last reviewed: 9th April 2025
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: We may analyse anonymised, aggregated data to understand trends in learning and engagement. 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 will never identify individual users. Privacy of individuals is prioritised.
- 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: You may interact with NudgeAI through coach chat or AI-powered features.
- 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, delete, or share these conversations with a coach if you feel it would support your development.
- We may also analyse anonymised and aggregated AI conversation data to monitor system performance, improve the quality of support, and ensure the AI meets high ethical standards. Individual conversations are never shared with external parties, including your employer.
—
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 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 also control whether any conversation is shared with a coach.
- 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 also be accessible, where to a limited group of professionals at Black Isle (Europe) Group Ltd for the sole purpose of supporting your learning journey. We do not share individual conversations with anyone else. However, we may review anonymised and aggregated conversation data to evaluate how the AI is performing, minimise bias and to improve the system 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 review AI interactions only when you have shared a transcript with them, to ensure guidance is tailored and contextually appropriate. Human oversight exists only to support the learner (not to monitor)
- Feedback & Reporting – If at any point a user finds that an AI interaction is unsuitable, unhelpful, or misaligned with their needs, they 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.
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.
—
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. 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
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. Reviewed: 9th April 2025
