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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 data:

  • Personal Information: Full name, email address, job title, company name, telephone number, and encrypted passwords.
  • Learning & Journal Entries: Personal journal entries for self-reflection and learning. Journal entries may be shared with one or more professional coaches only with your explicit permission.
  • Learning Goals: Your personal learning goals may be shared with workshop leads and professional coaches to support your development.
  • Habit Tracking Data: Activity patterns related to habit-building and learning progression. Individual habit data may be shared with professional coaches but will not be shared with your employer.
  • Aggregated Data: We may analyse and aggregate anonymised data to provide insights on activity trends, learning engagement, and return on investment (ROI). Aggregated data may be shared with your employer, used in research data, and incorporated into marketing and customer case studies. This data may appear under a client logo.
  • Learner Stories: With explicit and separate permission, we may seek to produce individual learner stories for marketing and promotional purposes.
  • Conversations: Interactions via Coach chat and with our AI within the app may be visible to professional coaches to assist in guiding user interactions and providing additional learning support where needed. Conversations may also be analysed in an anonymised format for research, learning, and system improvement purposes.

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

  • Transparency – Users are informed when interacting with AI-driven features.
  • User Control – Users have control over how their AI interactions are stored and used.
  • Privacy & Security – AI conversations are stored securely and only accessible in limited circumstances as outlined in this policy.
  • Human Oversight – Professional coaches may review AI conversations to support learners where needed, ensuring AI-generated insights are properly contextualised.
  • No Automated Decision-Making – NudgeAI does not make final decisions about users solely based on AI analysis.

 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 facilitate coach conversations with you.. If you grant permission, learning entries and habit data may be shared with professional coaches.
  • 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 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.
  • AI-Powered Learning – AI features in the app provide real-time feedback, insights, and suggestions for improvement based on user interactions. AI-driven conversations may be stored in anonymised form for analysis and system improvement.

 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.

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.

6.2 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, and we do not guarantee uninterrupted access or that it will always be error-free.
  • We are not liable for any loss, damage, or disruption caused by reliance on app functionality or external professional coaching advice.
  • We are not responsible for any misuse of data shared between users and professional coaches

 8. Company Details & Contact Information 

Black Isle (Europe) Group Ltd, Springfield House, Springfield Road, Horsham, West Sussex RH12 2R

Company Registration Number: 07945279

Email: contact@blackislegroup.com

 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.

Effective Date: 4th February 2025