Privacy Policy

Effective date: June 25, 2026
Last updated: June 25, 2026
Version: 1.0

1. Introduction

This Privacy Policy explains how Pink Elephant, Unipessoal Lda, operating the States of Mind platform, collects, uses, stores, discloses and protects personal data when individuals visit the States of Mind website, subscribe to communications, create or use a community account, participate in the community, complete a mental-health self-assessment or educational quiz, or use the AI Navigator.

States of Mind provides educational content, community features, self-assessment tools and content-navigation services relating to mental health, wellbeing and psychedelic-related topics. States of Mind is not a healthcare provider, does not provide medical advice, diagnosis or treatment, and is not a substitute for professional assessment or care.

2. Controller

The controller responsible for the processing described in this Privacy Policy is:

Pink Elephant, Unipessoal Lda
NIPC 519056582
Edifício Amoreiras Square
Rua Carlos Alberto da Mota Pinto, no. 17, second floor
1070-313 Lisboa
Portugal

Privacy enquiries and requests to exercise data-protection rights may be sent to:

privacy@pink-elephant.co

3. Scope of this Privacy Policy

This Privacy Policy applies to personal data processed through the States of Mind website, website analytics, newsletter, members-only community, mental-health self-assessments and educational quizzes, and AI Navigator.

4. Age eligibility

States of Mind is intended only for persons who are at least 18 years old, or the age of majority in their jurisdiction if that age is higher.

States of Mind does not knowingly collect personal data from persons under 18. A person under 18 must not create a community account, complete a mental-health assessment, use the AI Navigator, subscribe to the newsletter or otherwise submit personal data through the platform. If we learn that personal data has been collected from a person under 18, we will take reasonable steps to delete it, subject to any applicable legal obligation.

5. Sources of personal data

We collect personal data directly from individuals when they subscribe to the newsletter, register for the community, publish community content, communicate with other members, participate in an event, complete an assessment or quiz, or use the AI Navigator.

We also collect certain technical and usage information automatically through Amplitude and Google Analytics where the user has given analytics consent.

Community account and participation data may be received through Circle. Assessment and AI Navigator data may be generated from the answers, messages and preferences submitted by the user and from results or recommendations generated through the relevant feature.

6. Website analytics and Session Replay

Where the user has given prior analytics consent, States of Mind uses Amplitude and Google Analytics to understand website use, improve functionality and user experience, identify technical issues and analyze navigation patterns.

The analytics data may include an IP address to the extent processed by the relevant provider, device and browser information, analytics and session identifiers, page URLs, page views, referral source, click, scroll and navigation events, timestamps, coarse location data where derived, and the user’s consent status.

Amplitude Session Replay may record interactions on permitted pages. Session Replay is limited to pages approved for replay and masking is applied. States of Mind does not use analytics or Session Replay for the purpose of collecting assessment answers, community content, AI Navigator conversations, login credentials or other special-category data.

The legal basis for analytics and Session Replay is Article 6(1)(a) GDPR, consent. Amplitude and Google Analytics must not be activated until the user has given the required consent. Consent may be refused or withdrawn without affecting access to the non-analytics functions of the website.

Amplitude Session Replay data is retained for 30 days. Amplitude event-level analytics data is retained for 14 months. Google Analytics user- and event-level data is retained for 14 months, or the shortest available setting consistent with the documented analytics need. Genuinely anonymized aggregate statistics may be retained after anonymization.

7. Newsletter subscriptions

If a user subscribes to the States of Mind newsletter, we process the email address, subscription status, date, time, source and version of consent, withdrawal or unsubscribe date, and email delivery or bounce metadata.

The purpose of this processing is to send newsletters and educational updates requested by the subscriber.

The legal basis for newsletter subscription and delivery is Article 6(1)(a) GDPR, consent. The legal basis for retaining the minimum suppression record necessary to ensure that an unsubscribed person is not contacted again is Article 6(1)(c) GDPR, compliance with legal obligations relating to direct-marketing preferences.

Brevo, operated by Sendinblue SAS, is used as the newsletter and email-delivery processor.

The active subscriber record is retained while the subscription remains active. Following withdrawal or unsubscribe, newsletter engagement and delivery records are deleted in accordance with the applicable operational retention schedule. A minimum suppression record consisting of the email address, opt-out status and opt-out date may be retained for as long as necessary to prevent further direct-marketing communications and demonstrate compliance.

Subscribers may withdraw consent at any time by using the unsubscribe link in an email or by contacting privacy@pink-elephant.co.

8. Community registration and authentication

If a person registers for the States of Mind community, we process the email address, community user ID and login information needed to create and manage the community account, authenticate the member and provide access to members-only features.

The legal basis is Article 6(1)(b) GDPR, because the processing is necessary to provide the community account and functionality requested by the member.

The community platform is operated through CircleCo, Inc., which processes account and authentication data on behalf of States of Mind.

Community account data is retained while the membership remains active. Following confirmed account deletion, account data is deleted or anonymized within 30 days. Any security or fraud-prevention record retained beyond that period must be subject to a separately documented purpose, legal basis and retention period.

9. Community participation and moderation

Community members may create and interact with posts, comments and reactions, exchange direct messages or chat messages, participate in live events and AMA sessions, upload attachments or images where enabled, and engage with other community features. The community is presented as a private space for discussion, expert interaction and support concerning mental health, wellbeing and psychedelic-related topics.

We may process the member’s username or display name, profile information, posts, comments, reactions, direct messages, chat messages, event registrations, participation records, attachments, images, timestamps, reports, moderation records and related technical metadata.

The legal basis for providing the community participation features requested by the member is Article 6(1)(b) GDPR. The legal basis for moderation, abuse prevention, enforcement of community rules, security and platform integrity is Article 6(1)(f) GDPR, legitimate interests.

Community content may be visible to other community members. Content shared within live events or AMA sessions may also be visible to the relevant hosts, invited experts or facilitators. Direct messages are visible to their recipients and are processed by the community platform to provide the messaging function.

Where a member voluntarily discloses health, mental-health, treatment, psychedelic-related or other Article 9 special-category information in community content, States of Mind relies on Article 9(2)(a) GDPR, explicit consent. The applicable community flow must provide a separate explicit-consent mechanism before such special-category information is processed.

Members must not submit unnecessary health data or identifying information about another person. Where a member refers to another person, the member is responsible for ensuring that the disclosure is lawful and relevant.

Account-linked community data is deleted or anonymized within 30 days after confirmed account deletion. Private messages and content containing health, special-category or third-party personal data are deleted unless continued retention is necessary for an active legal, safety or moderation matter. Posts and comments may remain only where they have been genuinely anonymized so that the former member and other persons cannot be identified, linked or singled out. Merely removing a username is not treated as sufficient anonymization where the content remains identifying.

Where a community feature permits a member to appear anonymously to other members, this does not necessarily mean that the content is anonymous to States of Mind or Circle, because account and technical information may remain available for account operation, security and moderation.

10. Mental-health self-assessments and educational quizzes

States of Mind offers optional mental-health self-assessments and educational quizzes. The website currently includes screening tools concerning matters such as depression, anxiety, attention, trauma, obsessive-compulsive symptoms, eating-related concerns and other aspects of mental health. The tools provide scores, educational information and suggested next steps, but are not diagnostic instruments and do not replace professional assessment.

Where necessary for a requested result-history or email-delivery feature, we may process a name and email address. We may also process country, age or age range, sex or gender where used by the assessment, submission timestamp, consent record, assessment type and metadata, calculated score and result, recommendation request and response metadata, and email-delivery metadata where results are emailed.

The special-category data processed may include raw screening answers, mental-health indicators, ADHD-related responses, depression- and anxiety-related responses, PHQ-9 or comparable assessment answers and scores, trauma-related responses, obsessive-compulsive or eating-related responses, psychedelic-assisted-therapy interests, treatment interests, self-reported health information, generated assessment outcomes and personalized recommendation inputs and outputs.

Depending on the assessment selected, responses may include highly sensitive information, including information about severe distress or thoughts of self-harm. States of Mind is not an emergency or crisis service. If a user feels unsafe or requires urgent assistance, the user should contact a qualified professional, a mental-health helpline or the applicable emergency service immediately. The website’s screening pages similarly state that the tools are educational and not a diagnosis or substitute for professional care.

The legal basis for the optional assessment and recommendation process is Article 6(1)(a) GDPR, consent. The Article 9 condition for processing mental-health and other health-related data is Article 9(2)(a) GDPR, explicit consent. Consent must be obtained before assessment responses are stored or transmitted to OpenAI.

Assessment results are calculated within States of Mind systems. OpenAI may then be used through its API to generate personalized educational recommendations based on an assessment-related JSON payload. That payload may include information such as age or age range, sex or gender, country, the calculated outcome and other assessment-derived information needed to generate the recommendation. OpenAI Ireland Ltd. acts as processor for this activity.

Raw assessment responses, JSON payloads and OpenAI request data are retained only for the period necessary to calculate and deliver the requested result and for a short operational period necessary for security or troubleshooting. If States of Mind offers a persistent result-history feature, the applicable retention period must be communicated when that feature is enabled. Genuinely anonymized aggregate statistics may be retained after anonymization.

11. AI Navigator

The AI Navigator is an optional AI-assisted website-navigation feature that asks questions or accepts user messages and recommends relevant States of Mind content. It is intended to assist users in finding website resources and does not provide medical advice, diagnosis, mental-health assessment, treatment recommendations or eligibility decisions. The website describes the feature as helping users find a starting path based on what they are looking for.

We may process a user or account ID where the visitor is authenticated, or a session identifier where the visitor is not authenticated, together with messages and responses entered into the AI Navigator, conversation timestamps, conversation and session metadata, content-recommendation outputs, consent records and request/response technical metadata.

Messages may reveal mental-health symptoms, interests or concerns, treatment interests, psychedelic-related interests, health-related information or other special-category data. Users should not enter unnecessary personal data about themselves or another person.

The legal basis for the optional AI Navigator is Article 6(1)(a) GDPR, consent. Where the interaction contains or produces health or other Article 9 information, the applicable condition is Article 9(2)(a) GDPR, explicit consent.

User responses are stored in JSON and sent through the OpenAI API using a States of Mind prompt. OpenAI generates a response intended to direct the user to relevant website content. OpenAI Ireland Ltd. acts as processor for this activity. DigitalOcean or the relevant backend/database provider processes the stored conversation data on behalf of States of Mind.

AI Navigator messages, JSON inputs and outputs are retained only for the active session and any short operational period necessary for security, troubleshooting or a user-requested history feature. If persistent conversation history is offered, the applicable retention period must be communicated when that feature is enabled. Genuinely anonymized usage statistics may be retained after anonymization.

AI-generated content may be incomplete or inaccurate and should not be treated as professional or medical advice.

12. Special-category data

States of Mind processes special-category data only in the circumstances described in this Privacy Policy.

Special-category data may arise where a member voluntarily discloses health or mental-health information in the community, where a user completes a mental-health assessment or screening, or where a user enters health-related information into the AI Navigator.

The relevant Article 9 condition is explicit consent under Article 9(2)(a) GDPR.

A user may decline to provide explicit consent. If explicit consent is not provided or is later withdrawn, the relevant special-category feature may not be available or may cease to operate.

Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

13. Summary of legal bases

States of Mind relies on consent under Article 6(1)(a) GDPR for website analytics and Session Replay, newsletter subscriptions, optional mental-health assessments and the AI Navigator.

States of Mind relies on Article 6(1)(b) GDPR for community account registration, authentication and the community participation functions requested by members.

States of Mind relies on Article 6(1)(f) GDPR for community moderation, abuse prevention, rule enforcement, security and platform integrity.

States of Mind relies on Article 6(1)(c) GDPR for retaining the minimum newsletter-suppression information necessary to comply with opt-out and direct-marketing obligations.

States of Mind relies on Article 9(2)(a) GDPR for the special-category processing described in the community, mental-health-assessment and AI Navigator sections.

14. Recipients of personal data

Personal data may be accessed internally by authorized States of Mind personnel whose roles require access, including product, analytics, communications, community-administration, moderation, support, privacy and security personnel.

Amplitude, Inc. processes analytics and Session Replay data.
Google Ireland Limited processes Google Analytics data.
Sendinblue SAS, trading as Brevo, processes newsletter and email-delivery data.
CircleCo, Inc. processes community account, authentication and community-participation data.
OpenAI Ireland Ltd. processes assessment-related recommendation requests and AI Navigator interactions.
DigitalOcean processes backend, database and hosting data where used.
Cloudflare processes data necessary for website routing, content delivery and security.
An email-delivery provider may process an email address and result-delivery metadata where a user requests assessment results by email. The relevant provider must be identified in the applicable feature notice before that processing begins.
Community content is also disclosed to other community members and, where relevant, event hosts or invited experts according to the space in which the user posts or participates.

We may also disclose personal data where required by applicable law, a court order or a competent authority, or where necessary for the establishment, exercise or defense of legal claims.

15. International transfers

Some processors, affiliates or subprocessors may process personal data outside the European Economic Area.

Amplitude is configured with EU data residency, but non-EEA support, affiliate or subprocessor access may occur. Google Analytics may also involve non-EEA processing or access.
Brevo primarily hosts the relevant newsletter data within the European Union, but some subprocessors may operate outside the EEA.
CircleCo, Inc. is based outside the EEA and processes community account and participation data under its applicable data-processing terms.
OpenAI Ireland Ltd. is the relevant processor for EEA users, but processing, support or subprocessors outside the EEA may be involved.

Where personal data is transferred to a country that has not been recognized as providing an adequate level of protection, we rely on appropriate safeguards, including European Commission Standard Contractual Clauses, applicable Data Processing Agreements and supplementary contractual or technical measures where required.

Information about the applicable transfer safeguards may be requested from privacy@pink-elephant.co.

16. Retention

Analytics and Session Replay data are retained for the periods stated in Section 6.

Newsletter data is retained as described in Section 7.

Community account data is retained while the membership remains active and is deleted or anonymized within 30 days following confirmed account deletion. Community content is handled as described in Section 9.

Assessment data is retained only for the period necessary to provide the requested result and for the limited operational period described in Section 10. A separate retention period applies if a user expressly enables result history.

AI Navigator data is retained for the active session and the limited operational period described in Section 11. A separate period applies if persistent history is enabled.

Personal data may be retained for longer where necessary to address an active legal, safety, security or moderation matter, comply with a legal obligation or establish, exercise or defend legal claims.

Genuinely anonymized statistics may be retained because they no longer identify, link to or single out an individual.

17. Cookies and similar technologies

States of Mind uses cookies and similar technologies for strictly necessary website operations and, where consent is given, for Amplitude analytics, Amplitude Session Replay and Google Analytics.

Non-essential analytics technologies are not activated before the user gives the required consent.

Users may refuse or withdraw consent through the cookie or privacy settings made available on the website.

18. Security

States of Mind applies technical and organizational measures designed to protect personal data against unauthorized or unlawful processing and accidental loss, destruction or damage.

The documented measures include role-based access controls, least-privilege access for service accounts, periodic access reviews, separation of production and staging environments, logging of administrative access events, encryption of website traffic through Cloudflare, TLS 1.2 or TLS 1.3, AES-256 encryption for data at rest on DigitalOcean infrastructure, and storage of API keys and integration secrets as runtime environment variables rather than in application code or the WordPress database.

No method of electronic transmission or storage can be guaranteed to be completely secure.

19. Automated processing and AI

States of Mind calculates assessment scores and may use OpenAI to generate personalized educational recommendations or AI Navigator responses.

These processes do not make decisions that produce legal effects or similarly significantly affect users. Assessment and AI outputs are educational or navigational and are not medical diagnoses, clinical decisions, treatment-eligibility decisions or substitutes for professional assessment.

Users remain responsible for deciding whether and how to act on educational information or recommendations.

20. Data-subject rights

Subject to the conditions and exceptions in applicable law, a data subject may request confirmation of whether States of Mind processes personal data concerning them and may request access to that data.

A data subject may request correction of inaccurate or incomplete personal data, erasure of personal data, restriction of processing, or portability of data processed by automated means on the basis of consent or contract.

A data subject may object to processing based on legitimate interests, including community moderation or platform-integrity processing. States of Mind will stop the relevant processing unless it demonstrates compelling legitimate grounds that override the data subject’s interests, rights and freedoms, or the processing is necessary for legal claims.

Where processing is based on consent or explicit consent, the data subject may withdraw consent at any time.

States of Mind does not subject users to decisions based solely on automated processing that produce legal or similarly significant effects.

Requests may be submitted to privacy@pink-elephant.co. We may request proportionate information to verify the identity of the requester before disclosing, correcting or deleting personal data.

States of Mind will respond without undue delay and normally within one month. Where a request is complex or multiple requests are received, this period may be extended by up to two additional months, and the requester will be informed within the first month.

21. Complaints

A data subject may lodge a complaint with the Portuguese supervisory authority:

Comissão Nacional de Proteção de Dados
Av. D. Carlos I, 134, 1.º
1200-651 Lisboa
Portugal

A data subject may also complain to the competent supervisory authority in the Member State of their habitual residence, place of work or place of the alleged infringement. The CNPD provides a general complaint process for data-protection concerns.

22. Changes to this Privacy Policy

We may update this Privacy Policy where our processing activities, technologies, legal obligations or service providers change.

Where a change materially affects the nature of the processing or a consent previously provided, we will provide an appropriate notice and obtain new consent where required.

The effective and last-updated dates at the beginning of this Privacy Policy will identify the version then in force.

23. Contact

Questions about this Privacy Policy or the processing of personal data may be sent to: