SafeMind App Privacy Policy

Who is responsible?

Previon Nordic ApS is the data controller for the personal data processed in the SafeMind app.

For questions about privacy, your rights or deleting your account, contact us at kontakt@previonnordic.dk.

About SafeMind

SafeMind is a wellbeing app provided by Previon Nordic as part of its prevention and wellbeing service. Most users get access through an organisation that has an agreement with Previon Nordic. Some users get access directly from us. The app is free for users and has no in-app purchases or subscriptions.

There is no self-signup. Your account is created by Previon Nordic or by an administrator or captain in your organisation. You log in with your email address and a one-time code.

Using SafeMind is voluntary.

What information we process

• Account information: your name, email address, organisation, vessel and role where relevant, preferred language and, if your organisation uses one, an employee number (work ID). You also choose an alias in the app.
• Wellbeing answers: your answers about wellbeing, work conditions, stress, resilience and sleep, and your sleep check-ins.
• Calculated results: scores, Care Levels and recommendations calculated from your answers and, if enabled, your measurements.
• Mira: the messages you write to Mira, the AI chatbot in the app, and any Mira answers you choose to save as favourites.
• FaceScan, if you choose to use it: results such as pulse and heart rate variability (HRV). The camera video is processed on your phone and is never stored.
• Wearable data, if you choose to connect a Polar 360 band: heart rate, activity and steps, sleep and overnight heart rate variability.
• Safety information: safety checks triggered by your answers, safety alerts, the consents you give for contact with the confidential helpline or your captain, and your cabin number if you provide it for that purpose.
• Consents: which consents you have given and when.
• App use: the dates and time zone of when you open the app (used for points), your points and your favourites.
• Technical information: the app's build number, a push notification token if your phone registers one, and server logs. Our access log records your user ID, the action and your IP address.

Some of this information is health data, which is a special category of personal data under the GDPR.

We do not use advertising, analytics or crash-reporting tools in the SafeMind app. The FaceScan software from Shen.AI, which is built into the app, may itself collect technical information about your device.

How we collect it

• From your organisation or Previon Nordic, when your account is created, individually or by file upload.
• From you, when you answer questions, write to Mira or change settings.
• From your phone's camera, only when you choose to use FaceScan.
• From a Polar 360 band over Bluetooth, only when you choose to connect one.
• Automatically, when the app communicates with our servers.

Why we use it and our legal basis

• To provide check-ins, personalised assessments, Care Levels, recommendations and safety-related support. Legal basis: your explicit consent (GDPR Articles 6(1)(a) and 9(2)(a)).
• To create and administer your account, let you log in and deliver the service agreed with your organisation or with you. Legal basis: our legitimate interest in delivering the agreed service (Article 6(1)(f)) or, if you have access directly from us, our agreement with you (Article 6(1)(b)).
• To keep the app and our systems secure, prevent misuse and fix errors. Legal basis: our legitimate interest in security (Article 6(1)(f)).
• To keep records we are required by law to keep. Legal basis: legal obligation (Article 6(1)(c)).

We do not use health data for advertising, marketing or data mining, and we do not sell personal data.

You are not legally or contractually required to provide health information. Without your consent to the processing of health data, SafeMind cannot give you personalised assessments and recommendations.

Automated results, Mira and safety

SafeMind combines your answers, and measurements where you have enabled them, using predefined rules to calculate Care Levels and choose recommendations. These are support indicators, not medical diagnoses, and they are not used to make employment decisions.

Mira is an AI chatbot, not a doctor or a human adviser. Its answers may be imperfect.

Some answers may trigger a safety check. If an urgent concern is confirmed, authorised Previon personnel receive a limited alert containing your user ID, the time and the alert type, not your detailed answers or scores.

SafeMind is not an emergency service and is not continuously monitored by a clinician. An alert does not guarantee immediate contact. If you need urgent help, use the ship's emergency procedures, call your local emergency number or seek medical help immediately.

Who can see your information?

• Your employer and captain do not see your individual answers, scores, Care Level, measurements or Mira conversations.
• Administrators in your organisation, and your captain, can see the user or crew list: name, email address, role, language and work ID. They do not see health data.
• Your organisation sees group-level statistics only. No statistics are shown for a group with fewer than 10 active users.
• Previon contacts the confidential helpline on your behalf, or tells your captain that you need safety support, only if you give a separate, specific consent at the time. A captain notification contains only your identity, cabin number, the time and the need for safety support, not your answers or results.
• You can contact the confidential helpline yourself at any time, without sharing anything through SafeMind.
• Authorised Previon personnel and our service providers have access only where needed to run and support the service.

Service providers

We use the following service providers to run SafeMind:

• Amazon Web Services (AWS), Ireland: hosting, database, logs and login emails. Where safety alerts by text message or phone call to Previon's response team are in use, these are also sent through AWS, with calls routed via Frankfurt, Germany.
• TRX: operation and support of the SafeMind platform.
• OpenAI: processes the messages you write to Mira. Messages are sent with storage switched off. OpenAI may keep them for up to 30 days to monitor for abuse, after which they are deleted.
• Shen.AI: FaceScan software, if you use FaceScan.
• Apple: push notification service, if push notifications are registered on your phone.

Polar: when your Polar 360 band syncs, your phone checks Polar's server for firmware updates. This sends the band's ID, its firmware and hardware version and your phone's IP address to Polar. No wellbeing or health data is sent to Polar, and you do not need a Polar account.

We require every service provider and third party that processes personal data from SafeMind to provide the same or equal protection of your personal data as described in this policy.

International transfers

Core SafeMind data are stored with AWS in the EU (Ireland).

Messages to Mira are processed by OpenAI in the USA. This transfer is covered by OpenAI's data processing agreement, which includes the EU Standard Contractual Clauses.

If push notifications are used, the push token is handled by Apple's push notification service, which may involve processing outside the EU/EEA.

You can request information about the safeguards we use by contacting kontakt@previonnordic.dk.

Data stored on your phone

So that the app can work offline, some data are stored on your phone: your login token (in the phone's secure keychain), your profile (name, email address and vessel), answers waiting to be sent, your latest status, drafts, FaceScan results, sleep check-ins, safety consents and cabin number, data from your band and downloaded media.

Logging out removes most of this data, but not band data, the app's device log or downloaded media. Deleting the app removes the app's data from your phone. On iPhone, the login token may remain in the keychain for up to 90 days after the app is deleted.

How long we keep your data

• Account and app data are kept for as long as your account is active. They are deleted when you ask us to delete your account, or when your organisation asks us to close it.
• Mira conversations are not stored on our servers. Mira answers you save as favourites are stored with your account.
• Backups are kept for 14 days.
• Access logs (user ID, action and IP address) are kept for 365 days. Other app logs, without IP addresses, are kept for 30 days.
• If the law requires us to keep certain information for longer, we keep only that information, and only for as long as required.

Your rights and choices

You have the right to:

• request access to the personal data we process about you;
• request correction of inaccurate information;
• request deletion of your personal data and your account;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive your data in a portable format;
• withdraw your consent at any time;
• complain to a data protection authority.

To exercise your rights or withdraw consent, contact us at kontakt@previonnordic.dk. Withdrawing consent stops the processing based on that consent from then on. It does not affect processing that took place before, but personalised features may stop working.

FaceScan and wearable data are only processed if you choose to use these features.

We may need to verify your identity, for example by replying to the email address linked to your account. We respond within one month.

Deleting your account

You can ask us to delete your SafeMind account and the data linked to it at any time, without using the app.

How to delete your SafeMind account

Security

We use technical and organisational measures intended to protect personal data against unauthorised access, loss, misuse, alteration or disclosure, including access control, secure hosting in the EU and supplier management.

Complaints

You can complain to the Danish Data Protection Agency (Datatilsynet) or to the data protection authority where you live or work.

Changes to this policy

We update this policy when the app or our processing of personal data changes. The latest version is always available on this page.

Last updated: 29 October 2026