Privacy Notice

Last updated: 2 September 2026

Plain-English summary: we collect only what we need to run the app, we never sell your data, your private content stays yours, and you can delete your account at any time by emailing us.

What Stillwater can see, in plain English

• Your email and account ID, so we can sign you in and contact you.
• Your billing data through Stripe — a customer ID, plan, and invoice history. We never see your card.
• Your journal entries, AI conversations, mood check-ins, reflections, and personal insights stay on your account. Stillwater staff cannot read them — the database itself refuses to return that content to operator tools.
• What you write is checked automatically for safety by an AI provider before or after it is saved (see section 3). That check happens in memory and the provider does not keep your text. If it detects a risk of serious harm, a short safety record is stored — a category, a risk score and a brief non-verbatim note, never your words (see section 3).
• We record how you use the app — which features you open and when, tied to your account ID — so we can keep it working and improve it.
• If you joined through work, your organisation sees only anonymous activity counts for groups of 5 or more. Never your name, never your content, never your individual activity.
• Encrypted backups exist for disaster recovery only. Access to them is restricted and they are only opened when needed for restoration or a legal obligation.

1. Who we are

This service (“stillwater”, “we”, “us”) is operated by MYSTILLWATER Ltd, a company incorporated in England and Wales. For the purposes of UK GDPR, MYSTILLWATER Ltd is the data controller of personal data collected through this service.

Contact us: curtis.maughan@mystillwater.life
Registered office: 40 Cades Grove, Stockton-On-Tees, TS17 5FN
ICO registration number: ZC247059

2. Personal data we collect

• Account data: email address, login credentials, display name.
• Content you create: mood entries, journal entries, breathing/session history, community posts and replies, stillwater guide chat messages (typed and spoken) and preferences.
• Support communications: messages you send us by email or in-app.
• Usage and device data: IP address, browser type, device identifiers, pages visited, feature interactions, session activity, error logs. Feature-usage events are stored against your account ID; they never contain what you wrote.
• Safety and moderation records: where a safety check flags a risk of serious harm, or where a community post is reported or actioned, we store a short record — the surface it came from, a category, a risk score, a brief non-verbatim note, and any warning, suspension or ban applied to your account. These records never contain your journal text, chat messages or voice transcripts.
• Newsletter data: if you subscribe to optional emails, your email address, confirmation status and unsubscribe status.
• Billing identifiers: a customer ID and subscription ID returned by our payments provider. We do not store full card numbers.

3. Special category (health) data and how we handle it

Mood check-ins, journal entries, reflections and Guide conversations may contain or reveal information about a person's physical or mental health and can therefore constitute special category data under Article 9 of UK GDPR.

Legal basis for ordinary processing. For our ordinary processing of this health-related information to provide stillwater's wellbeing features and safety systems, we rely on Article 9(2)(a) — explicit consent. When you create an account, you are asked to tick an explicit consent statement. You can withdraw that consent at any time, without deleting your account, under Settings → Your data & privacy → Withdraw consent. When you withdraw, we stop the optional processing that relies on that consent — personalised insights, mood forecasts and emotional pattern analysis — and delete the insights we had generated. Your own check-ins, journal entries and Guide history remain available to you to read or delete, and you can give consent again at any time. Withdrawing consent does not affect processing that was already lawful before you withdrew it, and does not affect safeguarding or legally required records, which are kept under their own legal basis and retention rules.

Vital interests. In exceptional life-or-death circumstances, for example where we believe someone is at immediate risk of serious harm and is physically or legally incapable of giving consent, we may rely on the vital interests condition under Article 9(2)(c). This is reserved for genuine emergencies and is not used for routine service operation.

4. How AI, voice and safety checks are handled

When you message the stillwater guide, your message and a short context of the recent conversation are sent to an AI model provider via the Lovable AI Gateway so a reply can be generated. We do not use your conversations to train third-party AI models, and we do not sell or share them for advertising.

Voice conversations. If you use voice mode, your speech and a short context of the recent conversation are processed by ElevenLabs, a conversational voice AI provider, so the guide can hear and speak. The resulting transcript is stored against your account in the same place as your typed conversation.

Safety checks. To keep people safe, text you write in the guide, your journal, unload and community is passed through an automated safety classifier at the same AI gateway. This happens in memory to produce a category and risk score; the text itself is not stored by the classifier or added to any moderation queue. Where a risk of serious harm is detected, we store only the short safety record described in section 2 and show you professional and emergency resources. These records are readable by the service operator for safeguarding purposes only — never by your employer or organisation admin, and never by community moderators.

Conversations are stored against your account so you can come back to them. You can delete individual chats from within the app, and you can request deletion of all conversation history by emailing us.

The stillwater guide uses safety filters that block harmful content and redirect to professional and emergency resources where appropriate. The stillwater guide is not a therapist, doctor, or crisis service.

5. Why we use your data and our legal basis

• To provide the service (account, journaling, stillwater guide, subscription access) — performance of a contract.
• To process payments and manage subscriptions — performance of a contract.
• To keep the service secure and prevent fraud or abuse — legitimate interests.
• To protect people from serious harm through automated safety checks and moderation — legitimate interests, and vital interests where there is a risk to life.
• To debug, improve and develop new features, including feature-usage analytics — legitimate interests.
• To respond to your support requests — legitimate interests.
• To meet legal, tax and accounting obligations — legal obligation.
• To send optional product updates and newsletters, where applicable — consent, which you can withdraw at any time.

6. We do not sell your personal data

We do not sell, rent or trade your personal data to advertisers, data brokers or anyone else. We only share data with the service providers listed below, and only as needed to run the app.

7. Who we share it with

• Stripe (Ireland / United States) — handles checkout, billing, tax and subscription management. Transfers outside the UK/EEA are safeguarded by the EU Standard Contractual Clauses and the UK International Data Transfer Agreement.
• Lovable (United States) — provides hosting, database, authentication, serverless functions and the AI Gateway through which AI model calls are routed. Transfers outside the UK/EEA are safeguarded by the EU Standard Contractual Clauses and the UK International Data Transfer Agreement.
• OpenAI (United States) and Google (United States) — AI model providers reached through the Lovable AI Gateway to generate stillwater guide replies and run safety checks. Content is sent only as needed and is not used to train their models. Transfers are safeguarded by the EU Standard Contractual Clauses and the UK International Data Transfer Agreement.
• ElevenLabs (United States) — processes your speech and the guide's replies when you use voice mode. Transfers are safeguarded by the EU Standard Contractual Clauses and the UK International Data Transfer Agreement.
• Email providers we use to send account, transactional and (if you opt in) newsletter emails, and to reply to you.
• Professional advisers (legal, accounting) where reasonably required.
• Authorities or third parties where we are required to do so by law, or to protect our rights, property or safety, or those of our users.

8. Automated moderation and your right to human review

stillwater uses automated systems to keep the community safe:

• Content hiding. Community posts or replies may be automatically hidden when they receive a number of reports or when a safety classifier detects a high risk score. Hidden content is not deleted and can be reviewed.
• Trust scores and account actions. Reported or removed content can automatically adjust a trust score. If that score reaches certain thresholds, the system may automatically issue a warning, temporarily suspend posting, or in serious cases suspend or ban the account.

These decisions are made automatically because of the volume of content and the need to act quickly to protect other users. Where a solely automated decision has a legal or similarly significant effect on you — for example, a suspension or ban that prevents you using a paid service — you have the right to:

• Obtain human review of the decision;
• Express your point of view;
• Contest the decision and have it reconsidered.

To request a review, email us at curtis.maughan@mystillwater.life.

9. Workplace accounts and independent controllers

If you access stillwater through your employer or another organisation, your organisation and MYSTILLWATER Ltd are independent controllers of different parts of your data:

• Your organisation controls the seat list (who is invited, their email and their organisational role).
• MYSTILLWATER Ltd controls everything you create or do in stillwater — your journal, mood entries, guide conversations, community posts and usage activity.
• Your organisation never receives your individual content, individual activity, or individual wellbeing data. It sees only anonymous aggregate counts for groups of 5 or more.

Questions about your organisation's own data practices should be directed to your organisation.

10. Deleting your account and data

You can permanently delete your stillwater account at any time by emailing curtis.maughan@mystillwater.life from the address registered to your account. We will:

• Cancel any active subscription so you are not billed again;
• Delete your account, mood entries, journal entries, community posts, AI conversation history (typed and voice), usage-analytics events and personalization settings within 30 days;
• Retain safety and moderation records only where we must, to protect other users or meet a safeguarding or legal obligation, and delete them otherwise;
• Retain a minimal record of the transaction (invoices, payment IDs) only where required to comply with tax, accounting and anti-fraud obligations.

11. International transfers

Some of our service providers are located outside the United Kingdom and the European Economic Area. Where personal data is transferred internationally, we rely on appropriate safeguards such as the UK International Data Transfer Agreement, the EU Standard Contractual Clauses, or an adequacy decision.

12. How long we keep it

We keep personal data for as long as your account is active and then for the periods below. When data is no longer needed, we delete or anonymise it.

13. Your rights

Under UK and EU data protection law you have the right to:

• Access the personal data we hold about you;
• Have inaccurate data corrected;
• Request erasure of your data;
• Restrict or object to how we use it;
• Receive a copy in a portable format;
• Withdraw any consent you have given;
• Complain to the UK Information Commissioner's Office ( ico.org.uk) or your local supervisory authority.

To exercise any of these rights, email curtis.maughan@mystillwater.life from the address registered to your account, or provide enough information for us to verify your identity. We will respond within one month, or within three months for complex requests, and we will tell you if we need more time.

You can object to processing based on legitimate interests at any time. Objecting may mean we cannot provide certain features.

14. Personal data breaches

We take appropriate technical and organisational measures to protect your personal data. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will report it to the ICO within 72 hours where required, and we will tell affected users without undue delay.

15. Security

We use appropriate technical and organisational measures to protect your personal data, including encryption in transit, access controls, and authentication. No system can be guaranteed perfectly secure, but we take security seriously and review our practices regularly.

16. Cookies and similar technologies

We use a small number of strictly necessary cookies and similar storage to keep you signed in, remember your preferences and keep the service secure. Our payments provider may set its own cookies during checkout. We do not use third-party advertising cookies.

Because these cookies are either strictly necessary or set by us for your preferences, we do not show a separate cookie consent banner. You can clear local storage and cookies through your browser settings at any time.

17. Children

The service is not intended for children under 16. If you believe a child has provided personal data, please contact us so we can delete it.

18. Changes

We may update this notice from time to time. The “last updated” date above shows when it was last revised. Material changes will be communicated in-app or by email.

See also our Terms & Conditions, Refund Policy and Subscription Information.