Privacy and Cookies Policy

1. Introduction

We understand that your privacy is important to you and you care about the use of your personal data. We respect and value the privacy of everyone whose data we process. This privacy policy explains what personal data we collect, how we use it, who we share it with, how long we keep it, and what your rights are.

This policy applies to users of the Wobble On Demand platform, therapists and counsellors who provide services through the platform, and visitors to our website.

2. Who We Are

Wobble is a trading name of Get Wobbled Ltd, a company registered in England and Wales (company number 11737525). Our registered office address is: The Cowshed, Packwood Ln, Solihull B94 6AU.

Get Wobbled Ltd is a registered Data Controller with the Information Commissioner's Office (ICO registration number ZB681991).

Get Wobbled Ltd trading as Wobble ("we", "us", or "our") operates the Wobble On Demand platform at minutesnotweeks.co.uk (also accessible via getwobble.co.uk), which provides on-demand, personalised mental health support from qualified professionals.

3. What Is Personal Data

Personal data is defined by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 as any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier.

In simpler terms, personal data is any information about you that enables you to be identified. This includes obvious information such as your name and email address, but also less obvious information such as IP addresses and device identifiers.

4. What Data We Collect

4.1 If You Are a User

4.2 If You Are a Therapist

4.3 If You Are a Website Visitor

If you visit our website without creating an account, we collect technical data (IP address, browser type, device information) and any information you voluntarily provide through contact forms or enquiries.

5. How We Collect Your Data

We collect data in the following ways:

• Directly from you when you register, complete onboarding, submit a request, provide feedback, contact support, or interact with the platform
• Automatically via cookies and similar technologies when you visit our website (see section 14 below)
• From third-party services, specifically Stripe, which provides us with payment confirmation and transaction data

6. How We Use Your Data

6.1 Users

We use your data to:

• Register and manage your account
• Deliver the Wobble On Demand service, including matching you with a qualified therapist and delivering personalised responses
• Transcribe voice submissions using AI transcription to enable therapist review
• Process payments securely through Stripe
• Communicate with you about your submissions, responses, and account
• Provide support and respond to your queries
• Conduct quality assurance checks on therapist responses
• Improve our service, including understanding usage patterns and user needs
• Comply with legal and regulatory obligations
• Send you marketing communications (only with your explicit consent, and you can opt out at any time)

6.2 Therapists

We use your data to:

• Register and manage your therapist account
• Verify your professional credentials and registration status
• Assign submissions to you and manage your workload
• Process payouts securely through Stripe Connect
• Conduct quality assurance reviews of your responses
• Communicate with you about assignments, platform updates, and operational matters
• Comply with legal and regulatory obligations

7. Lawful Basis for Processing

Under the UK GDPR, we must have a lawful basis for processing your personal data. The bases we rely on are:

Special category data: Where you share information about your mental health through submissions, this constitutes special category data (health data) under the UK GDPR. We process this data on the basis of your explicit consent, which you provide each time you make a submission. You may withdraw this consent at any time, although this may affect our ability to provide the service.

8. Who We Share Your Data With

We share your data only with parties who are necessary for the delivery of our service:

9. International Transfers

We aim to store your data within the United Kingdom wherever possible. Some of our third-party service providers may process data outside the UK. Where this happens, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office, or transfers to countries with an adequacy decision.

10. How Long We Keep Your Data

10.1 Users

• Submission data (text, voice recordings, transcripts): retained for 12 months from the date of submission, after which it is securely deleted
• Therapist response data(video responses, written summaries, and guidance): retained in anonymised form for quality improvement and service development purposes. If you delete your account, your identity is removed from these records but the therapist's response content may be retained
• Account data (name, email, onboarding answers): retained for the duration of your account plus 6 years, in line with standard limitation periods for legal claims

10.2 Therapists

Therapist account and professional data is retained for the duration of the therapist's engagement with the platform plus 6 years, to support professional record-keeping and any potential regulatory enquiries.

10.3 Website Visitors

Enquiry data submitted via contact forms is retained for up to 1 year from the date of the enquiry.

11. Your Rights

Under the UK GDPR, you have the following rights regarding your personal data:

• Right of access: you can request a copy of the personal data we hold about you
• Right to rectification: you can ask us to correct any inaccurate or incomplete data
• Right to erasure: you can ask us to delete your personal data in certain circumstances. When you delete your account, all personal content is removed. Anonymised therapist response records and payment records are retained as described in section 10
• Right to restrict processing: you can ask us to limit how we use your data in certain circumstances
• Right to data portability: you can request a copy of your data in a structured, machine-readable format
• Right to object: you can object to processing based on legitimate interests
• Right to withdraw consent: where processing is based on consent, you can withdraw it at any time

To exercise any of these rights, please contact us at support@getwobble.co.uk. We will respond to your request within one month.

If you are not satisfied with how we handle your request, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

12. Data Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it, including:

• Encryption of data in transit (HTTPS/TLS) and at rest
• Access controls limiting who can view your data to authorised personnel and your assigned therapist only
• Private, access-controlled storage for all sensitive media (voice recordings and therapist video responses)
• Short-lived signed URLs for media access, ensuring content is not permanently publicly accessible
• Regular review of our security practices and third-party provider security standards
• Row-level security policies on our database, ensuring users can only access their own data

13. Children

Wobble On Demand is intended for users aged 18 and over. We do not knowingly collect personal data from children under 18. If we become aware that we have collected data from a person under 18, we will take steps to delete it as soon as possible.

14. Cookies

14.1 What Are Cookies

Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently, provide a better user experience, and give site owners useful information about how their site is being used.

14.2 How We Use Cookies

We use a limited number of cookies to operate and improve our service. We do not use cookies for behavioural advertising or cross-site tracking.

14.3 Types of Cookies We Use

14.4 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. Please note that blocking strictly necessary cookies may prevent you from using certain features of our service. You can also manage your cookie preferences through our cookie consent banner when you first visit the site.

15. Links to Other Websites

Our platform may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites. We encourage you to review the privacy policy of every site you visit.

16. Changes to This Policy

We may update this privacy and cookies policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Where changes are material, we will notify you by email or through a notice on the platform. We encourage you to review this page periodically for the latest information.

17. Contact

If you have any questions about this privacy and cookies policy, wish to exercise your data rights, or want to raise a concern about how your data is being handled, please contact: