Contents
Who We Are
Settle and Source™ is a daily self-led practice app owned by Angela M Carter and operated under licence by Concinnity Limited, a company registered in New Zealand.
In this Privacy Policy, references to "we", "us", and "our" refer to Angela M Carter and Concinnity Limited. References to "you" refer to any person who accesses or uses the Settle and Source™ app or website.
Angela M Carter is the data controller for the purposes of the New Zealand Privacy Act 2020, the Australian Privacy Act 1988, the UK General Data Protection Regulation (UK GDPR), and the EU General Data Protection Regulation (EU GDPR).
If you have any questions about this Privacy Policy or about how we handle your data, please contact us at support@traumareleasecentre.com.
What This Policy Covers
This Privacy Policy explains what personal data we collect when you use the Settle and Source™ app and website, how we use it, how we protect it, how long we keep it, and what rights you have in relation to it.
This policy applies to all users of the app regardless of where they are located, including users in New Zealand, Australia, the United Kingdom, the United States, and elsewhere.
Settle and Source™ is a self-led practice tool. The personal information you share within the app, including journal entries, check-ins, and Wise Self conversations, is deeply personal. We treat it with the care and respect it deserves.
What Data We Collect
Account information
- First and last name
- Email address
- Password (stored in encrypted form only, never as plain text)
- Profile photograph if you choose to upload one
- Your chosen primary context (Leadership, Parenting, or Relationships)
- Your daily check-in time preference
- Your marketing consent preference
Practice data
- Daily check-in responses including feeling states, body sensations, and context selections
- Parts and patterns selected or created within the app
- Pause records including completion timestamps and reflection responses
- Journal entries whether typed or transcribed from voice input
- Wise Self conversation history
- Reflection log entries
- Library phrases and practices saved to your personal library
- Self-led move entries
Technical data
- Device type and operating system
- App version
- Session timestamps and duration
- Feature usage patterns at an aggregate level
- Error logs for technical troubleshooting
Payment data
Payment processing is handled by our third-party payment provider. We do not store your full card details. We retain a record of your subscription status, billing dates, and transaction history.
How We Use Your Data
| Purpose | Data used | Legal basis |
|---|---|---|
| To create and manage your account | Name, email, password | Contract |
| To deliver the app and its features | All practice data | Contract |
| To personalise your experience | Context, parts, check-in history | Contract |
| To power the Wise Self feature | Journal, check-ins, patterns | Contract |
| To generate pattern insights | All practice data | Contract |
| To process payments | Email, subscription status | Contract |
| To send transactional emails | Email address | Contract |
| To send marketing emails | Email address, name | Consent (opt-in only) |
| To improve the app | Aggregate technical data only | Legitimate interest |
| To comply with legal obligations | As required by law | Legal obligation |
We will never use your personal practice data including journal entries, check-ins, patterns, or Wise Self conversations for marketing, advertising, research, or any purpose other than delivering the service to you.
Sensitive Personal Data
The nature of Settle and Source™ means that the data you share within the app may include sensitive personal information relating to your mental health, emotional state, and personal experiences.
We treat all practice data as sensitive personal data regardless of its content. We do not analyse, read, or access your journal entries, Wise Self conversations, or personal reflection content except where required to operate the service or where required by law.
Your practice data is processed only by automated systems to deliver the personalised features of the app. It is not read by human staff.
The Wise Self feature uses AI to generate responses. The AI processes your input to generate a reflective response but this processing is automated and your conversations are not reviewed by human staff.
How We Store Your Data
Your data is stored in a PostgreSQL database hosted on Replit infrastructure. Replit's servers are currently based in the United States.
- Passwords are encrypted using bcrypt hashing and are never stored as plain text
- All data is encrypted in transit using HTTPS
- Database access is restricted and protected
- Session timeouts are in place to protect your account if the app is left inactive
We regularly review our security measures and will update them as the app develops and as best practice evolves.
How Long We Keep Your Data
- Account and practice data is retained for as long as your account is active
- If you delete your account all associated data is permanently deleted from our systems immediately
- If your subscription lapses your data is retained for 90 days in case you wish to reactivate, after which it is permanently deleted
- Transactional records including payment history are retained for 7 years in accordance with financial record-keeping requirements
- Marketing consent records are retained until you withdraw consent or delete your account
You can delete your account and all associated data at any time from the settings screen within the app. Deletion is permanent and immediate. We do not retain backups of deleted accounts.
Who We Share Data With
We do not sell your personal data to any third party. We do not share your personal data with advertisers or marketing platforms.
We share limited data with the following categories of third-party service providers only where necessary to operate the service:
- Hosting and infrastructure providers (Replit) to store and serve the app
- Payment processors to handle subscription billing securely
- Email service providers to send transactional and marketing emails where consent has been given
- AI service providers to power the Wise Self feature
All third-party providers are required to handle your data securely and in accordance with applicable privacy law. We do not permit them to use your data for their own purposes.
We may disclose your data to law enforcement or regulatory authorities if required to do so by law, or to protect the rights, property, or safety of Settle and Source™, our users, or others.
International Data Transfers
Our servers are currently based in the United States. If you are located outside the United States your data will be transferred to and stored on US-based servers.
For users in the United Kingdom and European Union this transfer is subject to the requirements of UK GDPR and EU GDPR respectively. By creating an account and using Settle and Source™ you consent to this transfer.
We take reasonable steps to ensure that any international transfer of your data is subject to appropriate safeguards consistent with applicable privacy law.
Your Rights
You have the following rights in relation to your personal data. To exercise any of these rights please contact us at support@traumareleasecentre.com. We will respond within 30 days.
- The right to access a copy of the personal data we hold about you
- The right to correct any inaccurate or incomplete personal data
- The right to delete your account and all associated data at any time from the settings screen
- The right to request a portable copy of your data in a structured, machine-readable format
- The right to withdraw consent for marketing communications at any time
- The right to object to processing of your personal data in certain circumstances
- The right to restrict processing of your personal data in certain circumstances
- The right to lodge a complaint with the relevant data protection authority in your jurisdiction
Jurisdiction-Specific Rights
In addition to the general rights above, users in specific jurisdictions have additional protections under local law.
New Zealand
Your rights are protected under the Privacy Act 2020. You have the right to access and correct your personal information and to make a complaint to the Office of the Privacy Commissioner at privacy.org.nz.
Australia
Your rights are protected under the Privacy Act 1988 and the Australian Privacy Principles. You have the right to make a complaint to the Office of the Australian Information Commissioner at oaic.gov.au.
United Kingdom
Your rights are protected under UK GDPR and the Data Protection Act 2018. You have the right to make a complaint to the Information Commissioner's Office at ico.org.uk.
United States
Your rights vary by state. California residents have additional rights under the California Consumer Privacy Act (CCPA) including the right to know what data is collected and the right to opt out of sale of personal data. We do not sell personal data.
Cookies
The Settle and Source™ website may use cookies and similar technologies to operate and improve the site. A cookie is a small file stored on your device that helps us recognise you and remember your preferences.
- Essential cookies are necessary for the website and app to function and cannot be disabled
- Analytics cookies help us understand how the site is used so we can improve it. These are only placed with your consent
- We do not use advertising or tracking cookies
You can manage your cookie preferences at any time through your browser settings. Please note that disabling essential cookies may affect the functionality of the app.
For full details of the cookies we use please refer to our Cookie Policy.
Children
Settle and Source™ is intended for use by adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18.
If you believe that a person under 18 has created an account or provided us with personal data, please contact us immediately at support@traumareleasecentre.com and we will delete the data promptly.
Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes we will update the date at the top of this page and notify you by email.
Continued use of the app following notification of changes constitutes your acceptance of the updated policy. If you do not agree to the updated policy you may delete your account at any time from the settings screen.
Contact Us
If you have any questions about this Privacy Policy, want to exercise your rights, or have a concern about how we handle your data, please contact us. We take all privacy enquiries seriously and will respond within 30 days.
Privacy enquiries
Angela M Carter, Data Controller
Settle and Source™, operated by Concinnity Limited