Privacy Policy

Effective date: January 1, 2025

Our core privacy promise

Individual check-in data is never visible to your manager or employer. Managers only see anonymised, aggregated team data. We do not sell personal data. Ever.

1. Who We Are

Restemb operates the wellness platform at restemb.com. We act as a data processor on behalf of your employer (the "data controller") for employment-related data, and as an independent data controller for account and product data.

Data controller contact: privacy@restemb.com
Data Protection Officer: dpo@restemb.com

2. Data We Collect

2.1 Account Data

DataPurposeRetention
Name, email addressAccount creation, login, notificationsUntil account deletion + 30 days
Company nameOrganisation setupDuration of subscription
Role (employee / manager / HR)Access control, dashboard routingUntil account deletion

2.2 Wellness Check-in Data

DataPurposeWho sees it
Energy, stress, workload scores (1-5)Burnout risk calculation, personal dashboardEmployee only
Optional free-text noteAI coaching personalisationEmployee only
AI-derived burnout risk scorePersonal insights, trend trackingEmployee only
Anonymised team averagesManager heatmap (≥5 members required)Manager / HR (aggregated)

Individual check-in data is never accessible by managers, HR, or administrators. This is enforced at the database level (Row-Level Security), not just in application code.

2.3 Technical and Usage Data

  • IP address and approximate location (security and fraud prevention)
  • Browser type, device type (product improvement)
  • Feature usage events (product analytics, if consented)
  • Error logs and performance metrics (service reliability)

3. Legal Basis for Processing (GDPR)

  • Contract performance: Processing necessary to provide the Service (account management, check-in functionality)
  • Legitimate interests: Security monitoring, fraud prevention, service improvement
  • Consent: Optional analytics cookies, marketing communications
  • Legal obligation: Compliance with applicable laws, responding to lawful requests

For India (DPDP Act 2023): Processing is based on consent and contractual necessity. You may withdraw consent at any time without affecting the lawfulness of prior processing.

4. Third-Party Processors

ProviderPurposeLocation
SupabaseDatabase, authenticationEU / US (configurable)
GroqAI coaching suggestionsUS
ResendTransactional emailUS
Razorpay / StripePayment processingIndia / US
VercelWeb hosting, CDNGlobal (EU-accessible)

All processors are bound by Data Processing Agreements (DPAs) and comply with applicable data protection laws. International transfers use Standard Contractual Clauses (EU SCCs) or equivalent mechanisms.

5. AI and Automated Processing

We use AI (large language model API) to generate personalised wellness coaching suggestions. This is not used for automated decision-making that produces legal or similarly significant effects. AI suggestions are informational only.

Burnout risk scores are calculated by a deterministic algorithm based on the Job Demands-Resources model. No decisions about employment, salary, or performance are made based on these scores.

6. Data Retention

  • Check-in data: retained for the duration of your account, deleted within 30 days of account closure
  • Account data: deleted within 30 days of account deletion request
  • Audit logs: 2 years (security and legal obligation)
  • Billing records: 7 years (legal/tax obligation)
  • Anonymised aggregate statistics: may be retained indefinitely (cannot be re-identified)

7. Your Rights

Depending on your jurisdiction, you have the following rights:

Access

Request a copy of your personal data

Rectification

Correct inaccurate personal data

Erasure

Request deletion of your personal data

Portability

Receive your data in a machine-readable format

Objection

Object to processing based on legitimate interests

Restriction

Request restriction of processing in certain circumstances

To exercise any right, email privacy@restemb.com. We will respond within 30 days (or 72 hours for urgent erasure requests where legally required). You also have the right to lodge a complaint with your supervisory authority:

  • EU/EEA: your national data protection authority (DPA)
  • UK: Information Commissioner's Office (ICO) — ico.org.uk
  • India: Data Protection Board of India (once operational)

8. Cookies

We use the following categories of cookies:

CategoryPurposeConsent required
Strictly necessaryAuthentication session, CSRF protection, cookie consent preferenceNo
AnalyticsProduct usage analytics (aggregated, no cross-site tracking)Yes

You can manage cookie preferences at any time using the cookie preferences link in the footer.

9. Security

We implement industry-standard security measures including AES-256-GCM encryption for sensitive data at rest, TLS 1.2+ in transit, row-level database security policies, rate limiting, CSRF protection, and regular security audits.

In the event of a data breach affecting your personal data, we will notify you and relevant supervisory authorities within 72 hours as required by GDPR.

10. Children's Privacy

The Service is not directed at children under 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, please contact us at privacy@restemb.com and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by email or prominent notice within the Service at least 14 days before they take effect. The current version is always available at restemb.com/privacy.

12. Contact and Complaints

For privacy questions or to exercise your rights: