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Privacy Policy

Last updated March 2026

Who we are

Formulate is operated by Formulate Tools Ltd, a company registered in England & Wales (Company No. 17065550), registered address 11 Chantry Close, TW16 7TH.

Formulate is a platform of interactive clinical psychology tools and worksheets for use by qualified healthcare professionals. For data protection queries, contact privacy@formulatetools.co.uk.

What data we collect

Therapist account data

Email address, full name, organisation name (optional), subscription status, and usage data (which worksheets accessed, when, and frequency).

Client label data

Pseudonymised client labels (initials or case codes) assigned by the therapist. The platform enforces pseudonymity through validation. Formulate cannot identify clients from their labels.

Worksheet response data

Clinical content entered by clients via homework links. This data is pseudonymous. Only the assigning therapist can view response data. Formulate does not access, review, analyse, or use response data for any purpose other than storage and display to the therapist.

Technical data

IP addresses (for security), device and browser information (for compatibility), and strictly functional cookies (authentication session only). No analytics cookies, no advertising cookies, no third-party tracking.

Legal basis for processing

Data typeLegal basis
Therapist account dataContract (Art. 6(1)(b))
Subscription/payment dataContract (Art. 6(1)(b))
Usage analyticsLegitimate interests (Art. 6(1)(f))
Client labelsLegitimate interests (Art. 6(1)(f))
Worksheet responsesLegitimate interests as processor (Art. 6(1)(f))
Audit logsLegal obligation (Art. 6(1)(c)) + Legitimate interests

Special category data

Worksheet response data may constitute health data under Article 9. Our legal basis is Article 9(2)(h) — processing necessary for health care provision under a health professional's responsibility.

Data sharing

We share data with Stripe (payment processing), Supabase (database hosting), and Vercel (application hosting). We do NOT sell data, share clinical data with third parties, use clinical data for advertising, or train AI models on worksheet responses.

Data retention

Active account data is retained while the account is active plus 90 days after deletion request. Worksheet responses are retained while the therapeutic relationship is active. Therapists can permanently delete client data at any time via the GDPR erasure function. Audit logs are retained for 7 years.

Your rights

Under UK GDPR, you have the right to access, rectify, erase, restrict processing of, and port your data, and to object to processing. Contact privacy@formulatetools.co.uk. We will respond within 30 days.

Client rights

Clients who complete homework worksheets can exercise their rights by contacting their therapist. The therapist can delete all data associated with a client using the platform's GDPR erasure function.

Cookies

Formulate uses only strictly necessary cookies for authentication session management. No cookie consent banner is required under UK PECR for strictly necessary cookies.