Privacy Notice — Now for Women

Legal

Version 2.0 — Effective Date: 20 July 2026

Table of Contents
  1. Contact & Data Protection Officer
  2. What Is Personal Data?
  3. What Categories of Data Do We Process?
  4. Why Do We Collect Your Data and What Is the Legal Basis?
  5. Naomi — Our AI Wellness Companion
  6. Who Do We Share Your Data With?
  7. Is Your Data Sent Outside the UK / European Union?
  8. What Security Measures Have We Taken?
  9. What Are Your Rights?
  10. How to Exercise Your Rights
  11. Cookies and Tracking
  12. How Long Do We Keep Your Data?
  13. Changes to This Privacy Notice

INTRODUCTION

This Privacy Notice explains how Now for Women collects, uses, and protects your personal data, and what your rights are.

It applies to the NOW for Women digital wellness platform and all related services (the “Platform” or “Services”) offered by:

Now for Women — Simplified joint-stock company (SAS)
Registered office: 36 rue Scheffer, 75016 Paris, France
Registered capital: €30,000
Company registration: Paris Trade and Companies Register, number 940 318 975
(“Now for Women”, “we”, “us”, or “our”)

Now for Women acts as the data controller for all processing activities relating to the Platform.

All personal data is processed in accordance with applicable UK and French data protection law, including:

  • The UK General Data Protection Regulation (UK GDPR)
  • The Data Protection Act 2018
  • The European Regulation (EU) 2016/679 (GDPR)
  • French Law 78-17 of 6 January 1978 on information technology, files, and civil liberties (Loi Informatique et Libertés)

1. CONTACT & DATA PROTECTION OFFICER

If you have any questions or requests regarding your personal data, please contact our Data Protection Officer:

Email: admin@now-for-women.com
Post: Data Protection Officer, Now for Women, 36 rue Scheffer, 75016 Paris, France

2. WHAT IS PERSONAL DATA?

Personal data refers to any information relating to an identified or identifiable person — for example, your name, email address, or IP address. This includes data you provide directly, and data collected automatically when you use our Platform.

3. WHAT CATEGORIES OF DATA DO WE PROCESS?

CategoryType of Personal DataHow It Is Collected
Identification and Contact DataName, email address, phone number, postal code, ageRegistration forms
Health and Wellness Data (Special category)Wellbeing check-in responses (physical, emotional, cognitive, sexual health); reproductive health status; medical history and current treatments (if shared); physical measurements; lifestyle factors (sleep, diet, activity, stress); biosensor data from connected devices (optional)Wellness assessment questionnaire; Platform interactions; optional device integration
AI Conversation DataQuestions and topics you raise with Naomi; conversation history; session frequency and duration; wellness concerns mentioned in natural languageAutomatically collected when you interact with Naomi
Contractual and Payment DataService details, subscription tier, account information, billing and payment details, transaction historyRegistration, subscription, and payment processes
Technical and Usage DataIP address, device type, browser information, Platform usage patterns, cookies and tracking technologiesAutomatic collection via Platform
Customer Support DataCommunications with customer supportWhen you contact us
Marketing Data (opt-in only)Communication preferences, marketing interactionsConsent forms and preference settings

About our health and wellness data: Your wellbeing information is classified as special category personal data under data protection law. We only process it with your explicit consent and with appropriate safeguards in place.

Optional data: Many questions in our wellness assessment are optional. You can skip any question without affecting your ability to use the Platform or access Naomi. The more you share, the more personalised your experience — but all optional data remains your choice.

Age: We collect your age to confirm you meet our minimum age requirement of 18 years and to provide age-appropriate wellness guidance. We do not knowingly collect data from anyone under 18. If you believe we have done so, please contact us immediately at admin@now-for-women.com.

PurposeLegal Basis
Managing enquiries from prospective usersLegitimate interest
Delivering the NOW Functional Profile wellbeing assessment and resultsPerformance of contract; explicit consent (health data)
Creating and supporting personalised wellness programmesPerformance of contract; explicit consent (health data)
Personalisation via Naomi, our AI Wellness CompanionPerformance of contract; explicit consent (health data)
Improving and optimising Naomi’s performanceLegitimate interest; explicit consent where health data is involved
Anonymised and aggregated analysis to understand wellness patterns, improve our services, and contribute to women’s health knowledgeLegitimate interest; explicit consent for research use
Traffic statistics and platform analyticsLegitimate interest
Cookie managementLegitimate interest (essential cookies); consent (non-essential cookies)
Managing your accountPerformance of contract
Processing orders, transactions, complaintsPerformance of contract
Managing payments and financial recordsPerformance of contract; legal obligation
Newsletter and marketing communicationsConsent
Managing the commercial relationshipPerformance of contract
Customer serviceLegitimate interest
Satisfaction surveysLegitimate interest
Processing requests to exercise your data rightsLegal obligation
Managing disputes and legal claimsLegitimate interest; legal obligation

A note on anonymised data: We may use anonymised and aggregated data — data that cannot identify you — to better understand how our services perform, to identify trends in women’s wellbeing, and to contribute to broader health and wellness research. Once data is fully anonymised, it falls outside the scope of data protection law. Any use of your identifiable data for research purposes requires your separate explicit consent.

5. NAOMI — OUR AI WELLNESS COMPANION

Powered by AI. Naomi is an artificial intelligence wellness companion. She is not a human, not a healthcare professional, and her responses are not medical advice.

Naomi AI: available at no charge, subject to the features shown in the Platform. Naomi AI Premium is not yet available. Its features and price will be shown in the Platform before purchase.

What data Naomi uses

When you interact with Naomi, we collect:

  • The questions you ask and topics you discuss
  • How often and how long you use the service
  • Wellness concerns or symptoms you mention in conversation
  • Symptom tracking entries you choose to log

How Naomi works — in plain English

Naomi uses two types of technology:

  1. Your personalised wellbeing profile is built using transparent, rule-based logic — not black-box AI decision-making. The rules are fully auditable and traceable. This ensures your profile is built fairly and consistently.
  2. Naomi’s conversational responses are generated by an AI language model. Before any data reaches the AI, your name, email address, and other personal identifiers are automatically removed. The AI only ever processes anonymised content.

How we make sure Naomi is safe and fair

  • No personal identifiers reach the AI. Your name, email, and contact details are never sent to the AI model.
  • Bias and accuracy: Our wellbeing assessment rules are regularly reviewed to ensure they work fairly and consistently across users. We do not rely solely on AI for any decisions about your wellbeing profile.
  • Human oversight: Naomi’s outputs are informational only. No automated decision produces any legal or significant effect without human review.
  • Fail-safe design: If there is an error in our data protection processes , all AI processing stops automatically.

Your control over Naomi data

  • You can request deletion of your Naomi conversation history at any time from your account settings.
  • You can opt out of having your anonymised conversation data used to improve Naomi.
  • All use of health data from your conversations is based on your explicit consent.

Legal basis for Naomi data processing

  • Performance of contract — to provide the AI wellness service
  • Legitimate interest — to improve service quality and safety
  • Explicit consent — where health-related information is extracted from your conversations

6. WHO DO WE SHARE YOUR DATA WITH?

We share personal data only where necessary and only with parties who are contractually bound to protect it.

We never sell your personal data.

Internal access

Authorised team members with role-based access controls, on a strict need-to-know basis.

Service providers acting on our behalf

All third-party providers are carefully selected and contractually required to comply with applicable data protection law (GDPR Article 28 / UK GDPR Article 28).

Provider TypeExample Providers
Cloud hosting and infrastructureAmazon Web Services (AWS), EU region
Database servicesSupabase or equivalent (EU data residency)
Form and survey providersTypeform (EU data residency where available)
Email and communicationBrevo / Sendinblue (servers in France and EU)
Payment processingStripe Payments Europe Ltd.
AI model providersClaude by Anthropic or equivalent — personal identifiers removed before any AI processing
Analytics and marketingMeta Platforms (Instagram / Facebook)
Customer support toolsAs required to operate the service
Professional advisersAccountants, lawyers

Connected device providers (optional)

If you choose to connect a health tracking device or app (such as Apple Health, Fitbit, Garmin, Oura, WHOOP, or Withings), we receive data from those providers with your authorisation. These providers act as independent data controllers for data processed within their own platforms and are subject to their own privacy policies. You can revoke access at any time from your account settings. We recommend reviewing their privacy policies before connecting.

Sharing wellness data with research partners

We may use and share fully anonymised, aggregated wellness data with academic and scientific research partners to advance women's health science. Because this data cannot be traced back to any individual, your consent is not required under data protection law for this type of sharing - it is no longer personal data once anonymised.

If we ever wish to involve your identifiable personal data in a specific research project or clinical trial, we will ask for your explicit consent at that time, before any such sharing takes place. You will never be required to participate.

Business transfers

In the event of a merger, acquisition, investment round, or sale of all or part of our business, personal data may be transferred to prospective buyers or investors. Any such transfer will be subject to appropriate confidentiality protections. We will notify you if your data is to be subject to a new privacy policy as a result.

Legal and regulatory bodies

Where required by law, we may share data with government bodies, regulators, or law enforcement for tax, compliance, cybersecurity, or legal purposes.

7. IS YOUR DATA SENT OUTSIDE THE UK / EUROPEAN UNION?

We aim to keep your personal data within the UK and the European Economic Area (EEA). Where service providers are based within the EU or EEA, no additional cross-border transfer safeguards are required.

Some providers may process data outside the UK/EEA:

  • Marketing data: Meta Platforms (Instagram / Facebook) may involve transfers to the United States, governed by the EU–US Data Privacy Framework and its UK Extension.
  • AI processing: AI model providers receive only fully anonymised, de-identified content — no personal identifiers are transferred.

All international transfers are subject to appropriate safeguards including Standard Contractual Clauses (SCCs) and the UK International Data Transfer Agreement (IDTA) where applicable."

You can request further information about international transfers by contacting admin@now-for-women.com.

8. WHAT SECURITY MEASURES HAVE WE TAKEN?

We implement comprehensive technical and organisational measures to protect your personal data.

Technical measures

  • Encryption of data in transit (TLS 1.2 or higher)
  • Encryption of sensitive data at rest (AWS KMS)
  • Regular security assessments and penetration testing
  • Monitoring and anomaly detection
  • Secure development practices and code review
  • Personal identifiers excluded from system logs wherever possible

Organisational measures

  • Role-based access controls and least-privilege principles
  • Multi-factor authentication for administrative access
  • Data minimisation and pseudonymisation where appropriate
  • Staff training on data protection
  • Privacy by Design and Privacy by Default in product development
  • Data Protection Impact Assessments (DPIAs) for high-risk processing
  • Regular backups and disaster recovery procedures
  • Vendor due diligence and contractual safeguards

Data breach notification

In the event of a personal data breach posing a risk to your rights and freedoms, we will notify the relevant supervisory authority (CNIL for EU; ICO for UK) within 72 hours, and we will notify you without undue delay where the breach poses a high risk.

9. WHAT ARE YOUR RIGHTS?

Under UK and EU data protection law, you have the following rights. References to specific articles below refer to the General Data Protection Regulation (GDPR) and UK GDPR — the external legal frameworks that give you these rights.

RightWhat It Means
Right of Access (Art. 15)Request a copy of the data we hold about you
Right of Rectification (Art. 16)Correct inaccurate or incomplete data
Right to Erasure (Art. 17)Request deletion of your data where it is no longer needed, consent is withdrawn, or it has been unlawfully processed
Right to Object (Art. 21)Object to processing based on legitimate interest; object at any time to direct marketing
Right to Restrict Processing (Art. 18)Pause use of your data without deleting it
Right to Data Portability (Art. 20)Receive your data in a portable, machine-readable format
Right Not to be Subject to Automated Decisions (Art. 22)Not to be subject to decisions based solely on automated processing that significantly affect you, without human review
Right to Withdraw Consent (Art. 7(3))Withdraw consent at any time; this does not affect processing already carried out
Right to Delete Naomi Conversation HistoryDelete your conversation history at any time from your account settings
Right to Delete Your AccountDelete your account and associated data directly in account settings
Right to Define Post-Mortem Instructions (French law only)Under Article 85 of French Law No. 78-17, you may issue instructions about your data after your death. This right does not apply under UK GDPR.
Right to Lodge a Complaint (Art. 77)See below

How to complain

France — CNIL
Website: https://www.cnil.fr/fr/plaintes
Address: 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France

United Kingdom — ICO
Website: https://ico.org.uk/make-a-complaint/
Phone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, UK

10. HOW TO EXERCISE YOUR RIGHTS

Contact us at any time:

Email: admin@now-for-women.com
Post: Now for Women, Data Protection Officer, 36 rue Scheffer, 75016 Paris, France

We will respond within one month. For complex or multiple requests, we may extend this by a further two months and will inform you within the initial month. Requests are handled free of charge.

11. COOKIES AND TRACKING

We use cookies and similar tracking technologies on our Platform. For detailed information about the cookies we use, their purposes, and how to manage your preferences, please refer to our https://now-for-women.com/cookies-policy available on our website.

You can manage your cookie preferences at any time using the cookie settings tool on our website.

12. HOW LONG DO WE KEEP YOUR DATA?

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, including:

  • Legal obligations: Compliance with accounting, tax, and statutory retention requirements (e.g. financial records kept up to 6 years)
  • Contractual obligations: Duration of the contract plus applicable legal limitation periods
  • Legitimate interests: Establishment, exercise, or defence of legal claims
  • Consent-based processing: Until consent is withdrawn

After the relevant retention period, personal data is securely deleted or fully anonymised. Anonymised data may be retained indefinitely for research and analytics purposes.

A full internal Retention Policy is maintained and reviewed regularly.

13. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. We will notify you of material changes by:

  • Posting a prominent notice on our website (https://now-for-women.com)
  • Sending an email notification (where you have provided your email address)

Continued use of our services after changes are posted constitutes acceptance of the revised Privacy Notice.

© 2026 Now for Women. All Rights Reserved. Version 2.0 — Effective Date: 20 July 2026

© 2026 Now for Women. All Rights Reserved. Version 2.0 — Effective Date: 20 July 2026

This Privacy Notice complies with UK GDPR, EU GDPR, and French data protection law (Loi Informatique et Libertés).