NeuroHub Compass
AI policy
This policy explains how NeuroHub Compass uses artificial intelligence (the Phoenix companion), what happens to the things you tell it, and the rights you have under the UK GDPR, the Data Protection Act 2018 and the EU GDPR. It is written in plain words. Our privacy page covers the rest of the service. How NeuroHub uses AI in everything else it does is in the NeuroHub AI Policy.
At a glance
- You are talking to an AI. Phoenix is a computer program. It is not a person, a therapist, a doctor or a crisis service.
- Your chats are on your device, and in your account if you keep sync on, encrypted. NeuroHub does not store or log the messages you send to Phoenix AI.
- Messages are processed by Anthropic. When you use Phoenix AI, your message goes through our server to Anthropic’s Claude model, which writes the reply. The built-in helper never sends anything anywhere.
- Your check-ins are not sent to the AI unless you allow it in Settings.
- Nobody makes decisions about you. Phoenix does not profile you, score you or decide anything that affects your rights.
- Safety does not depend on the AI. Crisis detection and the red Help button run inside the app.
1. About this policy
Who we are. NeuroHub Compass is made and run by NeuroHub Community Ltd (“NeuroHub”, “we”, “us”). For the personal data described below, NeuroHub is the data controller, and NeuroHub Community Ltd is registered with the Information Commissioner’s Office (ICO), registration reference ZC088866.
What it covers. The web app at the NeuroHub Compass address and the installed app, including the Phoenix companion that floats beside the app, Phoenix’s chat, voice, memory notes, document drafting and the daily ideas.
Laws it follows. The UK General Data Protection Regulation, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR) and, for people in the European Economic Area, the EU GDPR. We also follow the transparency duties of the EU AI Act (Regulation 2024/1689) as they apply to a service like this.
2. What the AI is and is not
Phoenix helps you think things through, talk about your check-ins, use tools such as breathing and grounding, and draft documents. It is a companion for reflection and learning, built on knowledge written by NeuroHub and by authors who have given permission, credited by name when used.
Phoenix is not
- A therapist, counsellor, doctor or crisis service. It cannot diagnose, treat or prescribe, and it does not give medical advice.
- A way to get urgent help. Nobody monitors conversations and we cannot contact you.
- A medical device, or a tool for deciding anything about your care, employment, benefits, education or legal position.
3. How the AI works
Phoenix has two ways of answering you, and you can switch at any time in Settings.
Built-in helper
Answers come from rules and writing stored in the app. It runs entirely on your device and works offline. Nothing you type leaves your device.
Phoenix AI
- You send a message. The app adds Phoenix’s instructions and, where relevant, short reference extracts, the memory notes you have chosen to keep and, only if you have allowed it, a short numbers-and-notes summary of your recent check-ins.
- That bundle goes to NeuroHub’s server, which checks that you are signed in, that your licence allows it and that it is a genuine Phoenix request, and then forwards it to Anthropic’s Claude model.
- The reply streams straight back to you. NeuroHub does not store or log your messages or the replies. We keep only anonymous counters and a hashed record of how many replies your account has used, to apply the limits.
- Only the most recent part of the conversation is sent, up to a fixed length.
What the AI is not allowed to do
- It does not run on its own. It only replies when you send a message.
- It does not make decisions about you, produce a score or label about you, or take any action outside the chat.
- It does not try to detect your emotions from your voice, face or body. Voice is turned into text by your browser, and Phoenix does not record, keep or send audio.
- It does not use your messages to train a model. NeuroHub does not train models, and Anthropic’s commercial terms do not permit it to train on content sent through its API by default.
Automated safeguards
Some checks run on your device before and after the AI: spotting words that suggest a crisis, handling questions about medicines with a careful built-in answer, and checking that helpline numbers in a reply are the verified ones. These protect you. They do not produce any decision about you that has legal or similarly significant effects, so Article 22 of the GDPR (automated decision-making) does not apply.
4. Limits on Phoenix AI
Every reply costs NeuroHub money, so there are limits, and they follow your licence: a fair daily allowance while you are making your six payments; 10 replies each calendar month after you own the app; and the daily allowance again for as long as you keep the optional AI add-on. If you have no active licence, Phoenix AI is off and the built-in helper answers. There are also daily and monthly limits for everyone together as a last line of defence. We may pause Phoenix AI at any time. The built-in helper, the Toolkit and the safety tools are never limited.
5. Data we handle and why
| Purpose | Data | Lawful basis (UK and EU GDPR) | Who sees it |
|---|---|---|---|
| Phoenix AI replies | The messages you send, Phoenix’s instructions, reference extracts, any memory notes you have kept, and (if you allow it) a short check-in summary | Article 6(1)(b), providing the service you bought. For any health details you choose to type, or allow Phoenix to read, Article 9(2)(a), your explicit consent | Anthropic as our processor, for the moment it writes the reply. NeuroHub does not keep the content |
| Check-ins, notes, documents, settings | Everything you create in the app | On your device. If you keep sync on, Article 6(1)(b) and Article 9(2)(a), explicit consent given by turning sync on | You. NeuroHub staff do not read synced data, which is encrypted with a key only the server holds |
| Account | A one-way fingerprint of your email address | Article 6(1)(b) | NeuroHub systems only. Brevo sends the sign-in code |
| Licence and payments | The account fingerprint, payments made, plan status, Stripe reference numbers, amounts, and the version of the terms agreed. Your email address and card are held by Stripe, not NeuroHub | Article 6(1)(b), and Article 6(1)(c) for accounting records | Stripe as a payment processor. NeuroHub sees status and amounts |
| Usage numbers on your account | Days the app was used, check-ins done per day, streak, ideas opened. Numbers only, never content | Article 6(1)(f), our legitimate interest in running and improving the service | Authorised NeuroHub admins, as totals on a dashboard |
| Memory notes | Short notes Phoenix keeps about you, which you can view, edit, switch off and delete | Article 6(1)(a), your consent, which you give by leaving notes switched on | You. The notes go to Anthropic with a message so Phoenix can use them |
| Optional sharing of check-in scores | The date, seven numbers from 1 to 5 and a random ID made on your device | Articles 6(1)(a) and 9(2)(a), explicit consent. Off until you turn it on. 16 and over only | Authorised NeuroHub admins, as group results only (never for fewer than five people) |
| Limits and abuse prevention | A hashed account reference and a counter | Article 6(1)(f), our legitimate interest in stopping abuse and keeping the service affordable | NeuroHub systems only |
| Anonymous usage counts | Daily totals, coarse device type, country code, referring site. No cookies, no identifier | Article 6(1)(f). You can switch it off. We honour Do Not Track and Global Privacy Control | Authorised NeuroHub admins |
| Security and legal duties | Technical logs held by our host, and information needed to respond to a legal request | Article 6(1)(f) and Article 6(1)(c) | Our host. Authorities where the law requires |
What we never do. We do not sell personal data, use it for advertising, or build marketing profiles.
6. Health and other sensitive information
Check-ins and conversations can touch on health, neurotype and other special category data, so we treat all of it with extra care. You choose what to write, and the app never needs you to type health details to work. By default, your check-ins are not sent to the AI. After a crisis conversation Phoenix does not write memory notes. Because this is a wellbeing tool that handles health information, we are completing a Data Protection Impact Assessment (DPIA) for it, and we will review it at least every six months and whenever these features change.
7. Who receives data
| Provider | Role | What it receives |
|---|---|---|
| Anthropic | Processor. Runs the Claude model that writes Phoenix AI replies | The content of a Phoenix AI request, at the moment you send it |
| Netlify | Processor. Hosts the website, the app, the server functions and the encrypted account store | Ordinary server data such as IP addresses in short-lived logs, and encrypted account data |
| Brevo | Processor. Sends the one-time sign-in code by email | Your email address, at sign-in, so the code can be delivered |
| Stripe | Processor (and independent controller for its own legal duties). Takes the payments and tells NeuroHub Compass whether your plan is active | Your email address and payment details, entered on Stripe’s own page, and your account’s anonymous fingerprint |
| Your browser vendor (Google or Microsoft) | Independent. Turns speech into text if you use voice in Chrome or Edge | Audio from your microphone while listening. This happens in your browser, not through NeuroHub |
We do not give personal data to anyone else, except where the law requires it. Results we may publish about wellbeing are combined and anonymous, and are never shown for fewer than five people.
8. Transfers outside the UK and the EEA
Anthropic, Netlify, Brevo and Stripe may process data outside the UK and the European Economic Area, including in the United States. Where they do, we rely on an adequacy decision or the UK–US and EU–US data bridge arrangements where the provider is certified, or the standard contractual clauses approved by the European Commission together with the UK International Data Transfer Addendum. You can ask us for a copy of the safeguards in use.
9. Keeping and deleting data
| Data | How long |
|---|---|
| Phoenix AI messages and replies | Not kept by NeuroHub. They pass through and are discarded |
| Data on your device | Until you delete it in Settings or clear your browser data |
| Account data | Until you delete your account. Deleting is permanent, removes all synced data and ends your licence |
| Saved data after payments stop early | Kept read-only for 30 days so you can download, delete or carry on, then permanently deleted. A daily job removes it even if you never return |
| Payment records and amounts | As long as the law requires for accounting, usually six years. Stripe keeps payment records for as long as the law requires |
| Usage numbers on your account | While the account exists |
| Reported replies | Until reviewed, and no longer than one year. Only the reply, the reason and your note are kept, with nothing that identifies you |
| Shared check-in scores | Until you withdraw and delete them, and no longer than two years |
| Limit counters | Days to one month |
| Anonymous usage totals | As totals, for as long as they are useful. They contain nothing about you |
10. Your rights
Under the UK GDPR and the EU GDPR you have these rights. Most you can use yourself in Settings. For the rest, contact us. We reply within one month and do not charge, unless a request is clearly unfounded or excessive.
Because your email address is not stored, we may ask you to sign in to show that an account is yours before we act on a request about it.
11. Safety and limits
- Crisis support. Detection of distress and the Help panel run inside the app and never depend on the AI. Replies in a crisis are checked so they contain only verified helplines, which we review regularly.
- Medicines and medical questions. Phoenix gives a careful built-in answer and points you to a professional, instead of letting the AI guess.
- Pause. NeuroHub can pause Phoenix AI at any time if it misbehaves. The built-in helper keeps working.
- Reporting. If a reply is wrong, unsafe or upsetting, press the Report button under it. That sends us only the reply, the reason you choose and an optional note, never your own message, your name or anything about your device.
12. Fairness, accuracy and transparency
- It can be wrong. AI replies can be inaccurate, incomplete or out of date, and may sound more certain than they should. Check anything important with a qualified person.
- Neuro-affirming by design. Phoenix’s instructions are written to respect neurodivergent people, avoid pathologising language and avoid pressure to mask.
- Always labelled. Phoenix tells you it is an AI at the start and whenever you ask. Text written by the AI in documents you create is yours to review and edit before use.
- Sources are named. When Phoenix uses writing from NeuroHub or Helen Edgar, it names the source.
13. How we govern it
- Risk level. Under the EU AI Act we treat Phoenix as a limited-risk system that interacts directly with people. Our duty is transparency, which this policy and the in-app labelling meet. Phoenix does not use emotion recognition, biometric identification, social scoring or any practice the Act prohibits.
- Data protection by design. Check-ins stay on your device by default, email addresses are not stored, account data is encrypted, and the dashboard shows only numbers.
- Access control. Only named NeuroHub people with the admin role can see the dashboard, and they sign in with a password and an authenticator code. Sign-ins are logged.
- Incidents. If a personal data breach is likely to put you at risk, we report it to the ICO and, where required, to the relevant EU authority within 72 hours, and tell you without undue delay when the risk is high.
- Review. We review this policy at least once a year and whenever the AI features change materially.
14. Age
NeuroHub Compass is designed for adults. An account and the licence are for people aged 18 and over. If we learn that we hold data from someone below that age, we will delete it.
15. Contact and complaints
NeuroHub Community Ltd. For questions, to use a right, or to report an AI reply that went wrong, write to enquiries@neurohubcommunity.org or use the form at neurohubcommunity.org/contact-us. Please include “NeuroHub Compass” in the subject line. If you are unhappy, please tell us first and we will try to put it right. You can also complain to a data protection authority at any time.
- In the UK: the Information Commissioner’s Office, ico.org.uk/make-a-complaint, telephone 0303 123 1113.
- In the EU or EEA: the supervisory authority in the country where you live, work or believe the issue happened (edpb.europa.eu).
Quick questions
Does NeuroHub read my check-ins or chats?
No. They are on your device. With Phoenix AI, a chat message passes through our server to Anthropic and is not stored or logged by us. If you keep sync on, your data is encrypted and staff cannot read it. The dashboard shows numbers only.
Is my data used to train AI?
No. NeuroHub does not train models, and Anthropic’s commercial terms do not allow it to train on API content by default.
Can I use it with no AI at all?
Yes. Choose the built-in helper in Settings. It works offline and sends nothing anywhere. The check-in, the daily ideas, your trends and the Toolkit never need the AI.
What happens if the AI says something harmful?
Tell us, or press Report under the reply. We review it, fix the cause and, if needed, pause Phoenix AI. Safety checks also run on your device independently of the AI.
Changes to this policy
Version 1.0, 8 October 2026, was the first version. When we make a material change we will update the date and version, show a notice in the app, and keep earlier versions available on request.