Privacy Policy
Last updated March 2026
Who we are
Formulate is operated by Formulate Tools Ltd, a company registered in England & Wales (Company No. 17065550), registered address 11 Chantry Close, TW16 7TH.
Formulate is a platform of interactive clinical psychology tools and worksheets for use by qualified healthcare professionals. For data protection queries, contact privacy@formulatetools.co.uk.
What data we collect
Therapist account data
Email address, full name, organisation name (optional), subscription status, and usage data (which worksheets accessed, when, and frequency).
Client label data
Pseudonymised client labels (initials or case codes) assigned by the therapist. The platform enforces pseudonymity through validation. Formulate cannot identify clients from their labels.
Worksheet response data
Clinical content entered by clients via homework links. This data is pseudonymous. Only the assigning therapist can view response data. Formulate does not access, review, analyse, or use response data for any purpose other than storage and display to the therapist.
Technical data
IP addresses (for security), device and browser information (for compatibility), and strictly functional cookies (authentication session only). No analytics cookies, no advertising cookies, no third-party tracking.
Legal basis for processing
| Data type | Legal basis |
|---|---|
| Therapist account data | Contract (Art. 6(1)(b)) |
| Subscription/payment data | Contract (Art. 6(1)(b)) |
| Usage analytics | Legitimate interests (Art. 6(1)(f)) |
| Client labels | Legitimate interests (Art. 6(1)(f)) |
| Worksheet responses | Legitimate interests as processor (Art. 6(1)(f)) |
| Audit logs | Legal obligation (Art. 6(1)(c)) + Legitimate interests |
Special category data
Worksheet response data may constitute health data under Article 9. Our legal basis is Article 9(2)(h) — processing necessary for health care provision under a health professional's responsibility.
Data sharing
We share data with Stripe (payment processing), Supabase (database hosting), and Vercel (application hosting). We do NOT sell data, share clinical data with third parties, use clinical data for advertising, or train AI models on worksheet responses.
Data retention
Active account data is retained while the account is active plus 90 days after deletion request. Worksheet responses are retained while the therapeutic relationship is active. Therapists can permanently delete client data at any time via the GDPR erasure function. Audit logs are retained for 7 years.
Your rights
Under UK GDPR, you have the right to access, rectify, erase, restrict processing of, and port your data, and to object to processing. Contact privacy@formulatetools.co.uk. We will respond within 30 days.
Client rights
Clients who complete homework worksheets can exercise their rights by contacting their therapist. The therapist can delete all data associated with a client using the platform's GDPR erasure function.
Cookies
Formulate uses only strictly necessary cookies for authentication session management. No cookie consent banner is required under UK PECR for strictly necessary cookies.