Privacy Policy · v1.0 · 2026
Privacy Policy
Digital Companions, by Move to Happiness
1. Who we are
Digital Companions is a product of Move To Happiness Hub BV, with registered office at Statieplein 1 bus 1.02, 2560 Nijlen, Belgium, registered with the Crossroads Bank for Enterprises under number 0437.586.004 (“we”, “DC”). For questions about this statement or about your data, you can reach us at hello@digitalcompanions.eu.
2. Our dual role
DC processes personal data in two capacities. For the data that an employer or client entrusts to us in order to deliver the Platform, we act as a processor and the client is the controller; our data processing agreement applies to that. For the data that you as an end user provide directly to us and for which we ourselves determine the purpose and means, we act as the controller; this statement applies to that.
3. What data and why
| Data | Purpose | Legal basis |
|---|---|---|
| Account and identification data (name, email) | Creating and managing your account, access to the Platform | Performance of the contract (art. 6(1)(b)) |
| Professional data (role, department) | Assigning you the right agents and permissions | Performance of the contract (art. 6(1)(b)) |
| Interactions with the Agents | Delivering the service, monitoring quality, providing support | Performance of the contract (art. 6(1)(b)) |
| Usage and log data | Security, troubleshooting, improving the service | Legitimate interest (art. 6(1)(f)) |
| Communication and support | Answering your questions | Performance and legitimate interest |
Through the business suites we do not process health data or other special categories. If a specific application (Wellbeing) does process health data, we ask for your explicit consent and inform you separately.
4. What the employer does and does not see
If your employer works with DC, they only receive aggregated and anonymised insights at team or organisation level. Your employer has no access to your individual conversations with the Agents. Insights are never used for individual decisions about you.
5. AI context
The Agents run on AI models from specialised providers (such as Anthropic and OpenAI), via European infrastructure. We do not use your data to train those models. You always know that you are interacting with an AI system; the AI makes no binding decisions and does not replace a professional. More on this in our AI transparency statement.
6. Recipients and sub-processors
We engage carefully selected sub-processors, under a data processing agreement, including Microsoft Azure (hosting, EU region), the AI model providers, a payment provider and an email provider. We do not sell your data.
7. Transfers outside the EEA
We process and store your data within the European Economic Area. If a transfer outside the EEA is nevertheless necessary, it takes place with appropriate safeguards, such as the European Commission’s standard contractual clauses.
8. How long we keep data
We keep your data for as long as your account is active and no longer than necessary afterwards. When your account is deleted we apply a recovery period of 30 days, unless a legal retention obligation imposes a longer period. Logs for high-risk AI use are kept for at least six months in accordance with the EU AI Act.
9. Your rights
You have the right to access, rectification, erasure, restriction, portability and objection. You can submit a request via hello@digitalcompanions.eu. We respond within one month. If you are not satisfied, you can lodge a complaint with the Data Protection Authority (Drukpersstraat 35, 1000 Brussels).
10. Security
We take appropriate technical and organisational measures to protect your data, including encryption, role-based access control, isolation per organisation and logging. The measures are described in our security and processing documentation.
11. Changes
We may amend this statement. The current version is always available on our Knowledge Base, stating the date of the last change.
Last updated: 3 July 2026. Digital Companions, by Move to Happiness.
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© 2026 Digital Companions · by Move to Happiness