Privacy Policy

At Emotional Pulse, your privacy is central to everything we do. This policy outlines how we collect, use, store, and protect your information when you use our Emotional Pulse App and services. By using our app, you agree to the terms of this Privacy Policy.

1. Who we are

Emotional Pulse is a wellbeing technology solution developed by ShareTree Inc., an Australian-registered charity. Our mission is to empower individuals and workplaces to improve mental health, resilience, and relationships through confidential emotional insights and support tools.

2. What information we collect

We may collect the following types of information:

Personal information

• Full name: We ask for your name to personalise your emotional experience and enhance engagement. Using your name in prompts and feedback messages makes interactions feel more personal and supportive. It also simplifies connecting and sharing your wellbeing check-ins with your trusted Pairs.
• Email address: Your email is essential for creating a secure, unique account. We use it to verify your identity, manage login flows, and handle payments safely. No other personal identifiers, such as your email or user ID, are shared with third-party tools.
• Time zone: We collect your timezone to accurately deliver notifications, reminders, and support prompts at the right time for you, based on your location. This ensures check-ins and insights are contextually relevant and aligned with your daily rhythm.

Emotional and usage data

• Emotional state check-ins
• Check-in frequency and history
• AI-generated daily emotional insights
• Conversations with AI Mental Health First Responder
• Support requests made or received
• Connection and interaction data with your trusted Pairs

We never use your emotional, check-in or account data for advertising or profiling, and we never sell it. Separately, the public emotionalpulse.ai website uses analytics and advertising-measurement cookies to understand how the site is found and used. Those are explained, and can be switched off, as described in our Cookie Policy.

3. How we use your information

We collect this information to:

• Deliver core app functionality
• Provide you with personalised emotional insights
• Support mental health first responder functionality
• Help you track wellbeing, emotional trends, and relationships
• Enable you to form trusted support connections
• Monitor support requests and response time

Your emotional data remains completely confidential. It is never shared with HR or organisational admins. We only provide de-identified group-level insights to help organisations assess trends without identifying individuals.

Duty of care and risk of harm

In the event that we reasonably suspect a user is at serious risk of harm to themselves or others, Emotional Pulse reserves the right to disclose relevant personal information to appropriate professional support services, such as mental health crisis teams, emergency services, or qualified health professionals, without the user’s consent.

This action is taken under our legal and ethical duty of care, in line with Australian laws that prioritise the preservation of life and public safety. We will only disclose what is necessary to ensure appropriate support is provided and will aim to do so in a sensitive and proportionate manner.

AI safety monitoring and escalation

The AI Mental Health First Responder (MHFR) feature includes safety protocols that log support-related interactions. In the event a user expresses distress or high-risk indicators, the system may automatically notify qualified Emotional Pulse team members for further review and, where appropriate, escalation. These notifications are managed with confidentiality and used solely to assess risk and ensure appropriate support pathways are offered.

4. Legal grounds for processing

We process your data under:

• Consent: By registering and using the app, you consent to the collection and processing of your information.
• Legal obligations: We may disclose information where required by law or by court order.

5. How we store and protect your data

Your data is securely stored on AWS servers located in Sydney, managed by Xano. We enforce strict security protocols:

• All access accounts require 2FA
• Data is encrypted at rest and in transit
• Secure integrations with trusted third-party providers (for example ChatGPT, ElevenLabs, Stripe, SendGrid, Twilio), using signing secrets for encrypted data exchange

6. Third-party services we use

We partner with the following providers:

• ChatGPT: We use OpenAI’s ChatGPT API to deliver our daily emotional insights and mental health first responder conversations. Only your first name is shared with ChatGPT for personalisation. Email or other identifiers are never shared. By default, ChatGPT retains conversation data for up to 30 days, but does not use it for model training unless you explicitly opt in. We do not currently store data in Australia under OpenAI’s data residency program, as it is not yet supported here.
• ElevenLabs: Used for voice-enabled AI conversations. They do not store your conversation data; all audio and text is deleted as soon as your conversation ends.
• Stripe: Handles billing, subscriptions, and secure payments.
• SendGrid: Sends essential email notifications (for example account invites).
• Twilio: Sends one-time SMS verification codes to confirm your mobile number, and places the outbound calls used by Proactive EAP.
• Anthropic: Analyses Proactive EAP call transcripts to identify workplace themes. Contractually prohibited from training on your information.
• Cal.com: Books support sessions and sends the calendar invitations and reminders for them.
• Xano: Our system of record, hosted in Sydney, Australia. This is where your data is stored.
• Amplitude: Product analytics showing which parts of the app are used, so we can improve them.
• Intercom: Runs the in-app support messenger and keeps your support conversations with us.
• Google Analytics: Measures how the emotionalpulse.ai website is used. This applies to the public website, not to your account data.

All third-party services comply with secure data exchange and confidentiality requirements.

The providers used specifically for Proactive EAP check-in calls, including what each one handles, where, and the controls that apply, are listed in full at our sub-processors page. The cookies these services set are explained in our Cookie Policy.

7. Overseas disclosure

Some processing happens on servers outside Australia, in the United States and, for session bookings, the European Union. Australian Privacy Principle 8 requires us to tell you this and to take reasonable steps to ensure overseas recipients handle your information consistently with the Australian Privacy Principles. We do that through contract terms that prohibit each provider from using your information for its own purposes or for training AI models.

Our system of record, holding your account, check-in and Proactive EAP data, is hosted in Sydney, Australia.

8. Proactive EAP check-in calls

If your employer has engaged Proactive EAP, ShareTree will call you on a regular schedule for a wellbeing check-in. This is separate from the app, and the detail is set out in our Proactive EAP Employee Privacy Notice. In summary:

• We collect your name, mobile number, team and business unit from your employer, and the content of the call from you.
• Calls are transcribed as text and analysed by AI. Audio is never recorded or kept. The transcript is deleted after 30 days.
• The transcript may contain health information, which is sensitive information under the Privacy Act. We handle it accordingly.
• Your employer receives de-identified themes across teams of five or more people, never names, quotes, or anything traceable to an individual.
• The one exception is a follow-up list of people we could not reach or who declined, provided so someone can check on them. It is based only on whether a scheduled call connected, never on anything said.
• Participation is always voluntary. You can decline, stop, or skip any question, and it does not affect your employment.

Read the full notice at emotionalpulse.ai/proactive-eap/privacy.

9. SMS and mobile messaging

We use SMS text messaging only to verify your mobile number. When you add your mobile number during registration, we send a one-time verification code by SMS to confirm the number is valid and belongs to you. Verifying your number allows other users in your trusted support network to contact you directly in an emergency.

We do not send recurring, marketing, or promotional SMS, and we do not use your mobile number for advertising or profiling.

Message frequency: One SMS message is sent per verification request.

How consent is obtained: When you enter your own mobile number in the app and continue, you consent to receive a one-time verification code by SMS from Emotional Pulse.

Opting out and help: You can reply STOP to any message to opt out of further SMS, or reply HELP for assistance. You can also contact us at support@sharetree.org.

Charges: Message and data rates may apply, depending on your mobile plan and carrier.

Our SMS messages are delivered using Twilio (see section 6). Mobile opt-in data and consent are never shared with or sold to third parties or affiliates for marketing or promotional purposes.

10. Your rights

Under Australian law, you have the right to:

• Access your personal data
• Correct or update your information
• Delete your account and all associated data
• Contact us regarding privacy concerns

To make a data request, email us at support@sharetree.org. You can delete your account at any time via the Emotional Pulse App settings.

11. Children and underage users

Emotional Pulse does not currently restrict users by age and does not collect parental or guardian consent. Users under 18 should use the app with appropriate adult guidance.

12. Policy updates

We may update this Privacy Policy from time to time. When we do, we will notify users via email or in-app notification. Please review the policy periodically.

13. Contact us

For all privacy-related questions, please contact support@sharetree.org.
ShareTree Inc., Australia

See also our Terms of Use and Cookie Policy.