Privacy Policy

Jeff Says — operated by HappihubUK Limited
Last updated: 18 May 2026

HappihubUK Limited (company number: 14666346) ("we", "us", "our"), a company registered in England and Wales, operates the Jeff Says application (the "App"), available on iOS, Android, and the web. This Privacy Policy explains how we collect, use, store, and protect your information when you use the App.

We are committed to protecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. HappihubUK Limited is the data controller for the personal data processed through the App.

1. Information We Collect

Account information: When you register, we collect your name, email address, and password. Your employer or subscription provider may supply your email address on your behalf.

Profile preferences: You may optionally set preferences such as display name, avatar, voice gender, and voice language for the text-to-speech feature.

Conversation data: Messages you exchange with the AI assistant are stored on our servers to provide the service, maintain conversation history, and improve the experience.

Device information: We collect device type, operating system version, app version, and push notification tokens to deliver notifications and maintain service quality.

Usage data: We record login activity, session duration, and feature usage to understand how the App is used and to improve it.

2. Microphone & Speech Recognition

The App offers an optional voice input feature that uses your device's microphone and speech recognition capabilities. When you activate voice input:

Audio is processed on your device using the operating system's built-in speech recognition (Apple Speech on iOS, Google Speech on Android, Web Speech API in browsers).
We do not record, store, or transmit raw audio to our servers.
Only the resulting text transcription is sent to our servers as a chat message, the same as if you had typed it.
Microphone access requires your explicit permission and can be revoked at any time in your device settings.

3. Push Notifications

With your permission, we send push notifications for new messages and important updates. You can disable notifications at any time in your device settings or within the App.

4. Analytics & Usage Tracking

To understand how the App is used and to improve it, we use the following analytics services:

Google Analytics 4 (GA4) on the web app at jeffsays.com. GA4 collects information about your visit including the pages you view, the time you spend on each page, your approximate location (city/country level, derived from a truncated IP address), device type, browser, operating system, and referral source.
Firebase Analytics (provided by Google) on our iOS and Android mobile apps. Firebase Analytics collects information including which screens you visit, session duration, device model, operating system version, app version, country, and crash diagnostics.

Where you are logged in, both services receive your Jeff Says user ID (a random UUID) so that we can understand cross-device and web-vs-mobile usage of the same account. The user ID is not your name, email address, or any directly identifying information; it is a random identifier generated by us.

We do not send the content of your conversations, your messages to Jeff, the AI's responses, your habit data, or any Good To Go (G2G) responses to Google Analytics or Firebase Analytics. Only usage telemetry (which screen, when, how long) is collected.

Google processes this data on our behalf under its standard terms. GA4 anonymises IP addresses by default. Data is retained for 14 months by default in GA4, and according to Firebase Analytics's standard retention period for Firebase. You can read Google's privacy practices at policies.google.com/privacy.

Our legal basis for analytics processing is your consent (UK GDPR Article 6(1)(a)), captured when you accept this Privacy Policy. You can withdraw consent at any time by ceasing to use the App and requesting deletion of your account; see Section 10 (Your Rights).

5. How We Use Your Information

To provide and maintain the Jeff Says service
To deliver AI-powered conversational support
To send push notifications and email communications you have opted into
To improve the App's features and user experience
To provide aggregated, anonymised analytics to subscription providers (only with your consent via the data sharing preference)

6. Data Sharing

We do not sell your personal data. We may share information in the following limited circumstances:

AI processing: Conversation messages are sent to OpenAI's API to generate responses. OpenAI acts as a data processor on our behalf and their data usage policies apply to this processing.
Subscription providers: If you have opted in to data sharing, we may share anonymised and aggregated usage insights with your subscription provider (e.g. your employer).
Service providers: We use Google Cloud Platform to host the App and store data securely. Google acts as a data processor on our behalf.
Push notifications: Device tokens are shared with Firebase Cloud Messaging (Google) to deliver push notifications.
Legal requirements: We may disclose information if required by law or to protect our rights.

7. Aggregated and Anonymised Data

We may create aggregated, anonymised, and statistical datasets derived from usage of the App. This data is processed in such a way that no individual user can be identified or traced from it, either directly or in combination with other data.

In accordance with Recital 26 of the UK GDPR, truly anonymised data falls outside the scope of data protection legislation. Aggregated and anonymised data therefore:

Becomes the intellectual property of HappihubUK Limited;
May be used by HappihubUK Limited for research, product improvement, business analytics, and reporting purposes without restriction;
Cannot be subject to individual data deletion or access requests, as it is not practicable to identify or extract personal data from aggregated datasets once anonymisation has taken place;
May be shared with subscription providers and business partners in aggregated form.

For the avoidance of doubt, we will always ensure that the anonymisation process is robust and irreversible before treating any data as falling outside the scope of UK GDPR.

8. Data Storage & Security

Your data is stored on secure servers hosted on Google Cloud Platform. We use encryption in transit (TLS/HTTPS) and at rest, and follow industry-standard security practices to protect your information.

9. Data Retention

We retain your account and conversation data for as long as your account is active. If your account is deactivated or you request deletion, we will erase your personal data within 30 days, as required by UK GDPR. In exceptional circumstances, this may be extended to a maximum of 90 days, in which case we will inform you of the reason for the delay.

We may retain certain data for longer periods where required by law, regulation, or legitimate legal obligation (for example, tax or accounting requirements).

10. Your Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:

Right of access — to obtain a copy of the personal data we hold about you
Right to rectification — to request correction of inaccurate or incomplete data
Right to erasure — to request deletion of your personal data ("right to be forgotten")
Right to restrict processing — to request that we limit how we use your data
Right to data portability — to receive your data in a structured, machine-readable format
Right to object — to object to processing based on legitimate interests
Right to withdraw consent — where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, please contact us at support@happihubuk.com or submit a request through our Data Deletion Request page.

We will respond to all legitimate requests within one month. If your request is particularly complex, we may extend this by a further two months, but we will inform you of this within the initial one-month period.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO).

11. Legal Basis for Processing

We process your personal data on the following legal bases under UK GDPR:

Contract (Article 6(1)(b)) — processing necessary to provide the Jeff Says service to you
Consent (Article 6(1)(a)) — where you have opted in to data sharing with subscription providers, push notifications, or email communications
Legitimate interests (Article 6(1)(f)) — to improve the App, maintain security, and create anonymised aggregated datasets for business purposes

12. Children's Privacy

The App is not intended for use by anyone under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 16, we will take steps to delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy within the App or by email. The "Last updated" date at the top of this page indicates when the policy was most recently revised.

14. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to submit a data deletion request, please contact us at:

HappihubUK Limited (company number: 14666346)
Email: support@happihubuk.com
Website: happihubuk.com
Data Deletion Requests: jeffsays.com/data-deletion.html