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Policy

How information is handled at Badger.

Last updated: 13 July 2026

Badger is a wellbeing app operated by Bear-Up Ltd (“Badger”, “we”, “us”, “our”). This Privacy Policy explains what personal data we collect, how we use it, who we share it with, how long we keep it, and the choices and rights available to you.

1. About this policy

This Privacy Policy explains how Bear-Up Ltd, trading as Badger, collects and uses personal information when you use the Badger app, visit our website, contact us or receive access through an organisation.

Controller: Bear-Up Ltd (trading as Badger) Company number: 15888795 Registered office: Unit A452 4 - 6 Greatorex Street, London, E1 5NF, United Kingdom Contact: hello@badgerapp.io

Badger is designed for people aged 16 and over. It provides general wellbeing, personal-development and behavioural-navigation support. It is not a healthcare provider, medical device, diagnostic tool, therapy service or emergency service.

2. Privacy at a glance

  • Your journals and private wellbeing entries are not made available to an employer, university, charity or other sponsoring organisation through the organisation portal.
  • Optional sensitive AI features are controlled separately and are off unless you choose to enable them.
  • The primary Badger database is hosted in Microsoft Azure UK South.
  • We use selected service providers for hosting, AI-supported features, subscriptions, payments, communications, notifications and technical reliability.
  • You can access settings, withdraw optional permissions, delete content, request a copy of your information and request account deletion.

3. Information we collect

3.1 Account and authentication information

We may collect your email address, name or username, hashed password, authentication-provider identifiers, sign-in records, account identifiers, security records and age/self-declaration status.

3.2 Onboarding and personalisation information

We may collect answers about your goals, preferred pace, barriers, resources, routines, time availability, environment, task preferences, comfort-zone preferences and accessibility or practical constraints. We may create structured profile information from your answers to provide relevant tasks.

You can use Badger in standard-personalisation mode without enabling optional sensitive AI processing.

3.3 Wellbeing and check-in information

If you choose to use these features, we may collect mood, energy, stress or capacity bands, tags, notes and feedback about whether tasks were helpful, too easy or too difficult. Some of this information may reveal information about health or emotional wellbeing.

3.4 Journals and attachments

If you upload information about another person, you should only do so where you have a lawful reason and appropriate permission. This includes photos, audio, transcripts, screenshots and information that is personal, confidential or medical. Badger may restrict or remove content where this is necessary to protect users, comply with law or enforce the Terms of Service and Community Guidelines.

If you use journalling, we store the title, body, dates, optional mood association, privacy choices and any approved derived topics. If you upload a photograph or audio recording, we store the file and technical metadata needed to provide the feature. Images are processed to remove unnecessary embedded metadata where feasible.

3.5 AI-feature information

Depending on the feature you enable, an AI provider may receive an allowlisted, minimised set of structured context. This may include selected goal tags, barrier tags, difficulty preferences, broad capacity bands, recent task feedback, authorised journal topics, derived calendar availability or derived health/activity bands.

We do not intentionally include your email address, password, payment details or raw provider tokens in AI requests. Ordinary task generation does not receive raw journal text, journal attachments, calendar event titles or raw Fitbit records.

Audio transcription is separate: if you request transcription, the selected audio file is sent to our transcription provider and the resulting transcript is stored in your Badger account.

3.6 Connected calendar and activity services

If you connect Google Calendar, Microsoft Outlook Calendar or Fitbit, we collect the minimum account, authorisation and normalised event/activity information needed for the selected feature. Connection to a provider does not automatically permit us to use that information in AI personalisation.

3.7 Tasks, progress and gamification

We store generated and selected tasks, completion or skip events, difficulty/helpfulness feedback, progress measures, XP, berries, streaks, badges, rewards and transaction ledgers needed to operate the service and prevent abuse.

3.8 Subscriptions, billing and purchases

We may receive subscription, entitlement, product, transaction, invoice, payment-status and purchase metadata from Apple, Google, RevenueCat or Stripe. We do not receive full app-store card details.

3.9 Device, notification, diagnostic and security information

We may process device/app version, push token, notification settings, request identifiers, error class, performance information and strictly minimised security/diagnostic information. Our diagnostics are configured not to receive journal content, mood notes, AI prompts, calendar titles, health records, support-ticket text or payment secrets.

3.10 Organisation and B2B information

For organisation-sponsored access, we may process organisation membership, sponsored plan, cohort, status, invitation information, organisation administrator details and aggregate reporting data. Organisation administrators may see membership-administration information appropriate to their role.

3.11 Website and communications

We may collect contact details, business-enquiry details, communication preferences, source, timestamps, security information and the content of communications you send us.

4. Special-category and sensitive information

Information about health, emotional wellbeing or information that reveals such matters may be special-category personal data. Where we process special-category information for an optional feature, our proposed approach is to rely on your explicit consent in addition to an Article 6 lawful basis.

We provide separate controls for sensitive task personalisation, journal personalisation, transcription, calendar-based personalisation and health/activity-based personalisation. You can withdraw a permission at any time in Settings. Withdrawal stops future use for that purpose but does not affect processing that already occurred lawfully.

5. Why we use information and our lawful bases

6. AI-supported features

Journals, check-ins and support signposting are not monitored continuously and are not a route for emergency intervention. If you believe that you or another person is in immediate danger, contact emergency services or an appropriate crisis service.

Badger uses AI-supported services for selected features, including task generation and user-requested transcription. We use allowlisted structured information and apply minimisation and pseudonymisation before external AI processing.

Optional sensitive AI processing is not enabled solely because you accept these terms or create an account. Where a separate permission is required, the feature remains unavailable until you enable it.

AI-generated content may be incomplete, inaccurate or unsuitable. You may skip or adjust a task and provide feedback. Badger does not use AI to diagnose, prescribe, provide emergency support or make legal or similarly significant decisions about you.

7. Organisation-sponsored access and employer/university boundaries

Organisations must not pressure members to disclose private Badger content, screenshots, journals, AI outputs, check-ins, tasks, goals or support signposting. Organisation reports are indicative service-use information only and must not be used as the sole or determinative basis for employment, academic, disciplinary, admissions, clinical, safeguarding or similar decisions about an individual.

A sponsoring organisation may manage whether you are eligible for sponsored access and may see your membership status, assigned cohort and sponsored plan.

For organisation-sponsored access, Badger acts as an independent controller for member app data, including private content, app personalisation, privacy choices, service security, direct subscriptions, product operation and aggregated reporting controls. The sponsoring organisation is responsible for the membership, eligibility and administrator information it provides or controls.

It may receive aggregate, threshold-protected information about use of Badger. Organisations do not receive through the organisation portal:

  • private journal text, titles, photos, audio or transcripts;
  • raw mood, stress, energy or check-in responses;
  • personal goals, barriers or private onboarding answers;
  • AI memory or personalisation profile;
  • specific task text or individual task-completion history;
  • named crisis or risk information.

Badger suppresses wellbeing and behavioural reporting for groups below its minimum threshold and applies additional cell suppression. Organisations must not attempt to identify individuals from reports.

8. Who we share information with

We use selected providers for hosting, object storage, AI-supported features, subscriptions, payments, authentication, connected services, transactional email, push notifications and technical reliability. Our current key providers are listed in our Public Provider List.

We may also disclose information where required by law, to protect rights and security, or as part of a corporate transaction subject to appropriate safeguards. We do not sell personal information.

9. International transfers

Our primary PostgreSQL database is hosted in Microsoft Azure UK South. Some providers may process information outside the UK. Where required, we use an applicable transfer mechanism, such as UK adequacy regulations, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with supplementary safeguards where appropriate.

10. Security

We use proportionate technical and organisational measures, including encrypted transport, hashed passwords, protected credentials, least-privilege access, multi-factor authentication for privileged internal and vendor systems where supported, role-based controls, private storage containers, logging minimisation, monitoring, tested deletion processes and incident procedures.

No system can guarantee absolute security. Please contact us promptly if you believe your account or information has been compromised.

11. Retention

We retain information only for defined purposes and periods. Examples include:

  • journals and user-created content: until you delete them or close your account;
  • pending registrations: normally deleted within 24 hours if not completed;
  • generated data-export archives: normally deleted within 7 days;
  • generated B2B report files: normally deleted within 30 days;
  • normalised calendar working data: normally up to 30 days;
  • derived calendar features: normally up to 90 days;
  • raw Fitbit daily data: normally up to 30 days;
  • derived activity/sleep trends: normally up to 12 months while connected;
  • support tickets: normally 24 months after closure;
  • security logs: normally 12 months unless needed for an incident;
  • contracts, invoices and required accounting records: normally up to 6 years;
  • privacy-request and complaint records: normally 3 years after closure, unless a longer period is justified.

Other app information is retained while your account is active and while needed for the relevant feature. The detailed internal Retention Schedule governs deletion jobs and exceptions.

12. Deletion and backups

When you delete your account, we disable access and remove or anonymise personal information from active application systems, subject to limited legal, financial, fraud-prevention, security and dispute-resolution exceptions. We initiate applicable deletion or anonymisation steps with relevant providers and track failures or retries.

Residual copies may remain temporarily in protected backups until the configured backup cycle expires. Backups are not used for ordinary product activity. If a backup is restored, deletion reconciliation is applied before ordinary use.

13. Your rights

Depending on the circumstances, you may have rights to access, correction, deletion, restriction, objection, withdrawal of consent and portability. You can make a request by emailing hello@badgerapp.io.

The in-app export provides a convenient copy of key information. A formal data-protection request may cover additional systems and records. We may verify identity and may withhold information where a lawful exemption applies, for example where disclosure would adversely affect another person’s rights.

14. Data protection complaints

You can make a data-protection complaint directly to us at hello@badgerapp.io. We acknowledge receipt within 30 days, investigate without undue delay, keep you informed and explain the outcome. You also have the right to complain to the Information Commissioner’s Office.

15. Children

Badger is intended for people aged 16 and over. Age is currently based on self-declaration. If we reasonably believe an account is being used by someone under 16, we may suspend access, investigate and delete information where appropriate.

16. Changes

We may update this policy when the service, law or our providers change. Where a change is material, we will provide reasonable notice through the app, website or email. We will request a new choice where required.

17. Contact

Bear-Up Ltd, trading as Badger Company number: 15888795 Registered office: Unit A452 4 - 6 Greatorex Street, London, E1 5NF, United Kingdom Email: hello@badgerapp.io