InsideOut App Privacy and Cookie Policy

 

Publication Date: 8th October 2025

At InsideOut, we take the privacy and safety of our users very seriously. We have written this Privacy Policy to tell you about your rights in relation to the data you give to InsideOut when you use our App.

Who Are We?

We are InsideOut25 Limited, a company registered in England.
Our address is: 164 Walkden Road, Worsley, Manchester, M28 7DP.
If you have any questions about your privacy, data or this policy, please contact us at: [email protected]

What Data Do We Collect?

When you register with InsideOut, you, or your employer (who offers InsideOut as an employee benefit to you), give us some personal details. This is so we can provide you with the services that you need or ask for.

We will inform you about our data collection by referring to this Privacy Policy and we will ask for your consent to share data where necessary. Please note that without your consent, we cannot provide all of our services, so if you do not want to consent (and that’s totally up to you), we are unable to offer you the full range of services.

In many cases, your mobile device will provide tools to allow you to control when your device collects or shares personal data or tracking information. For example, your mobile device may offer tools to allow you to manage cookie usage or location sharing. We encourage you to familiarise yourself with and use the tools available on your devices.

The personal details we collect include:

  • Account Data: Login and account information, including screen name, password and unique user ID; and your use of the service.

  • Contact Data: Contact details including your name, office details, role and work email, as well as the contact details of your emergency contact, should you provide them.

  • Health Data: Data about your health, in particular your mental health, including our counsellor’s observations, details from video sessions, details from messaging chats and safeguarding status.

  • Preferences Data: Personal preferences including your marketing and cookie preferences.

  • Technical Data: When interacting with our App, data is automatically collected and shared with the InsideOut25 technology platforms. More information about these practices is included below. This data includes: device IDs, call state, network access, storage information and battery information, cookies, IP addresses, referrer headers, data identifying your phone and version, and web beacons and tags.

Why Do We Collect Your Personal Details?

To Provide the App and Offer the App Services to You

We use your personal information to provide the service you want and expect from us. The legal grounds for this is the performance of the arrangement we have with you to provide the services you’ve asked for.

To Keep You (and Others) Safe

Whilst our service to you is confidential, there may be a time when our counsellors are so worried about you, they share your personal information with the emergency services without your consent. This is only if absolutely necessary such as where your counsellor believes your life is in danger. In this situation we will rely on the lawful basis of ‘vital interests’ to process this personal data.

If our counsellors think that you are at risk or danger, we will talk to you about the need for somebody outside the InsideOut team to know what has happened or what is happening to you.

We would only do this if:

  • Your life is at risk because of something you are doing; or

  • You are at risk from somebody else; or

  • You are a risk to somebody else.

In these cases, your counsellor will use your contact details so that they can refer you to the appropriate services or get the help you need. This will only ever happen with your consent. If you refuse consent then we will not transfer your data to anyone but we will also not be able to be responsible if anything were to happen that could have been prevented had we been able to contact the appropriate services on your behalf.

To Maintain and Improve Our Services and Run Our Business

We may use the data you provide to improve our service. For example, we evaluate Technical Data to make sure our service is working well or whether we need to make improvements to the video conferencing tech or the App design.

We may also use Technical Data to understand more about how you use the App and your preferences.

We may also need to share data with our professional advisors. For example, to get legal advice, enforce our App Terms or to obtain insurance for our business. We also need to comply with any legal proceedings and applicable law.

If you’ve expressly agreed, we’ll use your contact data to keep you updated about new events and services.

This type of sharing is allowed because it is in our legitimate business interests. We will never share any medical information for this purpose.

Using Your Health Data

Your Health Data is special category personal data. We treat it as such. We keep it secure and only use it to provide the App and the services to you, including counselling. We will never pass this data on to anyone without your explicit consent, or as outlined above, or when the counsellor you are dealing with believes it is in your vital interests to do so. In these situations your counsellor may pass your information to the emergency services but will not pass it to anyone else.

When you first use the App and open an account, you are required to fill in a questionnaire, which asks for Health Data. By completing this questionnaire you consent to our collection and use of your Health Data information. If you do not wish to share this data then do not complete the questionnaire but, in doing so, you understand that we are unlikely to be able to provide you with some, or all, of the services for which you or your employer have signed up. You understand that we will share your Health Data with our counsellors. We will only ever share your Health Data with third parties such as emergency services, where we believe that your life is at risk because of something you are doing or because you are at risk from somebody else or you are a risk to somebody else.

Please note that you can withdraw your consent at any time, but if you do so, you will not be able to book any/further sessions with a counsellor.

Please note that we never share your Health Data with your employer. The only thing we may share with your employer is if you have missed three or more sessions that you’ve booked with a counsellor.

You can ask us to update or delete your Health Data by emailing us. See the “Your Rights” and “How to Contact Us” sections at the end of our Policy.

The legal grounds we have to use your Health Data is your consent and, sometimes, vital interest.

Health Connect Data (Android)

InsideOut integrates with Health Connect by Android, a secure platform developed by Google that allows users to share health and fitness data between apps under their control.

If you choose to connect InsideOut with Health Connect, the app may read the following data types that you explicitly grant permission for:

  • Heart Rate and Resting Heart Rate

  • Heart Rate Variability (RMSSD)

  • Steps and Step Cadence

  • Exercise Sessions

  • Active and Total Calories Burned

  • Sleep Sessions

InsideOut uses this information solely to calculate your personalised Wellbeing Score.

This information is used to improve your wellbeing experience and is not used for advertising, profiling, or analytics outside the wellbeing calculation.

You remain in full control of your Health Connect data:

  • You decide which data types InsideOut can access.

  • You can revoke access or delete shared data at any time in the Health Connect app.

  • InsideOut only reads data that you grant permission for and does not share or sell this data to any third party.

  • Health Connect data is processed locally or securely on our servers for the purpose of calculating your Wellbeing Score.

For more information about Health Connect, visit https://developer.android.com/health-connect.

Apple Health (HealthKit) Data (iOS)

InsideOut integrates with Apple HealthKit on iOS devices to access health and activity data that you explicitly allow.

If you choose to connect InsideOut with Apple Health, the app may read data types such as:

  • Heart Rate and Resting Heart Rate

  • Heart Rate Variability (HRV)

  • Steps and Walking Distance

  • Exercise Workouts

  • Active Energy and Total Energy Burned

  • Sleep Analysis

InsideOut uses this data only to calculate your Wellbeing Score.

You are always in control of your Apple Health data:

  • You decide which data types InsideOut can access when prompted by iOS.

  • You can revoke or change access at any time in the Apple Health app.

  • InsideOut does not use HealthKit data for marketing, analytics, or advertising.

  • HealthKit data is processed locally or securely on our servers for the sole purpose of generating your Wellbeing Score.

For more information about Apple HealthKit, visit https://developer.apple.com/healthkit/.

Who Do We Share Your Data With?

InsideOut shares your personal data as follows:

  • With counsellors, so they can provide the services you request.

  • With trusted third-party providers (e.g., AWS, Twilio, OpenAI) who process data securely on our behalf.

  • With emergency services in cases where there is a serious risk to life or safety.

  • With legal or regulatory bodies if required by law.

We do not share your Health Data with your employer, except to confirm attendance statistics on an anonymised basis.

How Do We Protect Your Data?

We use encryption, secure storage, and strict access controls to protect your data. Only authorised personnel and trained counsellors have access, and all are required to handle data in compliance with GDPR and professional standards.

How Long Do We Keep Your Data For?

We retain your data only as long as necessary to deliver our services or comply with legal obligations — typically up to 10 years. You can request deletion at any time (see “Your Rights”).

Your Rights

You have the right to:

  • Access, correct, or delete your personal data

  • Withdraw consent for processing of Health Data

  • Restrict or object to processing under certain conditions

  • Lodge a complaint with the UK Information Commissioner’s Office (ICO)

Contact us at [email protected] to exercise any of these rights.

Cookies

We do not use cookies or tracking technologies in the InsideOut mobile app.

Changes to This Policy

If we decide to change our Privacy and Cookies Policy to reflect changes in the App or in the law, we will post the changes on our App and, where appropriate, notify you via the App.
We encourage you to review this Policy regularly.
The latest version will always include the date at the top of the page.

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