Privacy Policy.

1. Introduction

MyPenelope (“we”, “us”, or “our”) provides a tool to help users track and organise personal, behavioural, and health-related data. Because this may include special category data under the UK GDPR, we take privacy extremely seriously.

This Privacy Policy explains how your data is handled when using the MyPenelope mobile app and website.

Important: At this time, we do NOT store, access, or transmit any personal or health data to our servers. All data you enter into the MyPenelope app is stored locally on your device only. Cloud-based backup and synchronisation are planned for a future subscription service, and this policy will be updated before that feature launches.

 

2. Data We Collect

2.1 Data You Enter

You may choose to enter:

• Personal information (name, date of birth, profile labels)

• Health-related information (symptoms, behaviours, wellbeing notes)

• Routine or environmental factors

• Notes and observations

This information is stored only on your device.
We do not collect, receive, transmit, or view it.

2.2 Automatically Collected Technical Data

To improve app performance and security, we may collect:

• Device type

• Operating system version

• Diagnostic/Crash data

• Anonymous analytics (if enabled)

This information does not include any health data and cannot identify the content you enter into the app.

 

3. How Data Is Stored

3.1 Local Device Storage (Current Version)

All personal and health-related information is stored:

• On your device only

• Encrypted by your device’s operating system (iOS/Android)

• Not transmitted to us or third parties

3.2 No Remote Access

We cannot:

• Access your entries

• Retrieve lost data

• View or process your information

If your device is lost or damaged, your data may be permanently lost unless you manually back up your phone using the device’s built-in backup tools.

 

4. Future Cloud-Sync Service (Not Yet Active)

A subscription service will be introduced in the future, enabling:

• Cloud-based storage

• Secure multi-device synchronisation

• Optional data backup and export

This feature is not currently available.
We do not store or process any of your data until this feature is launched.

Before activating cloud features:

• We will update this Privacy Policy

• Users will be required to explicitly consent

• Users will be informed of data processors used (e.g., hosting providers)

• Users may opt out or continue using local-only mode

 

5. Lawful Basis for Processing (When Cloud Storage Is Introduced)

Once we process special category data, we will rely on:

• Explicit consent for storing and processing health information

We will request this consent clearly, separately, and explicitly before enabling cloud syncing.

 

6. Children’s Privacy

Parents or legal guardians may enter data about minors.
We do not knowingly collect any data directly from children.

Since all data is stored locally:

• We have no access to children’s information

• We do not profile or analyse minors' data

Cloud features will include enhanced parental consent controls.

 

7. Your Rights (Under UK GDPR)

Even though we do not process your data on our servers, once cloud storage launches, you will have rights to:

• Access your data

• Correct inaccurate data

• Delete your data

• Withdraw consent

• Data portability

• Restrict or object to processing

These rights will apply only to data stored remotely, not device-local data.

 

8. Security

Because data is stored on your device:

• Security depends partly on your device’s safeguards (e.g., passcode, encryption)

• We recommend enabling device-level encryption and biometric authentication

• We cannot protect data stored on an unlocked or unprotected device

When cloud service launches, we will implement:

• Encryption in transit and at rest

• Access controls

• Zero-trust architecture

• Secure data deletion procedures

 

9. Changes to This Policy

We will notify users clearly and in advance before:

• Introducing cloud storage features

• Changing data storage methods

• Using new third-party processors

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Account Deletion and Data Removal

Users have full control over their account and data within the My Penelope app.

You may request deletion of your account at any time. When an account deletion request is made, all data associated with that account will be permanently removed and will no longer be accessible.

If you require assistance with account deletion, you can contact us at family@mypenelope.co.uk, and we will support you in completing this request.

We do not retain personal data once an account has been deleted, except where we are legally required to do so.

Local Data Storage

The free (freemium) version of My Penelope stores data locally on your device.

This means that information you record in the app — such as sleep, seizures, mood, meltdowns, or mobility — is saved directly on your device and is not uploaded to external servers.

Because data is stored locally:

• Your information remains under your control

• No cloud storage is used in the free version

• Data is not shared with third parties

Future premium features may offer optional cloud-based services. If introduced, these features will be clearly explained, and users will be required to provide explicit consent before any data is stored externally.

 

10. Contact Information

If you have questions about privacy or data protection, contact us:

Email: support@mypenelope.co.uk
Website: www.mypenelope.co.uk

Terms & Conditions

 

1. Acceptance of Terms

By downloading or using MyPenelope, you agree to these Terms & Conditions. If you do not agree, do not use the app.

 

2. Description of the Service

MyPenelope provides tools for monitoring and organising personal, wellbeing, and behavioural information.
It is not a medical device and does not diagnose or treat any medical conditions.

 

3. Data Storage Disclaimer

At present:

• All data is stored locally on the user's device.

• We do not store or process your data on our servers.

• We cannot recover lost data if you lose your device or if there is an issue with the function of the app.

Cloud features will be optional and require separate subscription and consent.

 

4. User Responsibilities

You agree to:

• Enter data accurately

• Keep your device secure

• Ensure backups are enabled if you want to preserve data

• Use the app only for lawful purposes

 

5. No Medical Advice

The app:

• Is not intended as medical advice

• Is not a substitute for professional care

• Should not be relied upon for diagnosis or treatment

Always consult a qualified healthcare professional.

 

6. Service Changes and Availability

We may:

• Add or remove features

• Introduce subscription services

• Update the app for performance, security, or compliance

 

7. Intellectual Property

All trademarks, logos, app design, and content belong to MyPenelope Ltd. Users receive a personal, non-exclusive licence to use the app.

 

8. Limitation of Liability

To the fullest extent permitted by law:

• We are not liable for data loss caused by device damage or user error

• We are not responsible for medical decisions or outcomes based on user-entered data

 

9. Termination

We may suspend or terminate access for:

• Breach of terms

• Misuse or illegal activity

• Security concerns

 

10. Governing Law

These Terms are governed by the laws of England and Wales.

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