Privacy, dignity and choice
Privacy Policy
We want people to understand what happens to their information when they use Comfort Companions, complete our matching quiz, contact us or support our work. This policy explains our approach in plain English.
Last updated: 2 November 2026
Who this notice covers
About Comfort Companions and this policy
Comfort Companions CIC is a UK Community Interest Company. We are responsible for the personal information we handle when we provide and administer our service. In data protection terms, we are generally the data controller for that processing.
This notice covers our mobile companion apps, supported setup and follow-up, our matching quiz, our public website and forms, updates subscriptions, partnership enquiries and supporter contributions. It also applies to relevant service communications.
Community organisations, care providers and other partners may hold their own records and have their own responsibilities. Their separate privacy notices explain how they handle information in their own services.
Information we handle
Different activities need different information
We aim to collect only what is reasonably needed for the relevant service, enquiry or supported access arrangement.
Supported access and setup
We may hold a name, contact or support-contact details, broad location, companion assignment, access credentials, device or connection information, setup status and support records. Some information may be provided by an authorised partner or trusted supporter helping with setup.
Companion conversations
The app processes short periods of speech and related text to produce a reply. We also process information needed to deliver the spoken response and maintain the service. See the next section for the important distinction between conversation history and technical records.
Companion matching quiz
We receive quiz answers and preferences, the resulting suggested companion or companions, and contact or setup details provided with the quiz, such as name, email address, telephone number and device type.
Website enquiries and updates
Forms and emails may provide a name, organisation, contact details, message and mailing-list preferences. We may also hold the record of a request, our reply and relevant subscription choices.
Supporter contributions
Our payment provider handles payment details. We may receive the contributor's contact information, payment reference, contribution amount and status, and records needed to administer contributions and accounts.
Technical and service records
We may process access activity, device identifiers, broad service usage, errors, security events and limited diagnostic information to help the service operate and to resolve issues. These records may relate to an account or supported access route.
For app usage reporting, we may record when a voice exchange succeeds, which companion was used and a protected user reference derived from the app passcode using a secret key. The passcode itself is not stored in these usage records. This helps us count exchanges and estimate periods of conversation activity, rather than measure exact conversation length. These records do not contain speech, companion replies or audio.
We do not ask visitors to include older people's medical records, detailed health information or other sensitive personal details in general website enquiry forms. Optional profile details and updates subscriptions are voluntary. Some basic information is needed to provide a requested quiz result, respond to an enquiry or arrange supported app access; without it, we may not be able to provide that part of the service.
Using the companion app
What happens when you speak to a companion?
When you start a conversation, the app captures your speech so it can be converted into text and used by an AI system to produce a conversational reply. The reply is then turned into audio and played through the app.
The app is designed for deliberate, tap-to-talk use. It is not intended to listen continuously in the background.
Conversation history is not a permanent personal diary
Recent messages may be used during an active conversation so the companion can follow what you are saying. We do not intentionally build a permanent personal conversation history for someone to browse or use in later chats.
This does not mean that no conversation-related information is processed or ever held. Generated speech audio is stored temporarily to deliver replies, and limited recognised speech or reply text may appear in operational records used for technical support and troubleshooting. Such records are not intended as a service for reviewing people's private discussions.
We do not offer care providers, community partners or families a facility to listen live to conversations or replay what a person has said to their companion.
Personal details you choose to provide
With the person's agreement during supported setup, we may keep a small amount of useful background information, such as a preferred name, interests or a broadly described local area. The purpose is to make conversations feel more natural. This is separate from saving conversations or automatically learning personal facts from previous chats.
Personalisation is optional. A person may also choose a short safety-relevant preference or limitation, such as not cooking alone or avoiding certain foods, to help reduce unsuitable suggestions. Some details may reveal health or disability information. We only store and use these details once the appropriate lawful basis, any special-category data condition, the person's informed consent and suitable privacy and security safeguards have been confirmed.
We do not use a companion profile as a care record or routinely add diagnoses, medication, care plans or safeguarding details. People can ask us or their support contact to review, correct or remove optional profile details or withdraw consent to their use. Personalisation cannot guarantee safe suggestions, so appropriate human support remains important.
A simple point about privacy
A digital companion is software, not a confidential human adviser. Someone should avoid sharing passwords, bank details or information that they would not want processed by a digital service. The app is not a monitoring or emergency response service.
Why we use information
Our purposes and lawful bases
UK data protection law requires a lawful basis for using personal information. The relevant basis depends on the purpose and the supported access arrangement.
| Purpose | Lawful basis |
|---|---|
| Providing requested companion access, conversations, matching, setup and user support. | Our legitimate interests in delivering a supported service requested by the person, or performance of a contract where applicable. |
| Optional companion profile facts chosen by the person, including approved safety-relevant preferences or limitations. | Consent under Article 6(1)(a) of UK GDPR. Where a fact reveals health or other special-category information, we also rely on explicit consent under Article 9(2)(a), with appropriate safeguards. |
| Responding to website, community-partnership and care-provider enquiries. | Our legitimate interests in responding to genuine enquiries and managing relationships. |
| Sending optional email updates and managing subscriptions. | Consent, which can be withdrawn. |
| Taking contributions and maintaining necessary payment and accounting records. | Performance of relevant arrangements and compliance with legal obligations. |
| Keeping the service reliable and secure, resolving problems and assessing app usage, including successful voice exchanges and estimated conversation activity. | Our legitimate interests in operating, supporting and protecting the service. |
| Handling data requests, complaints or disclosures required by law. | Compliance with legal obligations, where applicable. |
When we rely on legitimate interests, those interests include delivering the service safely, supporting people who use it, communicating with partners and protecting our systems. We must balance those interests against people's rights and expectations.
Consent for optional profile facts is a separate choice from using the companionship service and can be withdrawn. If a safety-relevant fact cannot be used, we may need to review with the person and their support contact whether the service remains suitable for them.
People may choose to discuss health, beliefs or other sensitive matters during a conversation. We do not ask for such information in general website enquiries. Processing information shared during conversations is separate from consent for optional profile facts. Where information has special protection under UK data protection law, additional conditions and safeguards apply.
The matching quiz uses preferences and answers to suggest a conversation style. This recommendation does not automatically grant app access or make a decision with legal or similarly significant effects. Supported setup remains a separate step.
Who may receive information
Service providers, partners and international processing
We use selected technology suppliers to deliver the service. These include Microsoft technology services for AI, speech and cloud processing, website and email service suppliers, and Stripe for supporter payments. These organisations may process information needed to provide the relevant function.
We may share appropriate setup, contact, access or general service information with a care provider, community organisation or trusted supporter helping to arrange and support access. That does not mean they receive a transcript of what someone says to their companion.
We may also disclose information to professional advisers, regulators or authorities where there is an appropriate lawful reason to do so.
We do not sell personal information or use private conversations to build advertising profiles.
Processing outside the UK
Some suppliers may process or access personal information from outside the UK, even where other parts of the service operate from UK-based infrastructure. International processing is subject to applicable data protection requirements, including safeguards for restricted transfers where required. You can contact us for more information about relevant transfer arrangements.
How long and how safely
Retention and security
We aim to keep information only for as long as it is needed for the purpose for which it was collected, taking account of legal obligations, support needs and reasonable security or recovery requirements.
- Conversation context: used during active conversations, rather than maintained as a permanent personal chat history.
- Generated voice replies: temporarily stored to support playback and service operation, with routine deletion processes and limited recovery periods.
- Technical records: kept according to operational support, security and troubleshooting needs; some records can include conversation-related text.
- App usage events: content-free records of successful voice exchanges, including protected user references, companion identifiers and timestamps, with routine scheduled deletion processes.
- Access and approved profile information: retained while needed for supported access and appropriate follow-up, then reviewed for removal.
- Quiz, enquiry and support records: kept as needed to respond, arrange support and manage relevant service or organisational records.
- Updates subscriptions: held while someone remains subscribed, subject to records needed to respect an opt-out.
- Payment and accounting records: kept as required by applicable financial and legal record-keeping obligations.
We use organisational and technical safeguards to protect information, including access controls, secure communications and restricted administrative access. No digital system can eliminate every risk, and we review arrangements as the service develops.
If something needs changing
If a person would like us to correct or delete personal information, including optional companion profile details, they can contact us. Some information may need to be retained for legal or legitimate operational reasons, which we will explain where relevant.
Our website and other services
Website forms, cookies and external links
Our website uses standard technologies needed to display pages, operate forms and protect the site. Cookies or similar technologies may be involved. Other features, including embedded video, may involve services run by third parties that have their own privacy and cookie practices.
You can manage or delete cookies through your browser settings. Where consent is required for non-essential cookies or similar technologies, that choice must be provided before they are used.
If you complete a care-provider or community-partnership enquiry, we use the details you supply to respond and manage the enquiry. Please do not include sensitive information about an older person in a general enquiry.
If you subscribe to updates, we use the information submitted for the updates service in line with your choices. Completing the companion-matching quiz does not automatically subscribe someone to marketing emails.
Supporter contributions are completed through an external payment provider. Its payment screens and privacy terms apply to the payment details it processes. Following links to external sites, videos or news articles also means the destination's own privacy practices apply.
Your choices
Your information rights
Depending on the circumstances, UK data protection law gives you rights to ask us for access to personal information, correction, deletion, restriction of use, or a copy in a portable format. You can also withdraw consent where consent is the lawful basis.
You can ask for optional profile details to be checked, changed or removed. You can unsubscribe from updates using the link in an email or by contacting us.
To make a request, email privacy@comfortcompanions.co.uk. We may need to confirm your identity before acting on a request. We normally respond within one month, subject to any extensions permitted by law.
We do not make solely automated decisions about people that have legal or similarly significant effects through the companion-matching quiz. A recommendation does not grant access to Comfort Companions by itself.
Questions, concerns or complaints
Contact us about privacy
If you have a privacy question, want to exercise a data protection right or believe we have handled your information incorrectly, please contact us directly. We will acknowledge data protection complaints within 30 days and investigate and respond appropriately.
Comfort Companions CIC
Email: privacy@comfortcompanions.co.uk
Telephone: 01275 261 061
Postal correspondence:
56 Heron Gardens
Portishead, Bristol
BS20 7DH
United Kingdom
Independent complaints
If you are unhappy with our response, you can raise a concern with the Information Commissioner's Office, the UK's data protection regulator.
Changes to this policy
We review this policy as our service changes. When we make a material update, we will publish the revised wording here with a new date.