Privacy Policy

Who we are

Noctua is operated by Agnieszka Ewa Piwowarska, trading as AGNÉLIS, a sole trader registered in the United Kingdom. Agnieszka Ewa Piwowarska, trading as AGNÉLIS, acts as the data controller under UK GDPR. Address: Bradford, United Kingdom. Contact: contact.agnelis@gmail.com. ICO registration reference: ZC253443. Registration valid from 20 September 2026 to 19 September 2027.

What data we collect

We collect data you voluntarily enter into the app:

• Account data: email, name, profile photo
• Journal entries: content, mood markers, emotions
• Dream entries: content, symbols, emotional tone
• Shadow work: responses, selected emotions
• Menstrual cycle data: dates, symptoms, phases
• Birth data (Premium): date, time, and place of birth. Entered voluntarily, used to personalise planetary workbooks.
• Technical data: IP addresses (anonymised), login timestamps, device identifiers for push notifications (subscription endpoints). Stored for technical purposes only.

Profile photos are not public. They are stored in private storage and shown only to the authorised person through short-lived signed URLs.

IMPORTANT: journal entries, dream entries, shadow work entries, and cycle data may contain information about mental or physical health, so we treat them cautiously as potentially special-category data under UK GDPR Article 9. We process them on the consent and other bases described in this Notice; the final legal classification requires legal confirmation.

Crisis detection

Noctua checks the text you write for words that indicate a crisis: suicidal thoughts, self-harm, violence, eating disorders and similar. This is a comparison against a word list, not artificial intelligence. No text is sent anywhere for this purpose.

In several places, when preparing your shadow work questions, a report, a Reflection, or a prompt sent in a notification, we also check your earlier entries. We check only entries from the last 30 days, never older. This is still the same comparison against a word list, carried out on our side, and no text is sent anywhere for this purpose.

When something is recognised, we show you helpline numbers. We record that it happened, when, on which screen, and whether the signal was acute or general.

If the message asks you to confirm it and you press “I understand, continue”, we also record that confirmation: that it happened, when, on which screen, in which language, and which version of the message you were shown. We keep the exact text of that message, so that it is possible to reconstruct what was actually on the screen and not merely a version number. If the message appeared alongside a saved entry, we also record a reference to it: its identifier, the screen, and the time it was created. If it appeared before you had saved anything, we record only the name of the screen.

We do not store what you wrote. Not the whole entry, not a fragment, not the word that matched. The record says that something happened. It does not say what. This applies to confirmations as well. The reference to an entry says which entry it was. It does not say what you wrote in it.

We do this so that help appears when it may be needed, and so that we do not return with the same message on every following entry. It is not used to judge you or to build a profile of you.

We do this so that it can later be shown that support was in fact presented to you, in what form and when. It is a record of what the application showed and whether it was acknowledged. It does not assess how you are, or how well you are coping.

No one reviews these records: there is no screen, panel or report in Noctua that shows their content. They are read only by counting mechanisms, with no access to the content of a record: one checks how many times this happened in the last seven days, the other counts how many records have passed 90 days and are due for deletion.

Noctua is not an emergency service and does not contact anyone on your behalf. In an urgent situation, call the numbers in the Grounding section.

Legal basis for processing

We process your data under UK GDPR based on the following legal grounds:

• Article 6(1)(b), namely performance of a contract with you (provision of Noctua services)
• Article 6(1)(f), namely legitimate interests of the controller (security, technical monitoring)
• Article 9(2)(a), namely your explicit consent for processing special category data (mental health, menstrual cycle data)

How we use your data

Your data is used solely to:

• Display your entries and track your progress
• Generate personalised reports and insights (Premium subscription)
• Generate shadow work questions based on your entries (automated process using artificial intelligence)
• Process payments (via Stripe, we do not store card details)
• Communicate with you on technical matters

We never sell your data. We never display advertisements. We never share your data with third parties for marketing purposes.

Who we share your data with (subprocessors)

To provide Noctua services, we use the following subprocessors. Their processing scope, contractual terms and transfer safeguards are recorded in our compliance documentation and reviewed periodically:

• Supabase Inc., database hosting and authentication; Noctua's primary database region is London (United Kingdom), while other services and subprocessors may be subject to separate terms
• Vercel Inc., web application hosting; infrastructure and logs may be processed in different locations according to the project configuration and provider terms
• Stripe, payment processing; data may be processed in the USA and other jurisdictions under Stripe's terms
• Anthropic PBC, AI-generated questions and analyses (Claude model); processing may take place in the USA and other jurisdictions under the provider's current terms
• Sentry (Functional Software, Inc.), application error monitoring; location and retention depend on the Sentry organisation configuration
• Resend Inc., feedback reply delivery; location and retention are governed by Resend's current terms

Anthropic's full subprocessors list is available at: trust.anthropic.com/subprocessors

Important: Noctua uses the commercial Anthropic API, not a consumer product or Workbench. Content sent to Anthropic may be processed and used under the current API terms and the agreement for this account. If those terms permit it, this may include improving or training models. We do not promise that the provider will never use this data for such purposes. Do not enter information into AI features that you do not want to send to an external provider.

Data transfer outside EU/UK

Some of our subprocessors may process data outside the United Kingdom, including in the United States. We use the transfer mechanism required for the relevant provider and data type under its current DPA and UK GDPR; verification of those mechanisms forms part of our compliance review.

The current DPA and transfer terms for each provider should be read together with its commercial terms; on request, we can provide information about the relevant provider and transfer basis for the applicable processing.

Profiling and automated decision-making

Noctua uses artificial intelligence (Claude by Anthropic) to generate personalised shadow work questions and reports based on your entries. This use may involve profiling or automated processing; its final legal classification must be assessed under the UK GDPR.

Important: AI-generated questions and analyses are reflective in nature only and do not produce legal or similarly significant effects on you. AI does not make decisions for you and does not provide a diagnosis. It does not judge you or assign you labels. Questions and readings are something to consider, not a verdict.

AI analysis is a separate consent and you can switch it off at any time in your profile, without deleting your account and without deleting your entries. Once it is off, your entries are still stored but are not sent to the model, and features that use the model stop being available. If we cannot establish whether consent is in place, nothing is sent.

There is one exception and we name it plainly: crisis detection recognises the level of a signal and records it (see the Crisis detection section). This is not done by AI but by comparison against a word list, and it exists to surface help, not to assess you.

Your rights

Under UK GDPR you have the right to:

• Access your data (Article 15)
• Rectify your data (Article 16)
• Delete your data (right to be forgotten, Article 17)
• Restrict processing (Article 18)
• Data portability in machine-readable format (Article 20)
• Object to processing (Article 21)
• Withdraw consent at any time (Article 7), without affecting the lawfulness of processing before withdrawal
• Not being subject to automated decision-making (Article 22)

To exercise these rights, email contact.agnelis@gmail.com. We will respond without undue delay and generally within one month, in accordance with the UK GDPR.

Data security

We apply appropriate technical and organisational measures to protect your data:

• Encryption in transit (TLS 1.2+) and at rest (AES-256)
• Row Level Security ensures each user sees only their own data
• Regular backups
• Error and security incident monitoring

In the event of a data breach posing a high risk to your rights and freedoms: we will notify you without undue delay and report the breach to the ICO within 72 hours as required by UK GDPR Articles 33-34.

Cookies

We use essential cookies to maintain your login session and a technical preference cookie that remembers your selected language. We do not use tracking, advertising, or analytics cookies.

Data retention

Retention depends on the type of data and is described below. Deleting your account starts the deletion of account-linked data from Noctua's active database and avatar files, but it does not automatically remove backups, logs, payment records, or data held by providers; those are governed by their current retention rules and legal obligations. Sentry and Vercel retention depends on account configuration and provider plan. We delete push-notification device identifiers from the active system when consent is withdrawn or the account is deleted, subject to provider backups.

Crisis detection records (the fact, the time, the screen, the level of the signal) are retained for 90 days from detection and then deleted. They are removed earlier together with your account.

We keep confirmations of crisis messages indefinitely, because they exist to show that help was presented. After your account is deleted the record remains but stops being linked to you: your identifier is removed and what stays is a value derived from your email address, which cannot be used to find you unless you provide that address yourself.

Children's data

Noctua is currently intended for users aged 18 and over. We do not currently allow registration by individuals under 18. If we discover that an account belongs to someone under that age, we will start removing the data from Noctua's active systems in accordance with the deletion procedure, subject to legal obligations and external-provider retention.

Changes to this privacy policy

We may update this Privacy Notice, particularly when features, subprocessors, transfers or retention rules change. We monitor such changes and update the description and date shown at the top of this page. We will notify you of material changes by email or in-app notification in the manner and within the timeframe required by applicable law.

Contact and complaints

For privacy-related questions: contact.agnelis@gmail.com. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) in the United Kingdom if you believe your data is being processed unlawfully. ICO: ico.org.uk.