Privacy Policy
You call. A real human being picks up for eight minutes. Your call is not recorded. No audio of you is stored, and no-one can ever play your call back.
Afterwards you get an Emotional Receipt — a short note in your Blu Bud's voice, written automatically after every call. That is the product, it happens either way, and it is never shared with anyone outside HeyBlu.
What starts switched off is continuity — whether a Blu Bud may read your past notes before a later call, so you never have to retell a hard story from scratch. One switch turns it on: Let my Bud catch up first, in You → What we remember. Turn it back off and the continuity copies are deleted. There is no button to edit or pick individual ones out — continuity stops working if the record is half-there — but you can always ask us at privacy@heyblu.co to correct or delete any single summary, and we will.
The one exception is safety. If your Blu Bud believes you or someone else is at risk of serious harm, they will stay on the call for as long as it takes, at no charge — and we may keep the minimum information needed to help keep someone safe.
"We don't keep your conversations. The only exception is when someone's safety is at risk — then we keep only what's needed to help keep them safe."
Blu Buds are trained, warm, non-clinical humans. They are not therapists, counsellors, doctors, or emergency responders, and HeyBlu is not therapy, medical advice, or a substitute for care.
If you are in immediate danger, contact your local emergency service. The app shows the right numbers for the country you're in. In Singapore: emergency 995, police 999, and the Samaritans of Singapore (SOS) 24-hour line 1767 or CareText on WhatsApp 9151 1767. In the US: 911, and 988 for the Suicide & Crisis Lifeline. In the UK: 999, and Samaritans on 116 123.
Section 1What we collect
Only what the product actually needs to work.
| What | Why we have it | How long |
|---|---|---|
| Your phone number | It's how a Blu Bud reaches you and how you reach them | While your account is open |
| Your first name (or whatever you tell us to call you) | So a human can say hello properly | While your account is open |
| Your date of birth | Checked once at sign-up to confirm you're 18+ | Not retained — we keep the fact that you passed, plus the date and method of the check |
| Your check-in window — mornings, Sunday evenings, late nights | To know when not to bother you, and when a nudge might help | Until you change it |
| Connect records — date, time, length, which Blu Bud, how it started | Billing, your own history, and paying Blu Buds fairly | 5 years (Singapore tax and accounting) |
| Emotional Receipts — the note written for you after a call | So the call leaves something behind for you | Until you ask us to delete it |
| Working text of a call — created only to write the summary | It's how the summary gets written (section 2) | Currently retained — automatic deletion is being built (section 2) |
| Conversation summaries — a brief summary written after a call | Continuity between conversations, so you don't start from zero | Only while continuity is on — 12 months from the call, or 30 days after you switch it off |
| My Blu Bud memory — a short profile note your matched Bud keeps | So you don't start from zero every week (section 3) | Until you switch Buds |
| Safety records — only if the safety exception applies | To help keep you or someone else safe (section 7) | As long as safety and law require, and no longer than 7 years |
| Feedback ratings — "not really / it helped / really did" | To support and coach Blu Buds | De-identified after 90 days |
| Payment records | Charging you correctly and not twice | Held by our payment processor; 5 years for receipts |
| Basic device and app diagnostics | Fixing crashes and bad call quality | 30 days |
We do not sell your personal information. Nothing you say on a call, and nothing in your receipts or summaries, is ever used for advertising or shared with an advertising network. Our public website uses ordinary web analytics, which see visits to the website — never your calls, your receipts, or anything inside your account.
Section 2Calls, recordings and conversation summaries
Your call is not recorded. No audio file of your call is stored. Nobody — not your Blu Bud, not a supervisor, not us — can listen to your call again, because there is nothing to listen to.
After a call, HeyBlu may create a brief conversation summary to help provide continuity in future conversations. The summary is written automatically, by software, not by a person taking notes.
Relevant conversation summaries may be used to provide continuity in future conversations — which means a Blu Bud may read them before or during a later call, so you don't have to explain yourself twice.
We would rather over-explain this than have you find it out later, so the next few paragraphs say exactly how that works.
How a summary actually gets made — and what that means
To write a summary automatically, our system has to convert the spoken call into text first. So, honestly and in order: the call audio is processed as it happens, a working text of the conversation is produced, that text is used to generate the short note that becomes your receipt, and the note becomes your receipt, and is also kept as a continuity copy if you have turned continuity on. The working text is not yet deleted afterwards — see below.
For a brief moment, a machine does hold the words of your call. We are not going to hide behind "we don't transcribe" — a working text is a transcript, even a short-lived one, and you deserve to know it exists.
We are not going to state this as a promise we have not finished building. Today the working text is kept. The speech-to-text files stay in our storage, the transcript can be saved alongside your receipt, and fragments of it can appear in our server logs. It is never used to train any AI model, and nobody reads it as part of how the service runs — but staff with production access could. Automatic deletion once your receipt exists is being built. Until it ships, this is the accurate position, and you should have it rather than a sentence that reads better.
Your receipt is written every time. Continuity starts off — the Let my Bud catch up first switch in You → What we remember. While it is off, the note becomes your receipt and no continuity copy is kept, so no Blu Bud reads anything about your past calls. Turn it on and a continuity copy is kept and may be read by a Bud; turn it back off and those copies are deleted within 30 days. It is always available and never costs you anything.
What a summary is — and what it isn't
A few sentences: what you were carrying, a handful of tags, what seemed to help, and anything you asked to be remembered for next time. Roughly the length of a postcard.
A recording, a verbatim account, a quote of what you said, a clinical note, or an assessment of you. And because software wrote it, it is an interpretation of your call rather than a faithful record of it — see "it can get you wrong" below.
Which Blu Bud can read them
This depends on your plan, and the difference matters — so the switch is always yours. Continuity starts off everywhere — what you talk about here is sensitive, and another person arriving already knowing it should be a decision you make rather than one you discover. Your receipt is unaffected either way. The rows below describe who can read your past notes once you have turned continuity on.
| Your plan | Who can read your past summaries |
|---|---|
| My Blu Bud | Your own matched Blu Bud, whoever covers for them when they're off shift, and any new Blu Bud you switch to — so you don't have to retell your story. |
| Pay-as-you-go and the weekly check-in | Whoever picks up — which is a different person each time. If you turn continuity on, that applies here too, so you're not repeating yourself to a new person every week; leave it off and every call starts fresh. |
| Any plan, continuity off | Nobody. Every call starts fresh, and any existing summaries are deleted within 30 days. |
Switch it either way at any time — the Let my Bud catch up first switch in You → What we remember. Switching it off stops new summaries being written, stops existing ones being read by anyone, and deletes them within 30 days.
What you can see, and what you can change
You are not kept in the dark about what's held on you — but we should be exact about the shape of it.
What the summary holds reaches you as your Emotional Receipt after every call — what you set down, what you carried out, and a line in your Blu Bud's voice. That is the summary's substance, written to be read by you rather than filed about you.
The switch. Summaries are on or off, and that choice is entirely yours, changeable at any moment, with deletion following within 30 days when you switch off.
The app gives you no way to rewrite a summary or remove one call's summary while keeping the rest. A continuity record that can be selectively edited isn't continuity — the next Blu Bud would be reading something neither of you could trust. So in the app it is all on, or all off. That is a product limit, not a limit on your rights: ask us at privacy@heyblu.co and we will correct or delete any individual summary, without asking you to justify it.
If a receipt reads wrong to you — badly wrong, not just clumsy — tell us at privacy@heyblu.co. We will look at it, and where something is inaccurate we will put it right or remove it. That is your right under data-protection law and we're not going to make you fight for it; it simply runs through a person rather than a button.
Nobody else ever sees it
Conversation summaries are never shared with anyone. Not with your employer, not with family, not with anyone who gifted you a Connect, not with advertisers, not with researchers, and never sold — to anybody, for any price. Inside HeyBlu they reach exactly one kind of person: a Blu Bud about to talk to you, and only while your switch is on. The AI provider that writes them cannot keep them or train on them (see below).
Nobody listens in
No human listens to your call except the Blu Bud you're talking to. Supervisors do not listen to live calls and cannot listen afterwards, because no recording exists. Quality and coaching reviews look at the record of a call — when it happened, how long it ran, how you rated it — and never its content. The one exception is an escalated call, where a supervisor may join to help; you will know, because they will say so.
The automated step described above is the only thing that ever "hears" your words other than your Blu Bud, and it is a machine that keeps nothing.
The people and companies that carry the call
HeyBlu calls run over a real-time voice service rather than a traditional phone network. That provider carries the call and produces the speech-to-text your receipt is written from; it is contractually barred from using your data for its own purposes. Blu Buds may not record calls, take screenshots, or keep private notes or copies of anything you said — it is a disciplinary matter and a breach of their contract with us.
The AI provider. The automated summarising step runs on a specialist provider's service. That provider acts on our instructions only, is contractually barred from using your data to train its models, and retains it only briefly for its own abuse monitoring. It is named in the list we keep at heyblu.co/subprocessors so you can see who it is and when it changes.
If a check-in call goes unanswered, we don't leave a voicemail containing anything personal about you.
It can get you wrong
Software writing a summary of a hard conversation will sometimes miss the point, overstate something, or flatten a nuance that mattered. So a summary is never treated as a factual record of you, is never used to make any decision about you, and never leaves the small circle in section 6. Your receipt shows you what it holds; if it reads badly wrong, email privacy@heyblu.co and a person will fix or remove it. And if the whole idea sits badly with you, the switch is right there.
Two things this costs you, said plainly
Because there's no recording, we usually cannot investigate a dispute about what was said on a call — we can only act on what both people tell us. And because a summary is generated rather than remembered, it is an approximation; you can't edit it, but you can switch the whole thing off, and you can always ask us to correct something that's genuinely wrong.
The single exception to everything in this section is the safety exception in section 7.
Section 3Emotional Receipts and continuity
Two different things get written after a Connect, and it's worth knowing which is which.
| Emotional Receipt | Conversation summary | |
|---|---|---|
| Written for | You | Continuity — so a Blu Bud can catch up |
| You see it | Yes, it's the point | Its substance reaches you as the receipt |
| A Blu Bud sees it | Only while continuity is switched on | Only while continuity is switched on |
| You can edit or delete it | Delete on request — always granted | No — but you can switch summaries off |
| Kept | Until you ask us to delete it | 12 months, or 30 days after you switch off |
The receipt is the keepsake: what you set down, a few tags, what you picked up, and a line from your Blu Bud. Neither one is a transcript.
- The receipt is yours. You can read your receipts any time in Your history. Ask us at privacy@heyblu.co to delete any of them and we will, without asking why — the words go, and we keep only the bare billing fact that a Connect happened.
- Neither is shared. Not with employers, not with family, not with anyone who gifted you a Connect — and never sold to anyone.
- Continuity works by a switch, not by editing. Off means no continuity copy is kept, nobody reads your past notes, and existing copies are deleted within 30 days. Your receipt still arrives after every call. See section 2.
- If you're on My Blu Bud, your matched Blu Bud can see a defined, limited set of things — nothing else.
- Changing your Blu Bud doesn't cost you your story. Your summaries belong to your account, not to any one Bud — so a new Blu Bud starts already knowing the shape of what you've been carrying, and you never have to tell it from the beginning again. What ends with the old Bud is their own private profile note about you; the summaries carry over. If you'd rather a new Bud started with a blank page, switch summaries off before you change.
| Your Blu Bud can see | Your Blu Bud cannot see |
|---|---|
| Your first name and check-in window | Your payment details, plan price, or billing history |
| Your past Emotional Receipts and their tags | Any recording of your call — none exists |
| Conversation summaries from your past calls — only while continuity is on | The working text a summary was written from — deleted |
| A short profile note they write themselves | Your BluBucks balance or gifting activity |
| The dates and lengths of your past Connects | Your date of birth |
| Anything you've asked them to remember | Your feedback ratings of them, or of other Buds |
| Whether you've switched continuity on | Past safety records — restricted to the safety team |
Section 4Timing, nudges and check-in calls
HeyBlu notices patterns in when you reach out — not what you said. If you tend to call late on Sundays, we may nudge you Sunday afternoon, before it gets loud.
- This uses call timestamps only.
- Predictive nudges and inbound check-ins are opt-in, and you can switch them off at any time in You → Your check-in. Turning check-in calls on is your express consent to be called on the number you gave us, where the law of your country requires that consent; it covers these calls only, never marketing, and you can withdraw it in the app or by telling your Blu Bud.
- Letting a check-in ring out is never held against you and is never recorded as a missed anything.
Section 5How we use what we hold, and our legal grounds
To connect your calls; to charge you correctly; to write your receipts and summaries; to keep your BluBucks balance; to match you with a Blu Bud; to support, coach and pay our Blu Buds; to fix the app; to meet legal and tax obligations; and to keep people safe under section 7. That's the list.
Our legal grounds. We are a Singapore company, so the Personal Data Protection Act 2012 (PDPA) is our baseline: we collect, use and disclose personal data with your consent, or where the PDPA permits it without consent — including the exception that allows disclosure where it is necessary because a person's life, health or safety is at risk (section 7).
Where the UK/EU GDPR also applies to you, our bases are: contract for calls, receipts and billing; consent for nudges, check-in calls, conversation summaries and My Blu Bud memory; legitimate interests for security, fraud prevention and product reliability; legal obligation for tax and accounting records; and vital interests for the safety exception. Because what you talk about can reveal something about your health or state of mind, we treat receipts, summaries and safety records as sensitive and handle them on the narrower grounds available for such data — your explicit consent, or, for the safety exception, the protection of someone's vital interests together with the safeguarding condition that UK and EU law provides for people at risk. Your receipt rests on contract — it is the service you bought. Continuity is the part that rests on explicit consent, and it starts off for everyone, so turning it on is the affirmative act that gives that consent; withdraw it at any time and existing summaries are deleted within 30 days. Automated summarising happens only while that consent is switched on, produces no decision about you, and can be switched off at any time. Where local law gives you stronger protection than this policy, that law applies.
Section 6Who else sees it
- Your Blu Bud — the list in section 3, and nothing beyond it.
- Supervisors — on escalated calls, and on quality reviews of the record of a call, never its content (section 2).
- Service providers — telephony, payments, cloud hosting, error reporting, and the AI provider that writes conversation summaries (section 2). They act on our instructions, under contract, cannot use your data for their own purposes, and cannot use it to train AI models. Some hold it briefly for security and abuse monitoring before deleting it. The current list is at heyblu.co/subprocessors.
- Emergency services — only under section 7.
- Legal — where we're compelled by valid legal process. We will tell you unless we're legally barred from doing so.
If Unbroken Consulting Pte. Ltd. is ever acquired or restructured, these promises travel with the data, or the data is deleted.
Section 7The safety exception — the one limit on all of the above
The eight-minute limit is a product boundary. It is never a safety boundary.
If a Blu Bud believes you or someone else is at risk of serious harm, three things happen. They stay on the call for as long as it takes. Nothing is charged — the meter is off in the product, not just in policy, and no payment, upgrade or minute prompt is shown to you. And we keep only what is needed to help keep someone safe.
In that situation we may create and retain a safety record: what the concern was, what was said about risk, any location or contact detail needed to get help to you, what action was taken, and the supervisor involved. Where there is a risk to life, we may share that record with emergency services, a crisis service, or a support person you name. Where the law requires it, we may report a risk to a child or a dependent adult.
Because HeyBlu runs by phone across borders, we may need to ask where you are in order to reach the right emergency service, and we cannot always locate you if you're unable or unwilling to tell us. We won't pretend otherwise: in that situation your Blu Bud stays with you and works with you on the next best step.
Safety records are stored separately with restricted access, are never used for marketing or product analytics, and are retained for as long as needed for the person's safety and our legal obligations, and in any case no longer than seven years, reviewed annually, after which they are deleted unless a live legal obligation requires otherwise. Blu Buds recognize and route; they do not diagnose, treat, or take clinical responsibility. We will always try to tell you what we did and why.
Section 8If your employer pays for HeyBlu
Your employer buys access to HeyBlu. It never buys visibility into who used it, or why. Your employer never learns whether you called, when you called, who you spoke to, what you said, or that a call was escalated — not HR, not your manager, not the benefits contact, and not through aggregate reporting timed closely enough to identify anyone.
Escalation runs to emergency services and to your own chosen supports. Never to your employer. This is a condition of every enterprise contract.
Section 9Retention and deletion — what closing your account does
There is no single deletion promise, because some records we are legally required to keep. Here is the exact position when you close your account.
| What | On account closure | Why |
|---|---|---|
| Call audio | Nothing to delete | Never recorded |
| The working text a summary was written from | Nothing to delete | Already deleted when the summary was written (section 2) |
| Emotional Receipts and tags | Deleted within 30 days | Yours, and only yours |
| Conversation summaries | Deleted within 30 days | Continuity only — no reason to keep them after you leave |
| — or when you switch summaries off | Deleted within 30 days | The switch is the control (section 2) |
| My Blu Bud's private profile note | Deleted immediately | Ends with that Bud — also when you simply switch Buds |
| Name, phone number, check-in window | Deleted within 30 days | No longer needed |
| Feedback ratings | De-identified, kept in aggregate | Blu Bud coaching; no longer linked to you |
| Diagnostics | Deleted within 30 days | A rolling 30-day window anyway |
| Billing and tax records — dates, amounts, invoices | Kept 5 years | Required by Singapore law; never includes what you talked about |
| Safety records (section 7) | Kept as long as safety and law require | Legal obligation and duty of care; restricted access |
So: "we delete your data" is true of everything about you and your conversations. It is not true of the bare financial record that a payment happened, or of a safety record — and we'd rather say that here than surprise you later.
Section 10Your rights and controls
Wherever you live, you can ask us to show you what we hold, correct it, delete it, or send you a copy — and you can withdraw consent for nudges, check-ins, conversation summaries and Bud memory at any time without losing access to calls. Depending on where you live you may also have rights to limit certain uses, to opt out of "sharing" (we don't sell or share for cross-context advertising), and to appeal a refusal. We won't treat you worse for exercising any of this.
Conversation summaries, specifically. There is no per-summary button in the app — section 2 explains why, and gives you the switch instead. Your legal rights are untouched by that: ask us and we will correct or delete any individual summary. If a receipt is genuinely inaccurate, email privacy@heyblu.co and a person will correct or remove it; you don't have to justify the request.
In-app: You → What we remember for the summaries switch; You → Your check-in for nudges and check-ins; Your history to read your receipts; You → Manage plan for billing. Deletions and corrections go through privacy@heyblu.co so a person handles them — we respond within 30 days, and usually the same day.
If we get it wrong, tell us first — most things are fixed in a day. You can also complain to the Personal Data Protection Commission of Singapore (pdpc.gov.sg). UK/EU users may complain to their local supervisory authority instead.
Section 11Security, age and international transfers
Traffic between you and HeyBlu runs over TLS, and the files we hold in cloud storage are encrypted at rest with AES-256. Our production database and server storage are not yet encrypted at rest, and our access records are partial rather than a complete audit trail. Both are being addressed, and we would rather say so than claim a standard we have not finished. Access to production is restricted to a small technical team, protected by key-based authentication and an allowlist of approved locations. Not recording conversations remains our strongest security control. No system is perfect — and where a breach affects your personal data, we will notify the relevant authorities within the time the law allows — the Personal Data Protection Commission within 3 calendar days of assessing a notifiable breach, and, where the UK or EU GDPR applies, the supervisory authority within 72 hours — and we will tell you as soon as practicable.
HeyBlu is for adults — 18 and over. We ask for your date of birth when you create an account and check it once; we keep the fact that you passed, and the date and method of that check, but not your date of birth. We don't knowingly collect anything from children. If we learn a minor is using HeyBlu, we close the account and delete the data, except where a safety record must be kept.
We are a Singapore company and your information is processed in Singapore and in other countries where our service providers operate. When personal data leaves Singapore we require a comparable standard of protection by contract, as the PDPA obliges us to; where data is transferred out of the UK/EU we rely on approved mechanisms such as the UK IDTA or EU Standard Contractual Clauses.
Section 12Where you live
HeyBlu is run from Singapore and available in most countries. Data-protection law differs by where you are, so this section says what you get on top of everything above. Where your local law gives you more than this policy, your local law wins — that isn't a courtesy, it's how we've built it.
The baseline, everywhere
Wherever you live you can ask us to show you what we hold, correct it, delete it, or send you a copy; withdraw any consent you've given, including the summaries switch, without losing access to calls; and complain to us or to your regulator. We won't treat you worse for any of it. One address does all of it — privacy@heyblu.co — and we answer within 30 days, usually the same day.
If you are in the United States
We are not a healthcare provider, a health plan, or a clearinghouse, and we don't bill insurance. People assume otherwise, so we'd rather say it plainly: your protection here comes from this policy and from state consumer-health-data law, not from HIPAA.
We treat what you tell us as health data. Most US states treat mental-health status — and the fact that you sought support at all — as sensitive information that needs your opt-in. So receipts, summaries and safety records are handled that way. Your receipt is part of the service you asked for and arrives either way; continuity — another person reading your past notes — starts off until you turn it on.
We do not sell or share it. We don't sell your personal information or your consumer health data, we don't share it for cross-context behavioral advertising, and we don't use it for targeted advertising or profiling. There is nothing here to opt out of — but the right exists, and we honor universal opt-out signals such as Global Privacy Control anyway.
| Your right | What it means here |
|---|---|
| Know | What we collect, why, where it came from and who receives it. Section 1 is that disclosure, by category. |
| Access | A copy of what we hold about you. |
| Correct | Anything inaccurate — including an individual summary or receipt. |
| Delete | We delete, and we tell our processors to. Section 9 sets out the little we must keep and why. |
| Portability | A copy in a portable, machine-readable form. |
| Limit sensitive information | Restrict use of sensitive personal information to providing the service you asked for. Ask us and we will. |
| Withdraw consent | The summaries switch, the nudges switch, or an email. Calls keep working either way. |
| Appeal | If we refuse, we say why, and a different person reviews it within 45 days. |
| No retaliation | Your price and your service don't change because you exercised any of this. |
Timing. We acknowledge within 10 business days and answer within 45 calendar days, extendable once by a further 45 if we tell you why. If we refuse in whole or part, we name the exemption we relied on.
Someone acting for you. You can use an authorized agent. We'll ask them for written permission from you, and we may ask you to confirm it directly — that check protects you, not us.
Washington and Nevada. Their consumer-health-data laws give you a specific right to withdraw consent and to have consumer health data deleted; we honor deletion within 30 days and pass the instruction to our processors. We never sell consumer health data, so the separate written authorization those laws require for a sale never arises. We don't operate geofences around health facilities of any kind. Washington also requires a separate consumer health data privacy policy, published at heyblu.co/health-privacy.
If a breach happens. Where the FTC Health Breach Notification Rule applies, we notify you and the Federal Trade Commission within the time that Rule requires — including for an unauthorized disclosure, not only a security failure.
Complaints. Tell us first; most things are fixed in a day. You can also contact your state Attorney General.
If you are in the UK or EU
Section 5 sets out our legal bases and section 10 your rights. The summaries switch starts off, so turning it on is the explicit consent Article 9 requires, and withdrawing it deletes what was written. HeyBlu is not currently offered in the UK or the EEA. If that changes, our Article 27 representatives will be appointed and named in section 13 before launch.
If you are in Singapore
The PDPA is our baseline throughout this policy. If we get something wrong, tell us — and you can complain to the Personal Data Protection Commission at pdpc.gov.sg.
Everywhere else
The baseline above applies to you as written. Any stronger right your own law gives you applies on top of it, and you can always complain to your national regulator as well as to us.
Section 13Changes, and how to reach a human
If we change this policy in a way that materially affects you, we'll tell you in-app and by message at least 30 days before it takes effect, and you can close your account rather than accept. Small clarifications we'll just publish with a new date. We'll never quietly weaken the promises in sections 2, 7 or 8 — those change only with clear, prominent notice.
- Company
- Unbroken Consulting Pte. Ltd. · UEN 202511691N
68 Circular Road, #02-01, Singapore 049422 - Privacy
- privacy@heyblu.co
- Data protection officer
- Jet Domingo · jet@mindnation.com · 68 Circular Road, #02-01, Singapore 049422
- EU / UK representatives (Art 27)
- Not applicable at launch — HeyBlu is not currently offered in the EEA or the UK. Representatives will be appointed and named here before any launch in those regions.
- Safety concerns
- safety@heyblu.co
- General
- hello@heyblu.co
- Terms
- heyblu.co/terms — a separate document
- In an emergency
- Your local emergency number
Singapore 995 · SOS 24h 1767
US 911 / 988 · UK 999 / 116 123 - Version
- 1.6 · effective 14 August 2026 (supersedes v1.5)
This policy describes how the HeyBlu product actually behaves as built. Five things must be true inside the company before it governs live calls: the operational escalation SOP behind section 7, with clinical sign-off; enterprise contracts and architecture that deliver the firewall in section 8; a completed Data Protection Impact Assessment for the summarising pipeline; an Appropriate Policy Document covering the safeguarding basis for safety records; and appointed UK and EU representatives. Because HeyBlu launches globally, it should be reviewed by qualified counsel in each market before it opens there, and the separate consumer health data privacy policy that Washington State requires must be published before any US user is onboarded. It should also be reviewed by qualified counsel in each market where HeyBlu is offered.