Policies

Before using the Mental Wellbeing Application, carefully read its Privacy Policy outlined in this document. The last modification of terms was made on June 2, 2025.
DEFINITIONS
The terms ‘We’ and ‘Us’ refer to Orange Griffin Ltd., a company with its head office in the United Kingdom, registered as a data controller with the Information Commissioner’s Office (ICO registration number: ZB561289)
The term ‘You’ refers to the person using the Application and its associated services.
An ‘Application’ is a software that runs on certain electronic devices and has a graphic interface from which You can interact with the available facilities.
In this document and in the Application, the term ‘Practitioner’ refers to a person who uses the Application for their client work and research activities. It is to be mentioned that We don’t collect information about Practitioner’s ability to work with confidential data, their academic background or professional membership status.
In this document and in the Application, the term ‘Client’ denotes a person who chooses to exchange information with another user, self-entitled Practitioner.
‘Personal Data’ refers to information that relates to an identifiable natural person.
‘Non-Personal Data’ refers to any set of data which does not contain personally identifiable information.
NOTICE
By using the Application, You confirm that You have reviewed our commitments and agree to our Billing Agreement, End User License Agreement, Privacy Policy, and Terms of Use. Any objection or contestation revokes your permission to use the Application, and You must uninstall the Application. Orange Griffin Ltd. might not respond immediately to actions that contradict its policies, agreements, or terms of use, but that does not mean that We cannot do it later.
1. DATA ACCURACY AND PROTECTION
1.1 General safety and confidentiality
We limit the access to our database to software developers, data analysts and professionals who are bound by a confidentiality agreement and have a justified need to access this information. While We use advanced methods to provide safety and reduce risks of data loss, no data transmission or technological system can guarantee to be 100% secure.
1.2 Children’s privacy
Users under the age of 18 must not use this Application.
1.3 Personal Data
We recommend You to make sure that your Personal Data is constantly accurate. If You encounter any inaccuracy, please update the information.
1.4 Data shared between users
We don’t guarantee that data shared between users is complete, correct or available anytime. We also don’t guarantee that deleting an account or archiving a Client-Practitioner collaboration will trigger the necessary changes in our database. The propagation of updates depends on several variables, some of them outside of our control, such as the user’s decision to use the Application offline.
2. DATA COLLECTION AND STORAGE
By using the Application, You allow Orange Griffin Ltd., or the storage company designated by Orange Griffin Ltd. for such purpose, to store data collected when using the Application.
2.1 We collect and store data when You:
- register your account;
- log in and log out;
- make a payment;
- use the Application;
- communicate with Us.
2.2 In general, We collect and store:
- your name, email address, and telephone number;
- your geographical location when You use the Application;
- records of your payments;
- details about how You interact with the Application, such as scores, frequency of use, duration of sessions.
2.3 When You engage in a dialogue with our avatar or during a session with a Practitioner, We collect and store:
- key points discussed during the session;
- your heart and respiratory rate;
- your presumptive emotional state as interpreted from your facial expressions and voice modulation;
- your head position and eye contact with the interlocutor on the screen;
- voice parameters, such as tone, pitch and volume.
2.4 When you give Us feedback regarding the Application’s performance, We collect and store data such as the operating system, device type and version of the Application.
3. DATA USE
We neither rent or sell your Personal Data. As long as your account is not deleted, We can use your contact details to send notifications about the Application and respond to your messages.
We use Your Personal and Non-Personal Data to:
- establish and maintain your account;
- provide technical support and maintenance for the Application;
- perform statistical analysis of your wellbeing and engagement with the Application;
- improve user experience;
- generate average values, allowing individual users to compare their personal results.
4. DATA RETENTION
4.1 You may not be able to access your data at all times, and We cannot guarantee You that your data will be available forever.
4.2 Our services are operated from the United Kingdom and the information You provide to Us is stored or processed in the United Kingdom and the United States of America. By downloading and installing the Application, You consent to a processing and storage of information that can take place outside the borders of your country of residence.
4.3 In case You want Us to empower a person to carry out specific instructions related to the fate of your data after your death, the rights (e.g. delete, edit, download) selected by You and agreed by Orange Griffin Ltd. will be transferred to the empowered person. In order to confirm their identity, the empowered person must be an account holder of this Application. We respond to requests of empowerment in a month time, but your directives can take several months to be analysed and accepted by Orange Griffin Ltd.
4.4 We retain your Personal and Non-Personal Data for as long as necessary to support your use of the Application and to comply with legal obligations, such as tax and accounting requirements. Additionally, we may retain data for a longer period if explicitly communicated to you or required for legitimate purposes.
5. DATA SHARING BETWEEN USERS
5.1 Clients and Practitioners
5.1.1 When a Client interacts with a Practitioner, the following information is shared with that particular Practitioner:
- the Client’s username;
- the Client’s session history with the Practitioner;
- the Client’s responses to games and questionnaires (excluding relational questionnaires);
- analyses of the Client's wellbeing trends;
- key discussion points from previous sessions with the Practitioner;
- the Client’s heart rate and respiratory rate as measured during sessions with the Practitioner;
- the Client‘s emotional state, as inferred from facial expressions during sessions with the Practitioner;
- the Client’s head position and eye contact with the screen as observed during sessions with the Practitioner;
- the tone, pitch, and volume of the Client’s voice as measured during sessions with the Practitioner.
5.1.2 If a Client’s account is deleted by Us, voluntarily disabled by the Client, or if the Client archives the collaboration with a Practitioner, the Client’s name will be removed from the Practitioner’s list of Clients. However, the Practitioner will still have access to the following anonymised data in a read-only format:
- the Practitioner’s session history with that particular Client;
- the Client’s responses to games and questionnaires (excluding relational questionnaires) from up to 6 months prior the account deletion;
- the Client’s notes and objectives documented by the Practitioner and confirmed by the Client as complying with the Client-Practitioner Agreement and the Application’s policies.
5.1.3 When a Practitioner interacts with a Client, the following information is shared with the Client:
- the Practitioner’s username;
- Client’s notes and objectives, as documented by the Practitioner.
5.1.4 If a Practitioner’s account is deleted by Us, voluntarily disabled by the Practitioner, or if the Practitioner archives the collaboration with a Client, the Practitioner’s name will be removed from the Client’s list of Practitioners. However, the Client will still have access to the following anonymised data in a read-only format:
- the Client’s session history with that particular Practitioner;
- the Client’s notes and objectives documented by the Practitioner and confirmed by the Client as complying with the Client-Practitioner Agreement and the Application’s policies.
5.1.5 While we do not monitor the communication between Clients and Practitioners - such as messages, objectives, and notes - this communication must remain respectful, adhere to agreed objectives, and exclude Personal Data, as defined by applicable data protection laws. The dissemination of harmful content, misinformation, and illegal activities is strictly prohibited. Text messages in the virtual room are automatically deleted 30 days after their creation.
5.1.6 We do not require Practitioners to take notes, but if they choose to do so, they must comply with the regulations that govern their professional activity.
5.1.7 Practitioners can use the Application to conduct scientific research and may invite their Clients to enrol, in accordance with the pre-existing Client-Practitioner contract. Clients retain the right to accept or ignore the invitation, and may withdraw from the research at any time without providing a reason. By accepting an invitation, a Client confirms that the research they are about to join complies with necessary regulations and the sharing of their data with the Practitioner is voluntary and informed. Upon the Client’s withdrawal, their data will be removed from the Practitioner’s research database.
5.1.8 Practitioners may optionally store in the Application the account details used for Client payments. This information is saved on the Practitioner’s device and remains inaccessible to Us. Clients can access it only if shared by the Practitioner.
5.2 Relationship assessments
When one user (the “inviter”) sends another user (the “invitee”) an invitation to complete the relationship questionnaire, the Application will disclose the inviter’s username and questionnaire answers, including their interpretation, to the invitee. Similarly, when the invitee accepts the invitation, their username and questionnaire answers, including the interpretation, will be disclosed to the inviter.
5.3 Social or nature prescribing and other team work activities
Users can interact with each other to achieve a goal. Their interaction via the Application occurs under a randomly assigned, unique pseudonym known to both parties.
6. YOUR RIGHTS
6.1 You can request an electronic copy of your data by using the feature available on the Account page of the Application.
6.2 You can erase any Personal Data We hold about You by deleting your account. This action irrevocably withdraws your name, email and telephone number from our database. Please note that modifying or transferring Non-Personal Data may be subject to limitations, as We are required to manage this information in specific ways to ensure it remains accurate and secure, in compliance with GDPR and other applicable data protection regulations.
6.3 In the event of a dispute, You can file a complaint at our registered office: Orange Griffin Ltd., 95 Robbery Bottom Lane, Welwyn, England, AL6 0UL.
7. COLLABORATION WITH THIRD-PARTY PROVIDERS
7.1 Hosting and traffic
We use Google (google.com) products and services to host our database and analyse traffic. Data transmitted to Google for the purpose of improving the Application is aggregated and anonymised. Your Personal Data is shared with Google solely for cloud hosting purposes. We have taken great care in selecting Google services to ensure a high level of protection, as required by applicable privacy laws.
7.2 Virtual room
For seamless communication during Client-Practitioner sessions, we utilise the WebRTC (webrtc.com) environment.
7.3 Virtual avatar
Some of our virtual avatar’s abilities rely on OpenAI (openai.com) services.
7.4 Before using the Application, we advise You to review the privacy policy of the third-party providers mentioned above to understand how they handle data.
8. FAST/BIOMETRIC AUTHENTICATION
8.1 Storage
If You allowed your device to collect and store biometrics, they should have been automatically secured on your device by the manufacturer. We don’t have access to your biological characteristics (e.g. fingerprint, facial traits) used to secure your device.
8.2 Multiple Users
If You share the device, anyone whose biometrics, PIN numbers or passwords are accepted by your device can access your data and make changes to your account.
9. DISCLOSURE OF PERSONAL AND NON-PERSONAL DATA IN EXCEPTIONAL CIRCUMSTANCES
We can disclose data for law enforcement reasons or other legal requirements such as to protect the public and individual safety, investigate a fraudulent use of the Application, protect against legal liability, etc. Also, unless otherwise instructed by You, in the eventuality of a merger, sale of Orange Griffin Ltd. or the Application, your Personal and Non-Personal data will be shared with the new owner to assure the continuation of the service. Any such decision will be brought to your attention in due time.
10. MODIFICATION OF TERMS
Orange Griffin Ltd. may amend the Privacy Policy at any time with or without notice by posting revised terms on this page. We usually provide a one week window between the modification date and the effective date. If You do not agree with the new terms, You must delete your account and the Application. Orange Griffin Ltd. shall not, under any circumstances, be liable to You or any other third party for any form of damages, losses or inconveniences arising out of or in connection with your disagreement with the new terms. If You continue using the Application after a modification of terms, that means You agree to all of the changes. It is your responsibility to periodically review if You agree with our commitments, terms and policies.

Before using the Mental Wellbeing Application, carefully read its Terms of Use outlined in this document. The last modification of terms was made on June 2, 2025.
DEFINITIONS
The terms ‘We’ and ‘Us’ refer to Orange Griffin Ltd., a company with its head office in the United Kingdom, registered as a data controller with the Information Commissioner’s Office (ICO registration number: ZB561289)
The term ‘You’ refers to the person using the Application and its associated services.
An ‘Application’ is a software that can run on certain electronic devices and has a graphic interface from which You can interact with the available facilities.
In this document and throughout the Application, the term ‘Practitioner’ refers to a person who uses the Application for their client work and research activities. It is to be mentioned that We don’t collect information about Practitioner’s ability to work with confidential data, their academic background or professional membership status.
In this document and across the Application, the term ‘Client’ denotes a person who chooses to exchange information with another user, self-entitled Practitioner.
‘Force Majeure’ is any event that prevents Us from fulfilling our obligations mentioned in the Terms of Use. Examples of such events can be a strike, flood, fire, earthquake, war, pandemic, disruption in transport services or energy supply, communication interference.
NOTICE
By using the Application, You confirm that You have reviewed our commitments and agree to our Billing Agreement, End User License Agreement, Privacy Policy, and Terms of Use. Any objection or contestation revokes your permission to use the Application, and You must uninstall the Application. Orange Griffin Ltd. might not respond immediately to actions that contradict its policies, agreements, or terms of use, but that does not mean that We cannot do it later.
1. USER ELIGIBILITY AND RESPONSIBILITY
As a user, You guarantee that:
- You are at least 18 years old, the age of consent in your jurisdiction, and capable of entering a formal agreement.
- You are comfortable engaging with theories, interpretations, or perspectives that may differ from your own or those of others.
- You do not experience confusion, or distress when using applications that reference physical, psychological, or relational aspects or when interacting with virtual entities.
- You will not share the Application with individuals who do not meet the age requirements or who may experience confusion, distress, or discomfort in using such applications or interacting with virtual entities.
- Your needs and expectations align with the services provided by the Application.
- We haven’t previously disabled your account for violation of law or any of our policies.
- You have confirmed your email address as part of the registration process.
- You agree to use the Application at least once a year to maintain an active account.
- You acknowledge and accept that some links to Internet domains or documents have not been created by Us. We are not responsible for any harm or potential damage that may result from your reliance on these links mentioned in the Application.
2. CLIENT-PRACTITIONER COLLABORATION
2.1 Clients and Practitioners may exchange messages or share information only if their relationship is based on a pre-existing Client-Practitioner contract that is not linked to Orange Griffin Ltd. or its services and is recognised by a professional body that regulates the Practitioner’s activity.
2.2 Practitioners must not use the Application as the main database management system or to communicate with their Clients outside of a contract that meets the requirements mentioned above. In case of an international relationship, the Practitioner must follow the laws and regulations that govern the Client-Practitioner contract in their own country, as well as the Client’s country. Only a Practitioner can add or edit their Client’s notes and objectives stored in the Application.
2.3 Clients must not use the Application as the main repository of notes and objectives or to communicate with Practitioners outside of a contract that meets the requirements mentioned above. In case of an international relationship, the Client must follow the laws and regulations that govern the Client-Practitioner contract in their own country, as well as the Practitioner’s country. Only a Client can confirm that the information provided by their Practitioner in the Application does not contain Personal Data, is respectful and aligned to commonly agreed objectives. Confirmation is provided by ticking the boxes available in the fields populated by Practitioners. Once provided, such a confirmation cannot be withdrawn.
2.4 If a Client or Practitioner deletes their account, or if one party archives the Client-Practitioner collaboration, the consequences described in the Privacy Policy will be applied. Archiving a Client-Practitioner collaboration is recommended to be a mutually agreed-upon decision.
2.5 Practitioners can use the Application to conduct scientific research and may invite their Clients to enrol, in accordance with the pre-existing Client-Practitioner contract. Clients will be notified of the invitation by a new button appearing under the Practitioner’s name. Clients retain the right to accept or ignore the invitation and may withdraw from the research at any time without providing a reason. Upon the Client's withdrawal, the Client's data will be removed from the Practitioner’s online research database. If the Practitioner withdraws from the research or removes the Client, the button will disappear from the Client’s account, and the Client’s data will be removed from the Practitioner’s online research database.
3. USE
The Application can be used for personal purposes or as a tool to collaborate with other users.
3.1 Disclaimer
Given that the Application is based on artificial intelligence, neither the information presented within the Application nor any recommendations derived therefrom shall be regarded as formal advice. None of our services can replace or increase the efficiency of professional services, such as medical care, mental health services or formal supervision. The Application is not intended to prevent, screen, diagnose, treat, monitor or cure any physical or psychological disorders. Terms like ‘anxiety’ or ‘depression’ refer to general states and should not be confused with clinical diagnoses such as Anxiety Disorder or Major Depressive Disorder, as We don’t refer to psychopathology.
When education, information, cognitive computing counselling and supervision are delivered by the digital avatar, your interaction with the Application cannot be considered a Client-Practitioner or supervisor-supervisee relationship. This is because the avatar lacks the human abilities and responsibilities of a qualified practitioner.
Although We strive to offer the best service possible, the information may not always be complete or up to date for unforeseeable reasons, such as technical difficulties. Also, We don’t guarantee that data shared between users is complete, correct or available anytime. Sharing data with other users is at your own risk.
3.2 Emergencies
The Application cannot be used for emergencies. If You are in a critical situation or considering any form of self-harm, including suicide, You must stop using the Application and contact national or local crisis helplines. By downloading, installing and using the Application, You confirm that You already know how to and can access the crisis services, your general practitioner, or the police.
3.3 Prohibited use
- You cannot impersonate others or provide inaccurate information.
- You cannot call yourself Practitioner unless You are authorised to work with confidential data, You have completed a professional certified training in your field of work and You are registered with the appropriate regulatory body.
- You cannot do anything unlawful or for an unauthorised purpose.
- You cannot violate (or help others to violate) our Privacy Policy, End User Licence Agreement or the Terms of Use.
- You cannot do anything to impair the functionality of the Application.
- You cannot attempt to sell, or transfer any aspect of your account or buy, nor solicit the login credentials of other users.
- You cannot use any logo, visual crops or text excerpts from the Application to create the false impression that You are associated with Orange Griffin Ltd. or with the Application.
- You cannot have more than one account.
- You are prohibited from using data extracted from the Application to draw conclusions that disparage or defame individuals, projects, or organisations. Access to raw or processed data is provided solely to inform your decision regarding the Application's use for a specific population segment. Any other use of data, including but not limited to making derogatory or harmful statements, is expressly forbidden and will result in legal action being taken against You.
3.4 Demonstration section
The demonstration section of the Application is intended for personal, temporary use only and offers limited functionality. Its purpose is to allow You to explore the Application before creating an account.
3.5 Log in
Depending on the compatibility between the Application and the electronic device, You may log in using your mobile number or biometric authentication (e.g. fingerprint, face ID). When You choose to log in with your mobile number, a message with an access code will be sent to your device. The access code should be used before it expires. The landing page provides a brief description of the Application and guides you through the process of authentication.
3.6 Technical support
When time permits, we respond to technical support queries raised by the account holders with a verified email address.
4. QUESTIONNAIRES, TESTS, INTERPRETATIONS
4.1 Purpose
All questionnaires and tests, as well as their respective interpretations, are intended solely for educational or informational purposes.
4.2 Restrictions
Tests dedicated to executive functions (Working Memory, Cognitive Flexibility, Impulse Control) can be administered only once every 6 months.
4.3 Relationship questionnaires
A user can invite, for a non-refundable fee, another user to complete questionnaires dedicated to their type of relationship, under the following conditions:
- The invitee has given written consent to answer all questions within 7 days of receiving the invitation.
- The invitee wishes to share personal opinions with the person who sent the invitation.
- The invitee has expressed in writing the desire to learn the personal opinions of the person who sent the invitation.
- Both users will use the recommendations to benefit both parties.
5. PRIVACY
For more details regarding your rights and responsibilities whilst using the Application refer to our Privacy Policy.
6. BILLING
By making a purchase, You acknowledge that You have thoroughly reviewed and accepted the terms of our Billing Agreement. For comprehensive information concerning your rights and obligations associated with a purchase, please consult the Billing Agreement.
7. ACCOUNT DELETION
7.1 Requested
When You request to delete your account, a 30-day deactivation period begins. After this period, the deletion is irreversible. To cancel the deletion request, log back into your account within these 30 days and reactivate your account. You can delete your account via the app or by visiting orangegriffin.com/account on the web.
7.2 Not requested
You agree that We may suspend services or your account and delete the associated data for any reason considered by Us justified, such as prolonged lack of use of the Application, violation of our Terms of Use, End User Licence Agreement or Privacy Policy. We may also discontinue, at any time, your access to the Application or any part thereof, with or without notice. Further, You agree that We are not liable to You or any other third party for any termination of your access to the Application.
8. PREREQUISITES AND USER EXPERIENCE
8.1 Access to microphone and camera
Access to the Application’s full range of features requires permission to use your device’s microphone and camera. For example, if you do not grant the Application permission to access audio or video functionalities, You will be unable to participate in audio-video sessions. By using the Application, You acknowledge and accept that declining access to the microphone, voice processing, camera or video processing may result in a diminished user experience and render certain services unavailable.
8.2 Hardware
The Application has limited functionality when your device belongs to an old generation or it is not properly connected to the Internet. We are not liable to You or any other third party for any inconvenience caused by the Application’s incompatibility with the electronic device or the functions alteration caused by a poor Internet connection.
8.3 Software
You can use the Application only if your device meets certain system requirements, that change continuously due to the dynamic nature of softwares and electronic equipment. We recommend the use of an operating system more recent than Android 12, iOS 15, iPadOS 15, MacOS 13 or Windows 11.
9. WARRANTY
The Application and all data derived through it are provided as is with no warranty. We expressly disclaim any and all warranties and conditions including, but not limited to, implied warranty of merchantability, fitness for a particular purpose, availability, security, title and non-infringement. You are solely responsible for any damage that results from the use of the Application including, but not limited to, damage to hardware, software or loss of data. Orange Griffin Ltd. shall not, under any circumstances, be liable to You for any indirect, incidental, consequential, special or exemplary damages arising out of or in connection with its use. Under no circumstances shall We be liable to You for any amount. We do not warrant that the Application will be available at any time, from any location, complete, secure or error-free. Furthermore, we do not warrant that defects will be corrected, or that the Application is free of viruses or other potentially harmful components.
10. FORCE MAJEURE
During a Force Majeure event, the Application will be suspended. It will resume once the cause of the Force Majeure ends and Orange Griffin Ltd. is able to provide services again.
11. MODIFICATION OF TERMS
Orange Griffin Ltd. may amend the Terms of Use at any time with or without notice by posting revised terms on this page. We usually provide a one week period between the modification date and the effective date. If You do not agree with the new terms, You must delete your account and the Application. Orange Griffin Ltd. shall not, under any circumstances, be liable to You or any other third party for any form of damages, losses or inconveniences arising out of or in connection with your disagreement with the new terms. If You continue using the Application after a modification of terms, that means You agree to all of the changes. It is your responsibility to periodically review if You agree with our commitments and policies.

Before using the Mental Wellbeing Application, carefully read its End User Licence Agreement outlined in this document. The last modification of terms was made on March 20, 2025.
DEFINITIONS
The terms ‘We' and ‘Us' refer to Orange Griffin Ltd., a company with its head office in the United Kingdom, registered as a data controller with the Information Commissioner’s Office (ICO registration number: ZB561289)
The term ‘You’ refers to the person using the Application and its associated services.
An ‘Application’ is a software that can run on certain electronic devices and has a graphic interface from which You can interact with the available facilities.
NOTICE
By using the Application, You confirm that You have reviewed our commitments and agree to our Billing Agreement, End User License Agreement, Privacy Policy, and Terms of Use. Any objection or contestation revokes your permission to use the Application, and You must uninstall the Application. Orange Griffin Ltd. might not respond immediately to actions that contradict its policies, agreements, or terms of use, but that does not mean that We cannot do it later.
1. LICENSING
The Mental Wellbeing Application is a digital product created by Orange Griffin Ltd. We licence the use of the Application but We do not sell You the Application. We are the owner of the Application.
2. INTELLECTUAL PROPERTY
The Application, including its content, graphics, user interface, animations, images, scripts, and software, contains proprietary information and materials that are owned by Orange Griffin Ltd. and are protected by applicable intellectual property and other laws, including but not limited to copyright. No portion of the Application may be reproduced in any form or by any means. You agree not to modify, rent, loan, sell or distribute the Application in any manner. If You identify any content on the Application that You believe infringes upon copyright, please use the Contact window to provide a description of the alleged infringement and your contact details.
3. MODIFICATION OF TERMS
Orange Griffin Ltd. may amend the End User Licence Agreement at any time with or without notice by posting revised terms on this page. We usually provide a one week period between the modification date and the effective date. If You do not agree with the new terms, You must delete your account and the Application. Orange Griffin Ltd. shall not, under any circumstances, be liable to You or any other third party for any form of damages, losses or inconveniences arising out of or in connection with your disagreement with the new terms. If You continue using the Application after a modification of terms, that means You agree to all of the changes. It is your responsibility to periodically review if You agree with our commitments, terms and policies.

Before using the Mental Wellbeing Application, carefully read its Billing Agreement outlined in this document. The last modification of terms was made on April 20, 2025.
DEFINITIONS
The terms ‘We’ and ‘Us’ refer to Orange Griffin Ltd., a company with its head office in the United Kingdom, registered as a data controller with the Information Commissioner’s Office (ICO registration number: ZB561289)
The term ‘You’ refers to the person using the Application and its associated services.
An ‘Application’ is a software that can run on certain electronic devices and has a graphic interface from which You can interact with the available facilities.
In this document and throughout the Application, the term ‘Practitioner’ refers to a person who uses the Application for their client work and research activities. It is to be mentioned that We don’t collect information about the Practitioner’s ability to work with confidential data, their academic background or professional membership status.
In this document and across the Application, the term ‘Client’ denotes a person who chooses to exchange information with another user, self-entitled Practitioner.
‘Force Majeure’ is any event that prevents Us from fulfilling our obligations mentioned in the Terms of Use. Examples of such events can be a strike, flood, fire, earthquake, war, pandemic, disruption in transport services or energy supply, communication interference.
‘Premium Services’ are marked across the application and are available either on a pay-per-use basis or through a monthly subscription.
NOTICE
The budget for Premium Services accessed on a pay-per-use basis is shown in the designated section of the Application. Insufficient funds restrict access to Premium Services and may result in the deletion of associated data.
Orange Griffin Ltd. does not collect or process bank card data. Purchases are processed through mobile payment technologies (e.g., Google Pay).
Bonuses are not eligible for reimbursement. Additionally, payments are non-refundable in cases of non-use or partial use of the Application.
1. PAYMENT
1.1 When You make a payment, You:
- Authorise Us to charge You;
- Confirm that You are authorised to make the payment;
- Authorise Us to store information regarding your purchase (e.g., date, amount).
1.2 When You share payment details with your Clients, You:
- Accept full responsibility for the accuracy of the payment details;
- Confirm that You are authorised and entitled to receive the payment.
2. LIMITATIONS
All services included in a subscription plan expire on the final day of the paid period. Unused services are not transferred, or extended to subsequent periods. If You do not have a subscription or have used all the services included in it, You may still access some Premium Services by paying per use.
All Premium Services and paid subscriptions require a reliable internet connection, as well as access to your device’s microphone and camera. If you intend to use the Application without an internet connection, camera, or microphone, please refrain from making any purchases.
3. REFUNDS
You may request a refund for the most recent payment within 14 days of the payment date, provided:
- there is no Force Majeure event;
- You complied with our Privacy Policy, End User License Agreement, Billing Agreement and Terms of Use;
- You presented substantiated grounds for your request;
- You have utilised less than 5% of the services associated with that payment. This limited usage is considered evidence that You have not benefited from the services covered by the payment;
- You do not request a refund for an amount paid for the services provided by a Practitioner;
- that such purchase was not made in violation of this Billing Agreement, which expressly advises You to refrain from making any purchases if You intend to use the Application without an internet connection, camera, or microphone.
Orange Griffin Ltd. does not mediate or resolve any issues arising between Clients and Practitioners.
Refunds will be processed using the same payment method used for the initial transaction. After the 14-day period, all paid fees become final and nonrefundable, even if features or functions of the Application are modified, replaced, or removed.
4. SUBSCRIPTION
4.1 Renewal
Subscriptions renew automatically. To stop the renewal and corresponding payment, automatic renewal must be deactivated before the subscription’s expiration date.
4.2 Platform change
To cancel a subscription on one platform (e.g., iOS) in order to create a new subscription on another platform (e.g., Microsoft), We recommend exhausting the subscription on the old platform. Creating a subscription on a new platform requires canceling the old subscription, which revokes your access to unused services. After a platform change, your access to your data remains unaffected, provided the new subscription is identical to the old one.
5. CHANGE OF PRICES AND MODIFICATION OF TERMS
Orange Griffin Ltd. may change its prices or amend this Billing Agreement at any time with or without notice by posting the new prices in the payment section of the Application and the revised terms on this page. We usually provide a one week period between the modification date and the effective date. If You do not agree with the new terms, You must delete your account and the Application. Orange Griffin Ltd. shall not, under any circumstances, be liable to You or any other third party for any form of damages, losses or inconveniences arising out of or in connection with your disagreement with the new terms. If You continue using the Application after a modification of terms, that means You agree to all of the changes. It is your responsibility to periodically review if You agree with our commitments, terms and policies.

This Commitment to Diversity reflects the values of Orange Griffin Ltd. The last modification of terms was made on July 3, 2025.
CONTINUOUS IMPROVEMENT
We are a socially responsible company, continually looking to enhance the diversity of our team and promote this value within the organisation. If you have suggestions for improvement, let us know via the Contact page. Logging in is required to send a message.
CONFORMITY
We are committed to operate in accordance with the main international regulations referring to diversity, equality, equity and inclusion.
- For selection and recruitment, we consider knowledge, skills, experience, and personal qualities, including engagement in activities that support vulnerable people or biodiversity.
- Creative results are delivered through a mix of talents and cultural origins.
- We educate ourselves on issues related to diversity, equality, equity and inclusion.
- Diversity performance is embedded in our way of working as a company.
- We understand the difference between diversity of opinion and diversity of background.
- We implement all relevant recommendations from external advisors in the area.
MODIFICATION OF TERMS
Orange Griffin Ltd. may amend this commitment at any time with or without notice by posting revised terms on this page. We usually provide a one week period between the modification date and the effective date.

This Commitment to Sustainability reflects the values of Orange Griffin Ltd. The last modification of terms was made on March 3, 2025.
CONTINUOUS IMPROVEMENT
We are a socially responsible company, continually looking to minimise the environmental impact of our products and services. If you have suggestions for improvement, let us know via the Contact page. Logging in is required to send a message. Our main challenge is the energy consumption required for artificial intelligence services.
CONFORMITY
We are committed to operate in accordance to main international environmental regulations.
- We are mindful of the need for conserving energy and natural resources.
- We monitor waste generation and support nature conservation initiatives.
- When not in use, our software products suspend most unnecessary tasks.
- We analyse the energy use of each product, consider new ways to reduce data needed and bring minimalism to everything we do.
- We create energy efficient solutions for large communities, including those who are hard to reach.
- We use only green service providers if possible.
- Our software products allow users to reduce the amount of paper used for notes and replace in-person appointments that involve fossil fuel consumption with online ones.
MODIFICATION OF TERMS
Orange Griffin Ltd. may amend this commitment at any time with or without notice by posting revised terms on this page. We usually provide a one week period between the modification date and the effective date.

This Commitment to Standards reflects the values of Orange Griffin Ltd. The last modification of terms was made on June 3, 2025.
GLOSSARY
Artificial Intelligence (AI) is a system capable of performing tasks that typically require human intelligence.
Data Encryption Key (DEK) ensures that the information is protected both at rest and in transit.
Datagram Transport Layer Security - Secure Real-time Transport Protocol (DTLS-SRTP) is used to secure real-time communications, particularly in VoIP (Voice over IP) and video conferencing.
Firebase App Check prevents unauthorised clients from accessing backend resources.
General Data Protection Regulation (GDPR) is a data protection law enacted by the European Union.
Health Insurance Portability and Accountability Act (HIPAA) is a U.S. law enacted to improve the efficiency of the healthcare system, ensure the privacy and security of individual medical information, and provide patients with certain rights regarding their health information.
Payment Card Industry Data Security Standard (PCI DSS) is a globally applied set of standards designed to ensure that all companies that accept, process, store, or transmit credit card information maintain a secure environment.
Payment Services Directive 2 Strong Customer Authentication (PSD2 SCA) is a regulatory framework aimed at authenticating payers and reducing fraud in electronic payments within the European Economic Area.
Strong Customer Authentication (SCA) verifies a customer identity based on at least two of the following factors: something the user knows (e.g. password), something they have (e.g. a mobile device) or their identity (e.g. face ID).
Transport Layer Security (TLS) is a cryptographic protocol used to ensure privacy, data integrity, and authentication between applications and users on the Internet.
1. CONTINUOUS IMPROVEMENT
We are a socially responsible company, continually looking to deliver quality and safety. If you have suggestions for improvement, let us know via the Contact page. Logging in is required to send a message. We are committed to operate in accordance with the main standards for design, performance, testing, security and documentation.
2. DESIGN
We use a domain-driven design approach in which we model software according to input from mental health experts. We reference the Human Interface Guidelines by Apple and Material Design Guidelines by Google.
2.1 Responsiveness
The Application works on various screen sizes and orientations.
2.2 User interface consistency
We use consistent design patterns and intuitive navigation to provide a seamless user experience. The interface is clean and visually appealing.
2.3 Accessibility
The Application provides the following features:
- contrast improvement using a dark or light theme;
- two levels of accessibility;
- parts can be listened to or navigated using voice;
- text explanations are available for most non-text content;
- captions are synchronised with pre-recorded audio-video content;
- colours are not used as means of conveying information, indicate an action, prompting a response or distinguishing a visual element;
- any audio that plays automatically can be stopped at any moment;
- no time limits are being used unless required;
- no animations that flashes more than 3 times per second are being used.
3. PERFORMANCE
3.1 Resources
The Application is optimised to minimise battery consumption.
3.2 Running
The Application should run smoothly, with minimal crashes and fast loading time across different devices and environments.
3.3 Network requests
Data usage is reduced at minimum possible.
3.4 Efficiency
All tests, assessments and forms of support are inspired by evidence. Further research is undergoing to assess and improve efficacy, accuracy, sensitivity and specificity.
3.5 Scalability
The Application maintains or improves its performance as the load increases.
4. TESTING
Major updates should perform well in open testing. Closed testing includes the assessment of all parts of the Application and how they work together.
5. SECURITY
5.1 Digital identity
Each user is uniquely identified within the Application by the following parameters:
- user ID (e.g. unique identifier code) generated during registration;
- phone number and email address collected during registration;
- biometric data (e.g. fingerprint) used for fast authentication;
- personal information (e.g. name) collected during registration and updated upon request;
- saved preferences (e.g. language);
- permissions (e.g. practitioner only);
- activity log (e.g. outcome measures);
- usage patterns.
5.2 Data at rest and during processing
We reference GDPR and some of its supplements (e.g. Data Protection Act, UK). Our data is encrypted using DEK. The following measures are implemented:
- Personal data is stored securely using technical and organisational measures like encryption.
- Processing activities maintain the confidentiality, integrity, and availability of the data.
- Users are provided with secure methods to edit and delete their data.
- Access is restricted to only the necessary data.
- Users can access individual files without needing access to the entire database.
5.3 Data in transit
We use Firebase App Check and attestation providers to ensure that only legitimate applications and authorised clients can access our services.
We reference the TLS1.3 standard for secure data transmission. The following measures are implemented:
- Live audio/video sessions between Practitioners and Clients are encrypted with DTLS-SRTP.
- Data transmitted between the user and server is sent using HTTPS and TLS protocols.
5.4 Payments
We use services that meet PCI DSS. The mobile payment technologies, Apple Pay and Google Pay, meet the SCA compliance requirements.
6. DOCUMENTATION
We offer clear terms of use and guides to assist users in navigating the Application.
7. MODIFICATION OF TERMS
Orange Griffin Ltd. may amend this commitment at any time with or without notice by posting revised terms on this page. We usually provide a one week period between the modification date and the effective date.

Among the professionals who refined this application, valuable inspiration came from:
Alex - 3D Animation Consultant (UK)
Chandan - Software Developer (Australia)
Cornel - Specialist Psychologist/CEO (UK)
Costin - Senior Software Developer (Romania)
Daniel - Agile Product Owner/COO (UK)
Emanuel - Mathematician (France)
Michelle - Lawyer (South Africa)
Mihai - Cybersecurity Architect (Denmark)
Oana - Lawyer (Germany)
Rakesh - Project Manager (India)
Satish - Senior Software Developer (India)
The photos used for contemplative practice are provided by The Metropolitan Museum of Art, New York.
A heartfelt thank you to Mycroft AI for imparting invaluable lessons in vision and determination.
The assessment tools have been created or are inspired by the work of:
National Centre for PTSD - U.S. Department of Veteran Affairs
Dr. Robert L. Spitzer, Dr. Janet B.W. Williams, și Dr. Kurt Kroenke, with support from Pfizer Inc.
Psychiatric Research Unit - World Health Organisation Collaborating Centre for Mental Health