Last updated: 4th August 2026
(a) This is the Generative AI Use Policy of Netarcs Ltd, a company registered in England and Wales (company number 04614488), with registered offices at C/O Mericrest, 8–10 Pembroke Building, Cumberland Park, Scrubs Lane, London, NW10 6RE, United Kingdom — the creators of Happimate (the "App", "Happimate", "we", "us", "our").
(b) This Policy applies whenever you use Happimate, however you obtained it, and wherever in the world you are. It explains how our AI-powered features (the "AI Services") work, what you can and can't use them for, what happens to the things you type and say, and how we keep quality and safety under review.
(c) How this fits with our other documents. This Policy sits alongside our Terms and Conditions and our Privacy Policy. Together these three documents govern your use of Happimate. Where this Policy gives detail about AI specifically, it expands on — rather than replaces — what those documents say. If there's a genuine conflict about how we handle personal data, the Privacy Policy governs.
(d) Plain-language summary. Happimate uses AI to write meditations and sleep stories for you and to power your AI companion. The AI is software, not a person, and not a professional. It can be wrong. What you type is used to give you the service, keep it safe, and improve it. We don't sell your conversations, we don't use them to train AI models, and we don't allow our AI provider to train on them either.
(e) Changes to this Policy. We may update this Policy. If we make a change that materially affects your rights or how your data is used, we'll tell you in advance through the App or by email, and where the law requires your consent, we'll ask for it. The "last updated" date above always reflects the current version.
Being clear about this matters more than the legal language, so here it is directly.
(a) Guided content generation — writing and personalising meditation scripts, sleep stories, breathing exercises and similar audio or text content, sometimes drawing on your stated preferences or past sessions.
(b) AI companion chat — conversational features where you can talk to an AI companion and receive replies, reflections, prompts and suggestions.
(c) Personalisation and suggestions — recommending content from our library and adjusting what we surface to you.
(d) Safety and moderation — automated systems that check inputs and outputs for content that breaches this Policy or presents a safety risk.
(a) Your AI companion is software, not a person. It has no consciousness, feelings, professional training, qualifications or duty of care — even when it sounds warm, personal or human-like, uses "I", or remembers things you've told it. We design it to be supportive, and we want to be honest that the support is generated, not felt.
(b) AI output is generated, not verified. Responses are produced automatically from patterns in data and from your inputs. They may be inaccurate, incomplete, out of date, biased, irrelevant, unexpected or simply wrong. Two people asking the same thing may get different answers, and so may you on different days.
(c) It is not professional advice. Nothing the AI produces is medical, psychological, psychiatric, therapeutic, nutritional, legal or financial advice, and it must not be treated as such. Please read the "Wellbeing, not healthcare" section of our Terms and Conditions alongside this Policy.
(d) It is not a crisis service. The AI Services are not monitored by humans in real time. They cannot detect, assess or respond to an emergency, and no one is watching your conversation as it happens. If you are in crisis or facing a medical emergency, stop and contact your local emergency services or a crisis helpline.
(e) Our safeguards are real but imperfect. We use moderation systems and safety instructions to keep outputs appropriate. None of this is perfect, and determined attempts to push the system will sometimes succeed. That's a limitation of the technology, not a promise we're quietly withdrawing.
(f) Emotional reliance. AI companions can feel genuinely supportive — that's the point of them. But they aren't a substitute for human relationships or professional care. If you notice yourself depending on the App in a way that concerns you, please take a break and talk to someone you trust or a qualified professional.
(a) We do not make automated decisions that produce legal effects or similarly significant effects on you.
(b) Members of our team may review interactions for safety, quality and troubleshooting purposes, as described in section 3.4. This is review after the fact, not live supervision.
(c) You can contact a human at any time at info@happimate.com.
This section explains what happens to what you type, say and generate. Our Privacy Policy covers our data practices as a whole; this section covers the AI-specific parts.
When you use the AI Services, we process:
(a) your inputs — messages, prompts, voice input, journal or reflection entries, mood or check-in data, and stated preferences;
(b) generated outputs — the meditations, stories, replies and suggestions produced for you;
(c) interaction data — timestamps, session length, features used and content played; and
(d) technical data — device, app version, language and diagnostic information.
Some of this may be sensitive — information about your mood, sleep, stress or wellbeing can reveal a lot. Please share only what you're comfortable sharing.
| Purpose | What this means in practice | Legal basis (EU/UK) |
|---|---|---|
| Providing the service | Generating responses and content, remembering context so your companion feels continuous | Performance of our contract with you |
| Safety and moderation | Automated checks, and human review where needed, to detect content that breaches this Policy or presents a risk of harm | Legitimate interests (keeping users safe); legal obligation where applicable |
| Security and abuse prevention | Detecting misuse, jailbreak attempts, fraud and account abuse | Legitimate interests |
| Troubleshooting | Investigating bugs and errors you or others report | Legitimate interests |
| Improving Happimate | Reviewing patterns to improve quality, relevance and safety — see 3.5 | Legitimate interests |
| Legal compliance | Meeting our legal obligations and handling disputes | Legal obligation; legitimate interests |
Where we rely on legitimate interests, you can object — contact us at info@happimate.com.
(a) Happimate uses OpenAI's API to generate AI outputs. When you use the AI Services, your inputs and the relevant conversation context are sent to OpenAI so a response can be returned. OpenAI processes this data on our behalf, under a data processing agreement.
(b) OpenAI does not use API data to train its models. Data sent through the OpenAI API has not been used to train or improve OpenAI's models since 1 March 2023 unless the customer opts in, and we have not opted in (OpenAI data controls).
(c) OpenAI retains API data briefly for abuse monitoring — up to 30 days by default, unless it is legally required to keep it longer (OpenAI data controls).
(d) OpenAI processes data in the United States and other countries. Our agreement with OpenAI includes the data protection terms and international transfer safeguards required by applicable law. Our Privacy Policy explains how international transfers work.
(e) Where you use voice features that rely on server-side speech-to-text (rather than OpenAI Realtime voice), audio may be sent to Google Cloud Speech-to-Text (Google LLC) to convert speech to text. Google's privacy policy is at policies.google.com/privacy.
(f) If we change or add an AI provider, we'll update this Policy.
(a) Interactions may be reviewed by members of our team for these purposes only:
(i) investigating a safety report, a bug or a complaint;
(ii) checking that safety and moderation systems are working;
(iii) investigating suspected serious breaches of this Policy; and
(iv) meeting a legal obligation.
(b) Reviewers are bound by confidentiality obligations, and access is limited to those who need it.
(c) We do not read your conversations for curiosity, marketing or advertising purposes.
(a) Aggregated and de-identified analysis. We analyse patterns across users in a form that does not identify anyone — for example which meditation lengths get completed, or which prompts tend to produce poor outputs. This is how we improve the App, and it does not involve reading your individual conversations.
(b) We do not use your content to train AI models. We do not use your inputs, conversations or generated outputs to train or fine-tune any AI model — ours or anyone else's. If that ever changes, we will ask for your explicit consent first, separately from this Policy, and it will be a choice you actively make rather than a default.
(c) Safety. Where content is flagged as harmful or unsafe, we may retain and analyse it — including in identifiable form where necessary — to improve safety and prevent recurrence.
(a) Conversation history and generated content — kept while your account is active, so your companion has continuity, and deleted within 1 year of you closing your account.
(b) Safety and moderation records — kept for 6 years where needed to protect users or meet a legal obligation.
(c) Aggregated, de-identified data — kept indefinitely, as it no longer identifies you.
(d) Backups — deleted content may persist in secure backups for a short period before being overwritten.
Full retention detail is in our Privacy Policy.
We process personal data in line with the laws that apply to you, including the EU GDPR and UK GDPR, the California Consumer Privacy Act as amended by the CPRA, and comparable laws elsewhere. Happimate is operated from the United Kingdom and uses providers in other countries, so your data may be processed outside where you live, with appropriate safeguards in place. We do not sell your personal information, and we do not share it for cross-context behavioural advertising.
Within the App you can:
(a) delete your conversation history;
(b) close your account, which deletes your data as described in 3.6.
Wherever you live, you can also contact us at info@happimate.com to:
(c) ask what personal data we hold about you and request a copy;
(d) ask us to correct or delete it;
(e) object to processing based on legitimate interests; and
(f) report a problematic AI output — see section 6.2.
Depending on where you live you may have further rights, including to port or restrict processing, and to complain to a data protection authority. Our Privacy Policy explains how to exercise these.
You may use the App to:
(a) engage with AI-powered conversational features for companionship, reflection and general wellbeing;
(b) generate personalised content, including meditation sessions and sleep stories;
(c) explore and use content in the App's library;
(d) take part in guided sessions and experiences within the App; and
(e) use AI features for relaxation, creativity, self-reflection and personal use.
You must not use the AI Services to:
(a) break the law, or encourage, plan or facilitate unlawful activity;
(b) attempt to jailbreak, prompt-inject, reverse engineer, manipulate or exploit the AI systems, or to extract system prompts, model weights or underlying instructions;
(c) circumvent safety features, content filters, behavioural safeguards or usage limits;
(d) generate or submit content that is abusive, threatening, violent, obscene, hateful, discriminatory, harassing or defamatory;
(e) generate or submit sexually explicit content, or attempt sexually explicit interactions with the AI;
(f) generate, request or submit any content that sexualises, endangers or exploits a minor — this is an absolute prohibition, will result in immediate termination, and will be reported to the relevant authorities where the law requires it;
(g) rely on the AI for medical advice, diagnosis, treatment or emergency guidance, or attempt to use it as a substitute for professional or crisis care;
(h) generate content that promotes or provides instructions for self-harm, suicide, disordered eating, violence, terrorism or serious harm to anyone;
(i) upload or share another person's personal data without their consent, or impersonate another person;
(j) use the App commercially, resell access, or use outputs to build, train or benchmark a competing product or model;
(k) extract, harvest or systematically copy content, prompts or outputs by automated means; or
(l) otherwise breach our Terms and Conditions.
(a) Depending on how serious the breach is, we may issue a warning, restrict access to specific features, temporarily suspend your account, or terminate it. We will normally start with the least restrictive step that addresses the problem.
(b) Unless we're legally prevented, we'll tell you what happened and why, and you can appeal by contacting info@happimate.com. We aim to review appeals within 14 days.
(c) Immediate termination without warning is reserved for the most serious cases — content involving minors, credible threats of harm, or conduct that puts other users at risk.
We monitor AI system performance to identify and correct inaccurate, harmful or inappropriate responses, improve relevance and quality, and check compliance with this Policy and our safety guidelines.
(a) If something goes wrong — an inaccurate answer, an inappropriate response, something that felt unsafe — please report it at info@happimate.com.
(b) When you report an issue, we will:
(i) acknowledge it within 3 working days;
(ii) investigate and respond within 14 working days, or tell you if we need longer and why; and
(iii) prioritise reports involving safety, minors or potential harm.
(c) Reports are taken seriously whether or not you're the person affected.
(a) We test the AI Services through scenario-based evaluations reflecting a range of backgrounds, ages, cultures and life experiences, and through review of response patterns to identify and correct bias. We review our safety instructions periodically.
(b) Testing uses synthetic data, internal test accounts, and aggregated or de-identified data. We do not use your identifiable personal data for bias or quality testing without your explicit consent, other than where we are investigating a specific report or safety incident.
(a) Safety instructions and moderation are built into the AI Services rather than added afterwards.
(b) The AI is designed to respond supportively where a conversation suggests distress, and to point towards professional and crisis support. This is a design intention and a best effort — it is not a guarantee, not a clinical assessment, and not a substitute for contacting emergency services.
(a) You will always be told when you are interacting with AI rather than a human. We won't design the App to blur that line.
(b) We publish material changes to how our AI features work when those changes affect you.
We may update or change our AI systems at any time to improve performance, safety or experience. Significant changes will be communicated through the App or our website. Model changes may alter the tone, style or behaviour of your AI companion.
(a) Netarcs Ltd is responsible for the AI Services and for this Policy. Responsibility sits with Netarcs Ltd, reachable at info@happimate.com.
(b) Where required by applicable law, we carry out impact assessments before launching new AI features that could significantly affect users.
Questions, concerns or feedback about this Policy:
Email: info@happimate.com
Post: Netarcs Ltd, C/O Mericrest, 8–10 Pembroke Building, Cumberland Park, Scrubs Lane, London, NW10 6RE, United Kingdom
For data protection queries specifically, including how to exercise your rights, see our Privacy Policy.