HonestBrands privacy notice

1. Who we are

The app is run by HFBA Trading Ltd, registered in Malta (company number C 107370 (Malta Business Registry)), at Mercieca Suite 4, Triq it-Tabib Anton Tabone, Victoria, Gozo VCT 9020, Malta. We are the controller of your personal data under the EU GDPR and, for people in the UK, the UK GDPR.

• Contact: hello@honestbrands.com
• Our UK representative: Janson Smith, Office 21, Wingate Business Exchange, London SW4 0AF

The app is for adults (18 and over): HonestBrands members, their business partners and the HonestBrands team.

2. What we collect

• Account details: your name, email address and, where we have them, your phone number, time zone and Discord username.
• Your membership: your programme, coach and success manager, support start and end dates, roadmap progress and contract status.
• Your weekly check-ins: your current roadmap step, your answers about your progress, goals, anything that might get in your way and the support you need, your 1–10 rating, and whether you completed it.
• Your conversation: messages, photos, voice notes (and their automatic transcripts), documents and emoji reactions. Location details are removed from photos.
• Staff notes about you and your support, visible to staff only.
• Technical data: sign-in records (IP address, browser or app version), which version of the website you use each day, error reports from the website (the error and the page it happened on), which are stored in the logs of our website host, Vercel, and, if you allow notifications, your phone’s notification token and model, or your browser’s notification address.
• Reports and requests: messages you report and requests you make about your data.

You need to give us your name and email to use the app.

Where it comes from. Mostly from you. Some comes from HonestBrands’ own systems: your enrolment and coaching calls, your sales handover, and payments, refunds and onboarding bookings.

Please don’t send health or other sensitive details unless you need to for your coaching.

3. Why we use it

We do not use your data for advertising, analytics or online tracking, and we never sell it. We make no decisions about you by automated means alone that have legal or similarly significant effects.

4. Who can see it and who we share it with

Your conversation can be seen by you, any business partner you have given access to, and HonestBrands staff. Other members never see it.

We use trusted service providers who act only on our instructions, under a data-processing agreement:

• Hosting and storage: Neon, Vercel, Cloudflare and Railway
• Live updates, email and notifications: Ably, Resend, Expo, Apple, Google, Mozilla and Microsoft
• Virus checking: Scanii
• HonestBrands’ business systems: Google Workspace, CC360, Whop, our own member tracking system and Slack
• Our own member tracking system receives your name, email, programme, coach and success manager, membership dates, status and contract status, and updates on your activity in the app, including your weekly check-ins and your answers to them. We use it to track your progress, prioritise support and improve our coaching programmes. It does not receive your messages, other than your check-in answers.

We may also share data where the law requires it, or to establish or defend legal claims.

5. Transfers outside the UK and EU

Some providers process data in the US or elsewhere outside the UK and EU. Where they do, we protect it with the EU–US Data Privacy Framework (and its UK Extension) where the provider is certified, or with the European Commission’s Standard Contractual Clauses and the UK’s International Data Transfer Addendum. Data held in the UK is covered by the EU’s adequacy decision for the UK. You can ask us for a copy of these safeguards.

6. How long we keep it

A partner’s details are deleted 30 days after their access ends.

7. Deleting your account

You can ask us to delete your account at any time: in the app (tap the person icon, then Account settings, then Delete my account), on the website (Account settings, then Delete my account), or by emailing hello@honestbrands.com. Instructions are also at members.honestbrands.com/account-deletion. You are signed out straight away, and we delete your account and data within one month. We keep only what we must for legal or tax reasons, for the periods above.

8. Your rights

You have the right to:

• get a copy of your data
• correct it
• have it deleted
• restrict how we use it
• object to our use of it based on legitimate interests
• receive the data you gave us in a portable format

To use any of these rights, email hello@honestbrands.com. We reply within one month; for complex requests this can be extended by up to two more months, and we will tell you if so.

You can complain to Malta’s Information and Data Protection Commissioner (idpc.org.mt) or, in the UK, the Information Commissioner’s Office (ico.org.uk, 0303 123 1113). We’d appreciate the chance to resolve it first.

9. Cookies and tracking

We use only the cookies the website needs to work: one keeps you signed in, and HonestBrands staff have a second that remembers which inbox view they were on. We use no analytics, advertising or tracking, on the website or in the app. The app asks for your camera, photos or microphone only when you choose to send a photo or voice note.

10. Changes to this notice

We will update this notice when the app changes, and tell you in the app about any significant change.