Privacy Policy

Last updated: 11 November 2025

Our Commitment to Your Privacy

Budd is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Who We Are

When we refer to 'The International Psychology Clinic', 'The International Psychology Clinic Ltd', 'we', 'our' or 'us' in this Privacy Policy, we refer to:

The International Psychology Clinic Limited

Trading as Budd

Registered Office: Unit 29, Highcroft Industrial Estate, Horndean, Waterlooville, Hants. PO8 0BT

Company Registration Number: 10877544

The International Psychology Clinic Limited is the data controller responsible for your personal data.

1. Information We Collect

We collect and process the following types of information:

  • Account Information: Email address, name, subscription status
  • Therapy Data: Chat messages, journal entries, mood tracking data, homework assignments, behavioural activation plans
  • Usage Data: Session information, feature usage, progress metrics
  • Technical Data: IP address, browser type, device information
  • Payment Information: Processed securely through Stripe (we do not store full payment details)
  • Communication Data: Emails sent through our service via Brevo

2. How We Use Your Information

We use your personal data for the following purposes:

  • To provide and improve our science-backed therapy services
  • To personalise your experience and provide AI-driven recommendations
  • To process payments and manage subscriptions
  • To send transactional emails and important service updates
  • To ensure the security and proper functioning of our services
  • To comply with legal obligations

Legal Basis: We process your data based on (a) your consent, (b) contractual necessity, (c) legal obligations, and (d) legitimate interests in providing and improving our services.

Data Minimization & Transparency

We are committed to collecting and processing only the minimum amount of data necessary to provide you with effective mental health support:

  • We collect only data essential to deliver therapy services and improve your experience
  • Therapy messages are transmitted to AI providers only to generate responses — no other processing occurs
  • Account identifiers and personal details are not shared with AI providers
  • Analytics data is aggregated and anonymized to prevent user identification
  • We do not retain conversation data longer than necessary for your active treatment

Explicit Data Collection Categories

Therapy & Mental Health Data

  • AI therapy session messages and responses
  • Journal entries and reflections
  • Self-assessment questionnaire responses (PHQ-9, GAD-7, etc.)
  • Mood tracking entries and anxiety levels
  • Goal definitions and progress updates
  • Homework completion records
  • Exercise and activity logs

Account & Profile Information

  • Email address and authentication credentials
  • Full name and language preferences
  • Subscription tier and billing information
  • Account creation and login history
  • Profile customization (therapist personality, voice preferences)
  • Timezone and device preferences

Technical & Usage Data

  • Device type, operating system, and browser information
  • App version and platform (iOS, Android, Web)
  • IP address (for security and fraud prevention)
  • Feature usage analytics (exercises completed, pages visited)
  • Session duration and interaction frequency
  • Error logs and crash reports

Analytics & Improvement Data

  • Aggregated engagement metrics
  • Feature adoption and usage patterns
  • Performance metrics (load times, response times)
  • User satisfaction and feedback
  • A/B testing and experimentation data
  • Anonymized behavioral patterns

3. Data Security

We implement industry-standard security measures to protect your personal data:

  • End-to-end encryption for sensitive therapy data
  • Secure data storage with regular backups
  • Access controls and authentication measures
  • Regular security audits and updates
  • Compliance with UK data protection standards

4. Data Sharing and Third Parties

We do not sell your personal data. We may share your data with:

  • Stripe: For secure payment processing (UK & EEA data centres)
  • Brevo: For transactional email delivery (GDPR-compliant)
  • Cloud Service Providers: For data storage and hosting (UK/EEA servers)
  • Firebase Analytics: We use Firebase Analytics to track app usage, performance metrics, and user engagement. Firebase may process your IP address and device information in accordance with their privacy policy.
  • Legal Authorities: When required by law or to protect rights and safety

All third-party processors are carefully selected and bound by data processing agreements ensuring GDPR compliance.

Third-Party AI Providers – Data Handling & Privacy

When you use Budd's AI therapy features, your messages are securely transmitted to the following providers for response generation:

  • Anthropic (Claude) – Provides cognitive and behavioral therapy-focused responses Privacy Policy
  • OpenAI (GPT Models) – Powers personalized therapy interventions and adaptive support Privacy Policy
  • Google DeepMind (Gemini) – Offers advanced reasoning for clinical formulations and insights Privacy Policy

How Your Data Is Handled by AI Providers:

  • Only message content necessary for response generation is transmitted
  • Data is encrypted in transit using industry-standard TLS 1.3 protocol
  • Your conversation data is not used to train or improve public AI models
  • Each provider maintains their own security certifications (SOC 2, ISO 27001)
  • No identifiable user information (name, email, account ID) is shared with these providers

By using Budd's AI features, you consent to this secure transmission of message content to these third-party providers.

By using Budd's AI features, you acknowledge that your conversation content will be processed by these third-party AI providers. If you have concerns, you can contact us at legal@getbudd.ai.

5. Your Rights

Under UK GDPR, you have the following rights:

  • Right of Access: Request a copy of your personal data
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure: Request deletion of your data ("right to be forgotten")
  • Right to Restrict Processing: Limit how we use your data
  • Right to Data Portability: Receive your data in a structured format
  • Right to Object: Object to certain processing activities
  • Right to Withdraw Consent: Withdraw consent at any time

To exercise any of these rights, please contact us at legal@getbudd.ai or use the account deletion feature in Settings.

6. Data Retention

We retain your personal data only for as long as necessary to provide our services and comply with legal obligations:

  • Active account data: Retained whilst your account is active
  • Archived therapy conversations: Retained for 7 years in line with UK healthcare records standards
  • Clinical assessments and formulations: Retained for 7 years as required by healthcare regulations
  • Journal entries: Retained according to your chosen preference (2 years recommended, or up to 7 years), configurable in Settings
  • Deleted account data: Permanently deleted within 30 days of account deletion request
  • Payment records: Retained for 7 years for tax and accounting purposes
  • Legal compliance data: Retained as required by UK law

You may request early deletion of your personal data at any time by contacting us at legal@getbudd.ai or using the account deletion feature in Settings. Certain data may be retained beyond your request where required by law or legitimate business necessity.

7. International Data Transfers

Your data is primarily stored and processed within the United Kingdom and European Economic Area (EEA). Any transfers outside these regions are protected by appropriate safeguards, including:

  • Standard Contractual Clauses approved by the UK ICO
  • Adequacy decisions recognising equivalent data protection standards
  • Additional technical and organisational security measures

8. Children's Privacy

Budd is not intended for children under 18 years of age. We do not knowingly collect personal data from persons under 18. If we learn we have collected data from a person under 18, we will delete it promptly.

9. Cookies and Tracking

We use strictly necessary cookies to provide our services. We do not use tracking cookies for advertising purposes. You can manage cookie preferences through your browser settings.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or through the app. Continued use of our services after changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact:

Data Protection Officer

The International Psychology Clinic Limited

Unit 29, Highcroft Industrial Estate

Horndean, Waterlooville

Hants. PO8 0BT

Email: legal@getbudd.ai

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk

Your Privacy Matters

At Budd, we believe your mental health journey is deeply personal. We are committed to maintaining the highest standards of privacy and data protection. Your data is encrypted, secure, and never sold to third parties.

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"Progress begins with understanding. Understanding begins with being heard. We built Budd so neither is ever out of reach."

Dr Martina Paglia
- Dr Martina Paglia

Budd is an AI Therapist designed to help you understand your emotions and inner states. Budd is not a licensed psychologist, psychotherapist or psychiatrist and does not provide medical services. These sessions are for self-help purposes only and do not replace the advice of a qualified professional therapist.

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