Legitimate Interests: In some cases, we process your data to support our legitimate business interests, as long as this doesn’t override your rights and freedoms. This includes activities like improving the app, fixing bugs, or preventing fraud. We always assess the balance between our interests and your privacy, and we do not rely on this basis for sensitive data without your explicit consent.
• Legal Obligation: In certain situations, we may need to retain or share data to comply with legal requirements — for instance, keeping
  transaction records for tax purposes, or responding to lawful requests from authorities.
• Vital Interests: In very rare cases, we may process data to protect someone’s life or prevent serious harm. However, Anticipate does not monitor for emergencies, assess immediate risk, or provide crisis intervention. While we care deeply about your wellbeing, the app is not designed or equipped to detect or respond to urgent situations (such as suicidal thoughts or medical emergencies). If you are in crisis or need immediate help, please contact emergency services or a mental health professional.

International Compliance (U.S. and Canada):

In addition to UK and EU requirements, we comply with applicable laws in the other markets we serve. This includes the California Consumer Privacy Act (CCPA) and similar state laws in the U.S., as well as the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada. If you are located in the U.S. or Canada, you have similar rights to access, correct, or delete your data, and can exercise those rights by contacting us directly.

We will always ensure we have a valid legal reason for processing your data and will document that basis. If you have questions about the legal basis for any specific type of processing, feel free to contact us.

USE OF AI SERVICES (OpenAI GPT and Google Gemini)

One of the unique features of Anticipate is our integration with powerful AI services to enhance your experience. Here’s how we use these services, what data they process, and the roles of each party involved:

OpenAI’s GPT (for Mood Predictions)

We use OpenAI’s GPT to help generate your daily mood predictions and insights. OpenAI acts as our data processor, which means:

• We securely send a limited set of relevant data (such as summaries of recent mood, sleep, and activity) to OpenAI’s system when a prediction is needed.
• OpenAI’s GPT processes the data and returns a mood insight or prediction.
• OpenAI does not keep your data or use it for any other purpose beyond generating that specific response. According to their API policies, OpenAI does not use API data to train their models.
• We have a data processing agreement in place with OpenAI to ensure your information is handled securely and confidentially.
• The resulting prediction is displayed to you in the app.

Responsibility:

EMOTION SENSE LTD remains the data controller, while OpenAI acts only as a data processor. That means OpenAI follows our instructions and does not decide how your data is used. If you have questions or concerns about how your data is used in this context, please contact us — we are responsible for your data.

Automated Processing and Profiling:

The mood predictions provided by Anticipate involve automated analysis of your recent health, activity, and journal data to generate personalized insights. This qualifies as profiling under UK and EU data protection laws. However, these insights are informational only — they do not result in decisions that produce legal or similarly significant effects. You always have the right to request a human review or share your feedback if you feel impacted by an AI-generated result.

Google’s Gemini AI (for Chat Feature)

Our chat feature is powered by Google’s Gemini AI, which provides intelligent, conversational responses. Google (via its Google Cloud services) also acts as a data processor on our behalf for this function:

• When you send a message in the chat, the content — along with relevant context like recent mood or environment data — is securely sent to Gemini AI.
• Gemini processes this data to generate a response and sends it back to the app.
• Google only uses this data to deliver the chat response. They do not use it to train their models or for any other purpose.
• We have a strict data processing agreement with Google that includes strong privacy and security obligations.

Responsibility:

As with OpenAI, EMOTION SENSE LTD is the data controller, and Google is the data processor. Google handles your data strictly under our instructions and in line with UK data protection laws.

By working with OpenAI and Google as processors, we ensure that no AI service makes independent decisions about your data. They act solely as tools under our control. We’ve chosen these providers because of their strong reputations and high standards for privacy and security. In the unlikely event of a security issue or misuse of data, we will take appropriate action and notify you as required by law.

DATA STORAGE AND INTERNATIONAL TRANSFERS

All Apple Health, journal, location, and motion data is securely stored on your device only. It is never transferred to our servers for storage and cannot be accessed by anyone but you.

On our servers, we store only limited technical information — such as subscription details — for monitoring purposes. We understand that, however small the data, where it’s stored and how it’s protected matters. Here’s how we handle it:

• Primary Storage in Belgium (EU): Your data is securely stored on Google Cloud Platform (GCP) servers located in Belgium, within the European Union. This means your information is protected under strong EU data protection laws. The UK government recognizes the EU’s data framework as adequate, so transferring and storing your data in the EU is fully compliant with UK law.
• Security Measures: All data stored on our Google Cloud servers is protected with robust security measures. This includes encryption at rest (so your data is encrypted when saved in our database) and encryption in transit (so your data is encrypted when it’s sent between your device and our servers). We also restrict access to these servers — only authorized personnel who need to maintain the service have access, and even then it’s controlled and logged.
• International Data Transfers: Some features — like mood predictions (OpenAI) or chat (Google Gemini) — may require certain data to be processed outside the UK or EU. For example, OpenAI is based in the U.S., and while Google has global infrastructure, some Gemini processing might also occur outside the EU/UK. When this happens, we ensure your data remains protected by:
  • Using Standard Contractual Clauses (SCCs) or equivalent legal safeguards in our contracts with OpenAI and Google, ensuring your data is handled according to UK/EU standards.
  • Sending only the minimum data necessary (e.g. your message text, not full account details).
  • Working with providers who maintain strong privacy programs and security certifications — like ISO 27001 in Google’s case.
• Disaster Recovery Replication: To ensure service availability in case of disaster recovery, Google Cloud may replicate limited operational data and metadata to other data centers around the world. However, full copies of your data remain within the chosen location (Belgium, eur3 region). The replicated data is minimal, restricted to operational purposes only, and does not include full account data. Google maintains strict access controls and encryption at all times, and replication is solely intended to maintain service reliability — not for processing or business operations.
• No Unnecessary Global Access: We do not routinely send your data to countries outside the UK, EU or U.S. The only locations where your data may be processed are UK (as the country where our company operates), EU (Belgium, where our servers are hosted), and U.S. (for OpenAI and potentially Google processing).
• Future Options: If we introduce new services that affect where your data is stored or processed — or give you the ability to choose your preferred data region — we will clearly inform you and update this policy.

Our goal is to ensure your data is always handled safely, no matter where it is processed. If you have questions about international data transfers or want more details about our safeguards, feel free to contact us.

DATA RETENTION

We do not keep your personal data longer than necessary. How long we retain data depends on the type of data and how it is used:

• Account Information: We retain your account details (such as your user ID and public Face ID or Touch ID key) for as long as your account is active. You can permanently delete your account and all associated data at any time by going to Profile → Manage your data, scrolling down, and pressing Delete my account and all data. Please note that this action is permanent and cannot be undone.
• Health Data: Your app keeps your health data, like sleep and steps, so you can view your history and support app features like mood insights and chat. Health data is stored on your device until you delete it or delete your account. You can delete this data within the app at any time. If you uninstall the app, health data is deleted as part of that process.
• Environment Data: We keep your environment data, like trips and weather, so you can view your history and support app features like mood insights and chat. Environment data is stored on your device until you delete it or delete your account. You can delete this data within the app at any time. If you uninstall the app, environment data is deleted as part of that process.
• Mood and Journal Entries: We keep your mood logs and journal entries so you can view your history and support app features like mood insights and chat. Mood and journal data is stored on your device until you delete it or delete your account. You can delete this data within the app at any time. If you uninstall the app, mood and journal data is deleted as part of that process.
• Usage Data: General usage data (e.g. how often you use a feature or when you last logged in) is retained as long as needed for internal analysis. Raw logs may be kept for a short period (e.g. a few months) for troubleshooting. Aggregated or anonymized statistics (which no longer identify you) may be retained longer to help us understand usage trends.
• Communications: If you contact our support team or we contact you via email, we may keep those communications for a reasonable period — typically 1–2 years — to follow up on ongoing issues. You may request the deletion of these records at any time.
• Legal Requirements: In some cases, we may need to retain certain information for longer periods to comply with legal obligations or resolve disputes. For example, we may need to retain data for audits, investigations, or legal claims. In such cases, data will only be used for those purposes and nothing else.
• Backups: Our system may create backup copies of data for reliability and disaster recovery. This means that even after deletion, some data may remain in secure backups for a short period until those backups are overwritten. We follow policies to ensure that backup data is deleted or replaced on a regular schedule and is not kept indefinitely.

Once the applicable retention period ends — or if you request deletion — we will either securely delete your personal data or anonymize it so it can no longer be linked to you. If immediate deletion isn’t possible (for example, if your data exists in an archived backup), we will isolate and protect it until it can be deleted.

YOUR RIGHTS

Under data protection laws, you have several important rights regarding your personal data. We want you to be fully informed and able to exercise
your rights easily:

• Right to Access: You can request a copy of the personal data we hold about you (commonly called a “Subject Access Request”). We’ll respond within one month, as required by law.
• Right to Rectification: If any of your information is inaccurate or incomplete, you have the right to ask us to correct it. You can also update certain details directly in the app.
• Right to Erasure (“Right to be Forgotten”): If you no longer wish to use Anticipate, you can delete all of your data and your account at any time from the app settings (Profile → Manage your data). Note: Simply deleting the app does not delete your anonymous account or any technical data (like subscription status) stored on our servers. Please delete your data and/or account from within the app settings before uninstalling, or email us at team@helloanticipate.com for help with deletion.
• Right to Restrict Processing: You can ask us to limit how we use your data in certain situations — for example, if you believe some data is inaccurate or you’ve objected to its use and we’re reviewing your request.
• Right to Data Portability: You have the right to receive your data in a common, machine-readable format (like CSV or JSON), and to request we transfer it to another provider, where technically feasible. This applies to data you’ve provided and that we process based on your consent or our contract.
• Right to Object: You can object to processing based on our legitimate interests. If you do, we’ll stop unless we have compelling legal grounds to continue. You also have an absolute right to object to marketing — if you opt out, we’ll stop sending you marketing messages.
• Rights Related to Automated Decision-Making and Profiling: You have the right not to be subject to decisions made solely by automated means if they have a legal or similarly significant effect on you. Anticipate’s mood predictions and chat replies are generated through automated processing (AI), but they are for informational and supportive purposes only. They do not affect your legal rights or access to services. If you feel impacted by an AI feature, you can request a human review or share your point of view — and we’ll do our best to help.
• Right to Withdraw Consent: If we process your data based on consent (e.g. sleep analysis, chat, or notifications), you can withdraw that consent at any time. For example, you can: stop using the chat feature, delete your mood entries, or turn off push notifications in the app settings. Withdrawing consent does not affect the legality of prior processing, but we’ll stop processing that data going forward.
• Right to Complain: If you are unhappy with how we are handling your data or your rights, please let us know first — we take your concerns seriously and will try to resolve them. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO), the supervisory authority for data protection in the UK. You can contact the ICO at https://ico.org.uk/concerns or by calling 0303 123 1113.

To exercise any of these rights, contact us using the details in the Contact Us section. We may need to verify your identity before fulfilling certain
requests, to protect your privacy. We’ll respond as soon as possible — and always within the timeframes required by law (usually within one month).
We do not usually charge a fee, unless your request is clearly unfounded, repetitive, or excessive — in which case we’ll explain why and let you know
in advance.

SECURITY MEASURES

We take the security of your personal data very seriously. We’ve implemented a range of measures to help protect your information from loss, misuse, or unauthorized access:

• Encryption: Your data is encrypted both in transit (when it’s being sent between your device and our servers or AI providers) and at rest (when it’s stored in our database or backups). This ensures it can’t be read or intercepted by others.
• Access Controls: Only a limited number of authorized EMOTION SENSE LTD team members or trusted contractors have access to personal data — and only when it’s necessary (e.g. for troubleshooting). All access is controlled, authenticated, and regularly reviewed.
• Third-Party Security: We work with reputable service providers, including Google Cloud and OpenAI, all of which have strong security practices. We have data processing agreements in place to ensure your data is handled responsibly and used only for the services we’ve agreed. We also rely on industry-recognized certifications (e.g. Google Cloud’s ISO 27001) as part of our due diligence.
• App and Website Security: We keep our software and systems up to date and apply security patches promptly. We use firewalls and monitoring tools to protect our infrastructure, and our developers follow secure coding practices to minimize risks.
• Testing and Training: We conduct regular security assessments, including penetration tests and vulnerability scans. Our team also receives ongoing training in privacy and security best practices to stay alert to potential threats.
• Incident Response: In the unlikely event of a data breach or security incident, we have a response plan in place. We’ll act quickly to contain and resolve the issue, and we’ll notify affected users and relevant authorities (such as the ICO) where required by law. We’ll also take steps to prevent similar incidents in the future.

While we work hard to safeguard your data, no system is 100% secure. You can help by keeping your device secure and letting us know immediately if you believe your account or data may have been compromised.

CHILDREN’S PRIVACY

Anticipate is not intended for children under the age of 18. We do not knowingly collect personal data from anyone under 18. If you are under 18, please do not use the app or submit any information to us. We do not use age verification mechanisms at signup, but rely on users to confirm their eligibility. We may consider implementing additional measures to prevent underage access in future versions of the app.

If we become aware that we’ve accidentally collected personal data from a child under 18, we will delete that information as quickly as possible. If you believe we might have collected such data, please contact us so we can investigate and take appropriate action.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make updates, we’ll revise the “Last Updated” date at the top of this policy.

For significant changes, we may also provide a more prominent notice — for example, by sending you an email or showing a notification in the app. If a change significantly affects how your personal data is used, we will notify you in advance and, where required, seek your consent.

We encourage you to review this Privacy Policy regularly so you stay informed about how we protect your data. By continuing to use the Anticipate app or website after changes are made, you agree to the updated terms.

CONTACT US

If you have any questions, concerns, or requests related to this Privacy Policy or how we handle your personal data, please get in touch. We’re here to help and will respond as promptly as we can.

• Email: team@helloanticipate.com (Please include “PRIVACY” in the subject line for privacy-related inquiries or to exercise your rights.)
• Postal Address: EMOTION SENSE LTD, 71-75 Shelton Street, London, England, WC2H 9JQ

EMOTION SENSE LTD is not currently required to appoint a formal Data Protection Officer under UK GDPR. However, our core team handles all data protection matters and can be contacted at team@helloanticipate.com.

We hope this Privacy Policy helps you understand how your data is used in Anticipate. Your privacy is important to us, and we’re committed to protecting it at every step.

Thank you for trusting EMOTION SENSE LTD with your personal data.