Last updated: [date of rebrand, 6 February 2026]
1. Introduction
1.1 This Privacy Notice applies to you as a user of the SpaceCare platform (the “Platform”), or as a prospective user who may be a client or a practitioner (“you” and “your”). SpaceCare is a trading name of EmotiPal Ltd.
We have developed this Privacy Notice to explain how we collect, use, store, and protect your personal information, the legal bases on which we rely, and the rights and choices available to you under applicable data protection laws. Please read it carefully.
SpaceCare is a trading name of EmotiPal Ltd. EmotiPal Ltd remains the legal entity and data controller responsible for the processing of personal data described in this Privacy Notice. References to the “Platform” refer to the SpaceCare platform, which was previously known as EmotiPal.
1.1.1 The “Platform” refers to the web-based and cross-platform software operated by EmotiPal Ltd under the trading name SpaceCare, including any web, mobile, or other digital applications, as they may be updated or rebranded from time to time.
1.2 Throughout this document, “Data Protection Legislation” means the Data Protection Act 2018 (DPA 2018), the United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003, and any related or replacement legislation.
Where personal data is processed by a controller or processor established in the European Union, or relates to individuals in the European Union, this also includes the EU General Data Protection Regulation (EU GDPR).
1.3 EmotiPal Ltd is the data controller for the personal information we process in connection with the SpaceCare platform, unless otherwise stated. EmotiPal Ltd is registered with the Information Commissioner’s Office (ICO) under registration number ZB880085.
1.4 By using our services, you acknowledge that you have read and understood this Privacy Notice.
2.1 We are EmotiPal Ltd (trading as SpaceCare). We provide software that enables professionals to create, share, and manage interactive content for health, care, wellbeing, educational, and informational use.
EmotiPal Ltd is a company registered in England and Wales (Company No. 16171148) with its registered office at:
Flat 5, 40 Harcourt Terrace, London, SW10 9JR, United Kingdom.
2.2 If you have any questions about this Privacy Notice or how we process your personal data, you can contact us at:
Email: data.privacy@space.care
Alternative email: data.privacy@emotipal.com
Postal address: Flat 5, 40 Harcourt Terrace, London, SW10 9JR, United Kingdom
3.1 It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes or if you believe any information we hold is inaccurate or incomplete.
4.1 Depending on how you interact with the Platform, we may collect and process the following categories of personal data:
| Data Category | Description |
|---|---|
| Identity Information | Full name, home address, date of birth, title |
| Contact Information | Email address, phone number |
| Communication Records | Details from any correspondence or interactions, including discussions with practitioners or clients, technical support inquiries, customer care requests, and any other information you provide |
| Platform Usage Data | Information on how you navigate and interact with the Platform (e.g., frequency of platform access, features used) |
| Health Records | Data you provide manually or automatically through the Platform, or information shared by your practitioner. This may include health history, prescription details, mood tracking, therapy progress responses, clinical questionnaire scores, and other relevant health insights |
| Practitioner Data | If you are a practitioner, this includes your identity, contact details, workplace, therapy specialization, and a securely stored (hashed) practitioner account password |
| Technical Information | Includes device type, unique device identifiers (e.g., IMEI, IDFA, IP, or MAC address), network data, operating system, browser, location, time zone, and other related details |
| User-Generated Image Data | Images or videos submitted via technical support channels while using the Platform, retained for troubleshooting and resolving customer issues |
| Marketing & Communication Preferences | Includes your marketing and communication preferences, as well as any feedback or reviews you provide |
4.2 You are not under any statutory or contractual obligation to provide personal data to us. We only collect and process personal data that is adequate, relevant, and limited to what is necessary for the purposes described in this Privacy Notice.
4.3 We do not knowingly process personal data relating to children under the age of 18. If you become aware that a child may have accessed the Platform and provided personal data without appropriate consent, please contact us immediately at data.privacy@space.care.
perform a contract with you;
comply with our legal obligations; or pursue our legitimate interests, provided those interests are not overridden by your rights and freedoms.
5.2 Where required, we process personal data based on your consent. You may withdraw your consent at any time.
5.3 Special category personal data, including health-related data, is processed only where you have provided explicit consent or where processing is permitted by law for reasons of public interest or legal claims. You are not required to provide such data, but doing so may affect the availability or functionality of certain services.
5.4 We may use anonymised or aggregated data for internal research, analytics, and product improvement. Such data does not identify you, and we retain any intellectual property arising from its use.
5.5 Where we need to use your personal data for a new purpose that is not compatible with the original purpose, we will inform you and, where required, obtain your consent.
6.1 We process personal data for the purposes and legal bases set out below:
| Purpose | Data Categories Used | Legal Basis |
|---|---|---|
| Product and services provisioning – Allow your practitioner to invite you to the Platform – Offer our Platform to you – Allow practitioners nominated by you to process your data – Apply proprietary technology to your Health Data | – Personal Identification Data – Contact Details – Communication Data – Platform Usage Data – Health Records – Practitioner Data – Technical Data – Support & Media Data | Explicit consent (for Health Data) Contractual Necessity Legal obligation Legitimate Interests to fulfil our obligations to you |
| IT operations and platform maintenance – To manage and secure the Platform, covering troubleshooting, incident management, testing, code maintenance, data analysis, reporting, customer care, and data hosting | – Personal Identification Data – Contact Details – Communication Data – Platform Usage Data – Health Records – Practitioner Data – Technical Data – Support & Media Files | Explicit consent (for Health Data) Contractual Necessity Legal obligation Legitimate Interests to fulfil our obligations to you |
| Research and development – Use anonymised data to improve our services to you and improve general quality of care, sharing data with other health services (e.g. NHS) or academic institutions | – Communication Data – Platform Usage Data – Health Records – Practitioner Data – Technical Data | Public Health Legitimate Interests to improve our offering |
| Marketing and Advertising – Promote our value proposition – Ask to rate us, leave us a review or take part in a survey – Use analytics to improve our Platform experience | – Personal Identification Data – Contact Details – Platform Usage Data – Marketing & Communication Preferences | Explicit content (opt-in) Legitimate Interests to promote our offering |
| Business Management – To manage our business activities, including maintaining financial and accounting records, performing audits and testing, and ensuring compliance with reporting and corporate governance obligations. – To inform you about any changes to our terms or this privacy notice | – Personal Identification Data – Contact Details – Communication Data – Platform Usage Data – Technical Data | Legal obligation Legitimate Interests to exercise our right, operate our business, and fulfil our obligations to you |
7.1 We may share your personal data with third parties in the following circumstances:
7.1.1 where disclosure is required by law or by a public authority;
7.1.2 where disclosure is necessary to establish, exercise, or defend our legal rights, including for fraud prevention;
7.1.3 where we engage third-party service providers to support the operation of the Platform. Such providers act as data processors under our instructions and are subject to contractual obligations to protect your data;
7.1.4 where we have obtained your consent.
7.2 In the event of a business sale, merger, or restructuring, personal data may be transferred to a third party, provided it is used only for the purposes for which it was originally collected and in accordance with this Privacy Notice.
8.1 Your personal data may be transferred to, and processed in, countries outside the UK or the EEA. We only do so where:
– the destination country has been deemed adequate by the UK or EU authorities; or
– appropriate safeguards (such as standard contractual clauses) are in place; or
– the transfer is otherwise permitted by law.
8.2 We take steps to ensure that your personal data receives a level of protection equivalent to that provided under UK and EU data protection laws.
9.1 We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, accounting, or reporting requirements.
9.2 We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse.
9.3 If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by law.
10.1 The Platform may allow you to interact with third-party social networks (such as sharing or reviewing content). Any information you share through those services will be subject to the privacy policies of the relevant third parties. You are responsible for managing your privacy settings on those platforms.
11.1 Subject to applicable law, you may have the right to:
– access your personal data;
– request correction or erasure;
– restrict or object to processing;
– request data portability; and
– withdraw consent at any time.
| Right to be Informed about Our Collection and Use of Personal Data | You have the right to be informed about the collection and use of your personal data. We ensure this by providing you with this Privacy Notice, which is regularly reviewed and updated to reflect our data processing activities. |
| Right to Access Your Personal Information | You have the right to request access to the personal information we hold about you, often called a ‘Data Subject Access Request.’ We will provide it free of charge and respond within one calendar month. Proof of identity may be required. |
| Right to Rectification of Your Personal Information | You can ask us to correct any inaccurate, incomplete, or outdated personal information we hold about you. |
| Right to Stop or Limit Our Processing of Your Data | You can object to the processing of your personal data, request its deletion if it’s held for too long, or request restrictions on how it’s processed in specific circumstances. |
| Right to Erasure | You have the right to request the erasure of your personal data, known as the ‘right to be forgotten,’ which applies only in certain situations. |
| Right to Data Portability | You have the right to receive your personal data in a structured, machine-readable format and request that it be transmitted to another data controller. |
| For More Information about Your Privacy Rights | The Information Commissioner’s Office (ICO) regulates data protection in the UK. You can visit their website for more information or to make a complaint about how we use your data. We hope you’ll raise any concerns with us first. |
11.2 We will respond to valid requests without undue delay and in any event within the time limits required by law.
12.1 To exercise your rights or raise any questions or concerns about this Privacy Notice, please contact us at:
Email: data.privacy@space.care
Postal address: Flat 5, 40 Harcourt Terrace, London, SW10 9JR, United Kingdom
12.2 You also have the right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO), at www.ico.org.uk. Thank you for taking the time to read this Privacy Notice.
EmotiPal Ltd
(trading as SpaceCare)