Privacy Policy

EarlyMind App Ltd. ("EarlyMind", "we", "us" or "our"), having its registered office in the United Kingdom, is a data controller within the meaning of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018 ("DPA 2018") for the purpose of processing your personal data.

This Privacy Policy applies to the processing of personal data of website visitors, app users, and individuals who join our waitlist.

EarlyMind values the protection of your privacy and takes its responsibility to protect your personal data seriously. The purpose of this policy is to be transparent about how EarlyMind collects, uses and protects your personal data.

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1. What Is Personal Data?

Personal data is any information relating to an identified or identifiable natural person. This includes information that directly identifies you (such as your name or email address) as well as information that can be used in combination with other data to identify you.

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2. Who Is This Policy For?

This Privacy Policy applies to:

• Visitors to our website (earlymind.app or equivalent landing page)
• Users of the EarlyMind mobile application
• Individuals who submit their email address to join our waitlist

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3. What Personal Data Do We Collect and Why?

We only process your personal data for specified, explicit and legitimate purposes.

3.1 Website Visitors — Waitlist Sign-Up

Our landing page includes a form that allows you to register your email address to join the EarlyMind waitlist. We collect this data to notify you when the app becomes available and, if relevant, to send you updates about EarlyMind.

• Legal basis: Your consent (Article 6(1)(a) UK GDPR), given when you submit the waitlist form.
• Data collected: Your email address.

You may withdraw your consent and unsubscribe from waitlist communications at any time by clicking 'unsubscribe' in any email we send you, or by emailing us at privacy@earlymind.app.

3.2 Website Visitors — Questions and Enquiries

If you contact us via our website or by email with questions, comments or complaints, we process the data you provide in order to respond to you.

• Legal basis: Our legitimate interest in efficiently handling enquiries (Article 6(1)(f) UK GDPR).
• Data collected: Your name, email address, and any other information you voluntarily share with us.

3.3 Website Visitors — Analytics and Cookies

Our website uses cookies for functional and analytical purposes to understand how visitors use the site and to improve it. Please refer to our Cookie Policy for more information.

• Legal basis: Your consent (Article 6(1)(a) UK GDPR) via the cookie banner, or our legitimate interest in maintaining a functioning website for strictly necessary cookies (Article 6(1)(f) UK GDPR).
• Data collected: IP address, browser type, device type, pages visited, and general location data.

3.4 App Users — Account Creation

To use the EarlyMind app, you must download it and create an account. We process the data you provide during registration to set up and manage your account and to deliver the services described in our Terms of Use.

• Legal basis: Performance of a contract (Article 6(1)(b) UK GDPR).
• Data collected: Your email address, name, and password.

3.5 App Users — Child Profile and Behaviour Tracking

EarlyMind App allows you to create a profile for your child and to record notes and observations about your child's behaviour and development in accordance with the Montessori system. You are in full control of the data you enter. You decide what information to include, and all notes remain private to your account.

Some of the information you may choose to enter — such as notes relating to behavioural patterns, or other developmental considerations — may constitute special category data under UK GDPR. We treat all such data with the highest level of care.

• Legal basis: Your explicit consent (Article 9(2)(a) UK GDPR) for any special category data, and performance of a contract (Article 6(1)(b) UK GDPR) for general account and tracking data.
• Data collected: Child's name, age or date of birth, behavioural notes, developmental observations, and any other information you voluntarily enter.

3.6 App Users — Health Document Storage

EarlyMind App provides a secure document storage feature where you may upload health-related documents (such as assessments or reports) for safe keeping in one place. We store these documents securely on your behalf. We do not read, scan, analyse, or use the contents of uploaded documents for any purpose other than storing and displaying them back to you.

• Legal basis: Your explicit consent (Article 9(2)(a) UK GDPR) and performance of a contract (Article 6(1)(b) UK GDPR).
• Data collected: The documents you upload and associated metadata (e.g. file name, upload date).

3.7 App Users — Child Photos

You may optionally upload photos to your child's profile. This is entirely voluntary and is used only to personalise your experience within the app.

• Legal basis: Your consent (Article 6(1)(a) UK GDPR).
• Data collected: Any photos you choose to upload.

3.8 App Users — AI-Assisted Features

EarlyMind App offers AI-assisted guidance related to developmental considerations such as ADHD and dyslexia. This feature provides general informational support only and does not constitute medical, psychological, or educational advice. You should always consult a qualified professional for any clinical concerns.

To provide AI-generated recommendations, the app processes the notes and information you have entered in your account. Before your data is used to generate recommendations, it is pseudonymised — meaning that directly identifying information (such as your name or email address) is removed or replaced with a non-identifying reference, so that the data sent to the AI cannot be directly linked back to you without additional information held separately by EarlyMind. This pseudonymised data is processed within our secure infrastructure. We do not share identifiable data with third-party AI providers.

• Legal basis: Your explicit consent (Article 9(2)(a) UK GDPR) and performance of a contract (Article 6(1)(b) UK GDPR).

3.9 App Users — Customer Support and Communications

When you contact our support team, we process the information you provide to respond to your query. We may also contact you about your subscription, app updates, or changes to our terms.

• Legal basis: Performance of a contract (Article 6(1)(b) UK GDPR) and our legitimate interest in providing effective customer support (Article 6(1)(f) UK GDPR).
• Data collected: Name, email address, app version, device type, and any information you share in your message.

3.10 App Users — Marketing Communications

If you have consented to receive marketing emails, or are an existing customer who has not opted out, we may send you information about EarlyMind features, updates, or relevant third-party offers. You can unsubscribe at any time by clicking 'unsubscribe' in any email or by contacting us at privacy@earlymind.app.

• Legal basis: Your consent (Article 6(1)(a) UK GDPR) or our legitimate interest as an existing customer relationship (Article 6(1)(f) UK GDPR).

3.11 App Users — App Analytics and Product Improvement

We collect aggregated, anonymised data about how users interact with the app (such as which features are used most frequently) to improve EarlyMind's functionality and content. This data is not linked to individual users.

• Legal basis: Our legitimate interest in improving our product (Article 6(1)(f) UK GDPR).

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4. Subscriptions

EarlyMind offers both a free version and paid subscription plans. Subscription payments are handled through your app store provider (Apple App Store or Google Play Store) under their respective terms. We do not receive or store your payment card details. We receive only a unique identifier and subscription status from the app store for account management purposes.

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5. Special Category Data

Some data you may enter into EarlyMind — particularly notes relating to a child's health, behaviour, learning difficulties or developmental conditions — constitutes 'special category data' under UK GDPR (Article 9). We treat this data with additional care:

• We process it only on the basis of your explicit consent.
• It is encrypted in transit and at rest.
• Access is strictly limited to authorised personnel who require it for technical support or security purposes, and all such staff are bound by confidentiality obligations.
• When used to generate AI recommendations, it is pseudonymised first — directly identifying information is removed or replaced before processing, so the data cannot be directly linked back to you.
• We do not use this data for advertising, profiling, or sale to third parties.
• Data you enter relating to a child is entered by you as the parent or legal guardian. By entering such data, you confirm you are authorised to do so.

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6. Who Do We Share Your Data With?

We do not sell your personal data to third parties. We may share data with trusted third parties only where necessary to operate the service:

• Cloud infrastructure and hosting providers (for secure storage of your data), based within the UK or EEA.
• Customer support tooling providers.
• Analytics providers (receiving only aggregated or anonymised data).
• App store providers (Apple / Google) for subscription management — limited to identifiers only.

All processors are bound by data processing agreements and may only process your data on our instructions.

We may also disclose data if required to do so by law, by a court order, or by a regulatory authority.

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7. International Data Transfers

We aim to store and process all personal data within the UK or the European Economic Area (EEA). Where data is transferred outside these regions (for example, via a third-party service provider), we ensure that adequate safeguards are in place, such as UK-approved Standard Contractual Clauses or an adequacy decision by the UK Government.

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8. How Long Do We Keep Your Data?

We retain your personal data only for as long as necessary:

• Account data is retained for as long as your account is active.
• Child profile data, notes, and uploaded documents are retained for the duration of your account, plus a short period thereafter to allow data export. You may delete this data at any time.
• Waitlist email addresses are retained until the waitlist closes or you unsubscribe.
• Customer support correspondence is retained for up to 2 years.
• Financial records may be retained for up to 7 years to comply with legal obligations.

You can request deletion of your data at any time by contacting privacy@earlymind.app.

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9. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

• Right of access — to request a copy of the data we hold about you.
• Right to rectification — to ask us to correct inaccurate or incomplete data.
• Right to erasure — to request deletion of your data in certain circumstances.
• Right to restrict processing — to ask us to limit how we use your data.
• Right to data portability — to receive your data in a structured, machine-readable format.
• Right to object — to object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please email privacy@earlymind.app. We will respond within one calendar month. If you are dissatisfied with our response, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

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10. How Do We Protect Your Data?

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, or misuse. These measures include:

• Encryption of data in transit (TLS) and at rest.
• Access controls limiting data access to authorised personnel only.
• Confidentiality obligations for all staff and contractors.
• Regular review and update of security practices.

In the event of a data breach that poses a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, notify you directly.

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11. Children's Privacy

EarlyMind is designed for use by parents and legal guardians, not by children directly. The app processes data about children as entered by their parent or guardian. We do not knowingly collect data directly from children. If you are under 18, please do not use this app without the consent of a parent or legal guardian.

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12. Consent

Where we process your data on the basis of consent, you have the right to withdraw that consent at any time by emailing privacy@earlymind.app. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

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13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you via the app or by email at least 30 days before they take effect. The current version will always be available in the app and on our website.

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14. Contact Us

If you have any questions about this Privacy Policy or your personal data, please contact us:

Email: privacy@earlymind.app

Company: EarlyMind Ltd., United Kingdom

If you wish to make a complaint to the supervisory authority, you may contact the Information Commissioner's Office (ICO) at ico.org.uk.

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