Privacy Policy & App Usage Terms

1. Introduction

Welcome to NudgeAI, owned and operated by Black Isle (Europe) Group Ltd ("we", "us", or "our"). We are committed to safeguarding your privacy and ensuring the responsible use of your data. This policy explains how we collect, use, store, and protect your personal data in compliance with UK data protection laws (UK GDPR, Data Protection Act 2018) and relevant EU regulations on AI and data protection, including the AI Act and General Data Protection Regulation (EU GDPR).

By using NudgeAI, you agree to the terms outlined in this Privacy Policy & App Usage Terms document. If you do not agree, please do not use the app.

2. Data We Collect

When you use NudgeAI, we may collect the following types of information to support your learning and development journey:

• Personal Information: Your full name, email address, job title, company name, telephone number, and encrypted passwords.
• Learning & Journal Entries: Your personal reflections and journal entries, recorded for self-reflection and learning purposes.
  Journal entries are treated as private and confidential. They are stored securely and are only accessible to your professional coach — if you explicitly choose to share them. Strong access controls are in place to protect this content, and your privacy is always our priority.
• Learning Goals: Your workshop goals may be shared with our workshop coaches and leads to tailor the learning experience within the workshop and to support your learning journey.
• Habit Tracking Data: Activity related to skill practice and habit-building. This data helps us personalise your experience and may be shared with professional coaches to support your progress. Individual habit data is never shared with your employer.
• Aggregated Data: While we do not currently analyse anonymised and aggregated AI conversation data, we may begin doing so in the future as our user base grows and our technology evolves. If introduced, this process will involve only fully de-identified data and will be used strictly to support ethical system improvements, improve quality of support, minimise bias, and enhance learning outcomes. Individual conversations are never shared with external parties, including your employer. In addition, trends in learning and development activity across the platform may also be aggregated. This type of data may be shared with your employer, used in research, or featured in marketing and case studies (e.g. under a client logo, with permission), but it will never identify individual users. The privacy of individuals is always prioritized.
• Learner Stories: With separate and explicit permission from you and your employer, we may invite you to share your learning journey as a case study or success story for marketing or promotional use.
• Conversations:
  • Coach Chats: Conversations with human coaches may be visible to those coaches to support your learning experience.
  • AI Conversations: Transcripts of your AI interactions are visible only to you. You can choose to save or delete these conversations at any time. You may also email a transcript to yourself or reference it when reporting a concern. Functionality to share transcripts directly with a coach is not currently available.

3. AI Ethics Policy

We are committed to the ethical and responsible use of AI in NudgeAI. Our AI is designed to enhance learning experiences, provide personalised insights, and support our users' learning journey and professional development.

Our approach follows key principles aligned with UK and EU AI regulations, including the forthcoming EU AI Act:

• Transparency – Users are clearly informed when they are interacting with AI-driven features.
• User Control – Users can view transcripts of their AI conversations and choose whether to save or delete sessions. They may also email transcripts to themselves or reference them include them when reporting a concern.
• Privacy & Security – AI conversations are stored securely and are only accessible under limited circumstances and with permission. Transcripts are visible to the user and may be accessed by a limited group of professionals at Black Isle (Europe) Group Ltd only if shared by the user for support or investigation. We do not share individual conversations with anyone else. While we do not currently analyse anonymised and aggregated conversation data, we may do so in future, and only for the purpose of evaluating AI performance, minimising bias, analysing trends and improving the learning and user experience.
• Data Usage & Session Insights – We may capture metadata such as the length and timing of AI practice sessions or interactions. This helps us better understand engagement patterns and support continuous improvement in learning outcomes.
• Human Oversight – Professional coaches may discuss AI interactions with users, but do not have automatic access to transcripts. Human oversight exists only to support the learner (not to monitor).
• Feedback & Reporting – If at any point you find that an AI interaction is unsuitable, unhelpful, or misaligned with your needs, you can report it directly within the app. This allows us to investigate and continue improving the experience.
• No Automated Decision-Making – NudgeAI does not make final decisions about users based solely on AI analysis. All AI input is designed to support — not replace — human judgement and reflection.
• No Machine Learning on User Data – We do not use AI conversation transcripts or user content for training machine learning models. OpenAI’s ChatGPT API, which powers our AI assistant, also does not use client data to train its models unless explicitly opted in — and we have not opted in.

4. How We Use Your Data

Your data is used for the following purposes:

• Providing and improving NudgeAI – To ensure smooth functionality and enhance the user experience.
• Personalised learning – To help tailor habit-tracking and learning journeys.
• Professional coaching – To support developmental conversations with your coach. While transcript sharing is not currently built into the app, users may discuss content with their coach as part of their learning experience.
• Workshop support – Learning goals may be shared with workshop leads and professional coaches to help facilitate learning sessions.
• Analytics and reporting – We use aggregated, anonymised data (where available) to understand learning patterns, measure effectiveness, and provide insights to employers and research initiatives.
• Marketing & Case Studies – Aggregated data may be used in customer case studies and marketing materials. Client logos may be included where relevant, and individual learner stories will only be shared with explicit separate permission.

5. Data Storage & Security

We take the security of your data seriously. Your information is stored securely and is protected against unauthorised access, disclosure, or loss through encryption, secure servers, and access controls.

Passwords are encrypted and never stored in plain text. We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy or as required by law. For enterprise clients, we can implement custom data retention schedules on request.

6. App Usage Policy

6.1 Acceptable Use

By using NudgeAI, you agree to:

• Use the app for its intended purpose of professional development and habit tracking.
• Not attempt to copy, modify, distribute, or reverse-engineer the software.
• Not engage in any unlawful, harmful, or abusive activities within the app.

Content entered into AI conversations is subject to automated safety filtering to prevent abuse or misuse, in line with OpenAI’s moderation tools.

6.2 User Agreement for Use of AI-Powered Features

By using NudgeAI, you acknowledge and agree that certain features of the platform are powered by artificial intelligence. These AI tools are designed to support your professional development by offering suggestions, reflections, and prompts aligned with the content of our workshops and coaching practices.

You understand that AI-generated content is not a substitute for professional advice or human judgment. While we take care to ensure the quality and ethical use of AI, you remain responsible for how you interpret and apply the outputs provided.

You also acknowledge that transcripts of your AI interactions are private by default and will only be visible to others if you choose to email, report, or share them manually.

To protect your privacy and your organisation’s confidentiality, you agree not to enter any information that is sensitive, proprietary, or considered confidential, including names of clients, colleagues, or details of internal projects. The AI is designed for learning and reflection — please keep your inputs general where possible.

If you choose to email a transcript to yourself, we recommend that you do not forward or share it externally, especially if it includes personal reflections or sensitive topics. Sharing transcripts with others outside of the app is not required or encouraged, and you do so at your own discretion and responsibility.

6.3 Intellectual Property Rights

• NudgeAI is a trademark of Black Isle (Europe) Group Ltd.
• All content, branding, and technology within NudgeAI are owned by Black Isle (Europe) Group Ltd.
• You are granted a limited, non-transferable, revocable licence to use the app for personal and professional development purposes only.
• You may not copy, reproduce, distribute, or create derivative works of NudgeAI without prior written permission.

7. Limitation of Liability

• NudgeAI is provided on an “as is” basis. While we work hard to ensure reliable access and performance, we cannot guarantee that the platform will always be free from interruptions or technical errors.
• We are not liable for any direct or indirect losses resulting from temporary access issues or technical faults beyond our control.
• Professional coaching is provided as a developmental service. Users are responsible for how they apply coaching insights, and we do not guarantee specific outcomes.
• Data shared voluntarily between users and coaches is treated with care, but we are not responsible for how individual users choose to disclose or use information within those interactions.

8. Company Details & Contact Information

9. Changes to This Policy

We may update this policy from time to time. If we make significant changes, we will notify users via the app or email. Continued use of NudgeAI after changes means acceptance of the revised terms.