1. Introduction

Apex Minds Services Ltd (“we”, “us” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose and safeguard your information when you access the Apex Minds cognitive performance platform and website (the “Platform”).

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Who We Are

Data Controller: for account management, the website and marketing, Apex Minds Services Ltd is the controller.
Data Processor: where we process employee lists and related data provided by your employer (the “Organisation”), we act as processor on the Organisation’s behalf, under a data processing agreement.

3. The Data We Collect

We collect different types of data depending on whether you are an end user (employee) or an administrator (HR/manager).

A. Personal Data

Identity Data: first name.
Contact Data: corporate email address.
Employment Data: department and employer name.
Technical Data: IP address, login data, browser type and version, time zone setting and operating system.

B. Special Category Data (Health and Wellbeing)

Some data processed through the Platform may reveal information about your health or wellbeing. We collect this only with your explicit consent:

Session Data: audio sessions accessed, duration and frequency of use.
Self-Assessment Data: self-reported stress levels, focus scores or mood check-ins entered before and after sessions.

4. How We Use Your Data and Our Lawful Bases

To provide the Service - granting access to the Platform and delivering personalised audio sessions (lawful basis: performance of a contract; explicit consent for special category data).
Personalisation - tailoring session recommendations based on your preferences, goals and usage (lawful basis: performance of a contract; explicit consent for special category data).
Aggregated employer reporting - providing your Organisation with anonymised, aggregated insights on engagement and workforce trends (lawful basis: legitimate interests; data is anonymised before reporting - see Section 6).
Support and security - resolving technical issues and protecting the Platform (lawful basis: legitimate interests).
Marketing to business contacts - with consent or as otherwise permitted by law; you can opt out at any time.

5. Automated Processing and Artificial Intelligence

The Platform does not use artificial intelligence. Personalisation is delivered through rules-based technology that matches sessions to the preferences and goals you provide. We do not carry out automated decision-making that produces legal or similarly significant effects about you.

6. Data Sharing with Your Employer

We know this data is personal. The Platform is built on a strict separation between what you see and what your employer sees:

What your employer CAN see: that you have an active account, and aggregated, anonymised reports at organisation or department level covering engagement, sentiment trends and index scores.
What your employer CANNOT see: your individual session history, the specific programmes or topics you listen to, or your private self-assessment scores - unless you explicitly choose to share them.

Department-level reporting is designed to preserve anonymity. Where a group is too small for results to be meaningfully anonymous, data is aggregated at a higher level.

7. Data Sharing with Third Parties

Cloud infrastructure providers to host the Platform securely.
Service providers - supporting functions such as email delivery and analytics, under contracts that restrict their use of your data.
Our environmental partner - engagement milestones trigger tree planting through Ecologi; no personal data is shared for this purpose.
Legal authorities - where required by law or to protect the safety of users.

We do not sell personal data.

8. International Transfers

Where our service providers store or process data outside the UK, we ensure appropriate safeguards are in place, such as UK adequacy regulations or the International Data Transfer Agreement (IDTA) / standard contractual clauses.

9. Data Retention

We retain personal data only for as long as your Organisation maintains an active subscription, or as legally required. If your employment ends or the corporate subscription is cancelled, your personal data will be deleted within 24 months. Anonymised, aggregated data that can no longer identify you may be retained for statistical and product improvement purposes.

10. Your Legal Rights

Under the UK GDPR, you have the right to:

Request access to your personal data.
Request correction of inaccurate data.
Request erasure of your data (the “right to be forgotten”).
Object to, or request restriction of, processing of your data.
Request portability of data you have provided to us.
Withdraw consent at any time, in particular regarding special category (health and wellbeing) data - withdrawal does not affect processing carried out before withdrawal.

To exercise these rights, contact us at contact@apexminds.co.uk. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk, although we would welcome the chance to address your concerns first.

11. Cookies

Our website uses cookies and similar technologies. For details of the cookies we use and how to manage them, please see our Cookie Policy or your browser settings.

12. Security

We implement industry-standard security measures, including encryption, access controls and secure protocols, to protect your data. No electronic transmission or storage is entirely secure, and we cannot guarantee absolute security, but we work continuously to protect your information.

13. Age Restrictions

The Platform is intended for users aged 18 and above. We do not knowingly collect personal data from anyone under 18.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be available on our website, with the date of the most recent update shown.

15. Contact Us

Email: contact@apexminds.co.uk

Address: 128 City Road, London, United Kingdom, EC1V 2NX