Watson Development ApS, Denmark, trading as DearestWatson ("we", "us", or "our"), is committed to protecting your personal data and ensuring transparency in how it is used. This policy explains what we collect, why we collect it, and the choices you have.
Your choices
You can review sharing when you first enter DearestWatson and change it later in Profile. Continuing records that you received this notice. Accepting the Terms of Use is separate from optional sharing.
Sharing with your workplace
Profile has separate choices for assessment results, leadership context in Watson, named Watson advice about you, and personal development-goal titles and status. The first three default to on; personal goals default to private. Your choices apply to existing and future information. Turning a choice off stops new access under that choice; information already delivered may remain in the recipient’s conversation.
When you accept a peer-learning group invitation, current and future accepted members may see your shared assessment results and use eligible shared information in Watson. Your Profile choices still apply. The invitation explains the audience before you join. You can leave the group from its workspace to stop new group access; information already delivered may remain with recipients. Private Watson conversations, raw answers, reflections and check-ins are excluded.
Optional AI sharing on iPhone
The installed iPhone app asks permission before sharing relevant information with Mistral AI in the EU. Personal AI covers messages, work context, assessment answers and results, development goals, reflections and coaching history for your own guidance and eligible background personalisation. AI support covers support messages, history and screenshots you attach. Shared workplace AI covers permitted team context, meeting transcripts and approved organisational documents; authority for other people’s information is checked separately.
These are separate, remembered choices. You can keep them off or change them in Profile. A refusal stops new requests in that category until you choose to enable it. Withdrawal cannot recall information already sent. Saved work and human support remain available. Browser and Teams features follow the workspace processing and access rules described in this notice; these additional iPhone permissions are not a global AI-off setting.
For voice input on iPhone, a separate permission covers one audio clip sent to Mistral to create an editable draft. DearestWatson does not save the clip. You can cancel before upload or keep typing. Sending the draft to Watson is a separate action. Microphone access is controlled by your browser, Teams or device.
Where offered, Remember my voice is a separate, optional choice in Profile. You record or upload a short sample of your own voice and explicitly choose to save it for your workspace. For a meeting you are included in, an authorized organizer can choose to send your sample and short meeting clips to Mistral in the EU for name suggestions. Suggestions need confirmation and never grant account access. You can listen to, replace or delete your sample in Profile. Deletion stops future use of that saved sample; moving workspaces, account reassignment or archiving also removes the sample. Names already confirmed in a shared meeting remain subject to that meeting’s ordinary access and retention rules. Previously sent requests cannot be recalled, but a response arriving after withdrawal is discarded. Comparing voices within an authorized meeting uses only that recording’s clips and does not create a reusable profile.
Storage, reminders and connections
Necessary cookies and browser storage support sign-in, security and essential service state. We currently use no optional preference, analytics or marketing cookies. Profile lets you turn off any earlier optional-cookie choices. If optional storage is introduced, it will stay off until you choose to allow it.
Email copies of inbox updates, iPhone alerts and reminders have their own settings in Profile. Operational and company-sent emails follow their stated service rules. Meeting authorisation, joining a group and connecting an external AI account are explained when you take those actions. Device permissions may also need changing in device Settings.
1. Data Roles
Watson Development ApS (Denmark), trading as DearestWatson
Contact: privacy@dearestwatson.com
When you use DearestWatson directly, we act as controller for your account and service data. When your employer, client organization, or another customer invites you into the platform, that organization is usually the controller for the workspace purpose and DearestWatson acts as processor under our agreement with them. For some operational data, such as security logs, abuse prevention, billing, and product reliability, DearestWatson may act as an independent controller.
2. What Data We Collect
We collect and process the following types of personal data:
Account information
- Email address (used for login and identification)
- Name (used to personalize your experience)
- Company, team, role, level, and portal-access information where supplied by an organization or administrator
Assessment data
- Your responses to assessments
- Generated results, insights, and profiles
- Stakeholder Match, organizational-diagnosis, and development-pathway responses where you are invited into those modules
AI and meeting-analysis interactions
- Chat transcripts between you and Watson are stored on our infrastructure to provide continuity across sessions
- Behavioral signals derived from your interactions (e.g. recurring themes, blockers, completed actions) are synthesized into a coaching memory
- Meeting recordings, transcripts, and AI-assisted analyses where a user authorized for that meeting records or connects an engagement or internal meeting
- Raw behavioral event logs are retained for 30 days, after which only the synthesized memory is kept
Company Brain and purpose-bound professional context
- Up to four administrator-verified company documents may provide disclosed secondary context in Watson, Stakeholder Match, and meeting analysis
- Company context cannot determine development goals, change match scoring, become meeting evidence, or judge culture fit, alignment, performance, or potential
- Professional-context records are separate summaries used only for the documented workspace purpose under this notice. They include their source, confidence, status, creation time, and expiration—not raw assessment answers, private coaching chats, or transcript passages
- Usage records show which sources were used, for what purpose, and when. They do not contain private coaching chats, the text of search questions, or document passages
- Meeting analysis does not automatically create or retain professional-context observations about participants
- Before any meeting capture is connected, an authorized organizer records one meeting-level authorization covering recording or transcription, AI analysis, retention, and any relevant existing workspace context used for the stated meeting purpose. That authorization is not requested again for individual remarks or transcript passages.
- For a linked engagement, existing Stakeholder Match evidence may be used only as working-style hypotheses within that authorized meeting scope. The transcript remains the evidence for what happened, and the meeting cannot change an assessment, profile, or match ordering.
Watson People Intelligence
- Existing published professional-experience records, if any, remain labeled self-declared. The professional-experience editor is no longer available.
- Current team leaders and company administrators may use eligible named evidence in Watson people advice only while your named Watson sharing choice is on. Assessment outcomes, Profile leadership context, and personal development-goal titles and status also follow their separate sharing choices.
- For consistency between authorized questions, Watson may keep one current, rebuildable structured evidence profile per person for up to 180 days. Eligible source, assignment, team/role/status, or feature-setting changes invalidate it. It is included in your access and erasure rights and is not a permanent personality, performance, potential, or readiness judgment.
- For these requests, Watson records the permitted group of people, confirmed criteria, identifiers for the people considered, fingerprints of the evidence, and the versions of the instructions used. These audit records do not contain the text of the question.
- Private Coach chats and memory, raw assessment answers, personal development goals you have not chosen to share, reflection and check-in text, meeting recordings/transcripts, protected characteristics, and special-category data are excluded.
Usage data
- Interaction data used to improve the product, including analytics and search optimization
- Security, access, invitation, email-delivery, and audit logs used to protect the service and support customers
External invitation data
- Public invitation tokens and expiry information for assessment, onboarding, and client-match links
- Onboarding drafts that may include company, team, participant, and evaluation-context information before an account is created
- Transactional email delivery status for invitations, reminders, and access messages
Privacy notice and legal receipts
- Timestamp and version showing that this privacy notice was delivered and acknowledged; this receipt is not consent
- Separate timestamp and version for Terms of Use acceptance
- Any earlier optional-cookie choices, retained so you can withdraw them in Profile
- Meeting-level authorization evidence recorded before capture, without storing individual remarks in the authorization record
Website, enquiries and business contacts
- Website visits: our host (Vercel, EU region) logs IP address, browser and requested pages to deliver and protect the site. We use no analytics, advertising or tracking cookies. Your currency choice is stored only in your own browser.
- Enquiries: the contact form opens an email in your own email app. When you write to us, we keep your name, work email, organization and message to answer you. We do not add you to a marketing list.
- Business contacts: for customers, partners and suppliers we keep name, role, work contact details and our correspondence to run the agreement.
- Legal basis: legitimate interest (Article 6(1)(f)) and, for agreements, contract (Article 6(1)(b)).
- Retention: enquiries without an agreement are deleted 24 months after last contact; business and contract records are kept for the contract term plus 3 years, and bookkeeping records for 5 years.
3. How We Use Your Data
We process your data to:
Provide the service
Deliver assessments, generate insights, and enable platform functionality.
Personalize your experience
Tailor insights and recommendations based on your inputs.
Improve the product
Analyze usage patterns to improve functionality, usability, and discoverability.
Ensure security and access control
Maintain secure login and protect your data.
Operate customer workspaces
Enable approved administrators to create participants, Stakeholder Match respondents, onboarding drafts, runs, reports, and module assignments.
Legal basis (GDPR):
- Contract performance (Article 6(1)(b))
- Legitimate interest (Article 6(1)(f))
- Consent where applicable (Article 6(1)(a))
Reading or acknowledging this policy records that the notice was delivered; it is not itself consent. For organization workspaces, the controller must identify and document the applicable lawful basis before enabling Company Brain.
4. Team, Leadership & Watson Usage
If you use the platform as part of a team or organization:
- Named assessment outcomes are shared with your current team leaders and company administrators by default. You can turn this off in Profile; named Readiness diagnosis views then omit your results
- Your raw assessment answers are not shared
- Your Profile leadership context may be used in leader-facing Watson advice by default. You can turn this off in Profile
- Watson may include you in named people advice to authorized leaders and company administrators by default. You can turn this off in Profile
- Personal development-goal titles and status are private by default. One account-wide choice in Profile can share them with current team leaders and company administrators. Goals shared under an earlier setting may remain visible until you make all goals private. Goals assigned in a managed path have separate access rules
- These choices apply to information already saved and information added later. Turning a choice off stops new named reads, but an answer already delivered to a leader may remain in that leader’s conversation history
- Assessment results may still contribute to privacy-protected anonymous team summaries when named assessment sharing is off
- Meeting recordings and organization-assigned development tracking have separate access rules
- Your Watson chat transcripts are private to you and are not shown to leaders or administrators as chat transcripts
- Private Coach conversations, blockers, resistance, and behavioral memory are not available to Stakeholder Match or meeting-analysis workflows
- Operational coaching telemetry, such as event delivery, notification status, and module activity, may be visible to authorized administrators where needed to run the service
- Stakeholder Match outputs are AI-assisted evidence for human review and are not standalone automated decisions
- Where your workspace enables self-matching, you can create working-relationship matches involving yourself. The people included in a self-match and authorized team leaders and company/platform administrators can view its relationship result. Unrelated employees cannot browse it. The selected stakeholder answers a working-style questionnaire; the employee requesting the match receives any missing matching assessments. Assigned tasks appear in the recipient’s Assessments, with in-app and email requests. Individual questionnaire answers and private journey reflections are excluded from the shared result view, and your workplace sharing choices still apply.
- “Joining a team” views describe possible working dynamics and onboarding questions only. They do not assess competence, performance potential, or employment suitability and must not be used as a hiring recommendation
- Where the governed Watson People Intelligence pilot is enabled, current leaders may receive named requirement-by-requirement staffing and team-composition decision support within their authorized scope. Staffing criteria must be confirmed before ranking.
Governed Company Brain
Where your organization enables Company Brain, the feature operates under this Privacy Policy and the workplace sharing choices described above. Your organization remains responsible for establishing and documenting an appropriate lawful basis for workspace processing. You may access, correct, delete, restrict, or object to processing through your organization or by contacting us.
- Stakeholder Match may reuse professional evidence within the stated privacy notice and purpose boundaries for deterministic comparison. Company Brain context may support briefing preparation, useful questions, collaboration guidance, and communication only; it does not determine ranking, hiring, eligibility, or suitability outcomes. The platform does not ask you to consent separately to each evidence item.
- Leader-facing meeting analysis and coaching may use relevant administrator-verified documents as secondary organizational context. That context is not evidence that something occurred in the current meeting and cannot become person evidence.
- Meeting analysis does not automatically create a durable professional-context claim from the transcript. Raw transcripts, quotations, interpretations, and person-pattern observations remain in the meeting workflow.
- Where working-style context is included in the pre-meeting authorization for a linked meeting, only a small set of natural-language relationship hypotheses is supplied. Raw answers, scores, assessment labels, mode identifiers, and other shortlisted people are excluded. Any displayed reflection must be grounded in an exact quote from that meeting.
- Administrators can see records of the purpose and access involved, but cannot directly inspect your professional-context summaries or private coaching memory.
- Some permitted background information may shape a response without being repeated in the response itself. Its use is still recorded, and the usage records and relevant professional-context records are included in your data export.
- Company Brain blocks special-category and sensitive inference, including health, diagnosis, political, religious, union, sexuality, and emotion-recognition categories.
- Company Brain is human decision support only. It must not make standalone decisions about employment, compensation, promotion, performance, or work allocation.
How Watson Uses Data
The platform uses your data to generate AI-powered coaching and insights. This includes:
- Individual leadership feedback
- Team-level patterns and dynamics
- Recommendations for leaders and organizations
Each feature uses only the information permitted for its purpose and the requesting person’s role. Depending on the feature, this may include:
- Your assessment results
- Your Watson chat history for your own private coaching, not for leader or administrator insights
- Aggregated team data
- Organizational context (where applicable)
To generate these insights, your prompts and relevant context are transmitted to third-party large language model (LLM) providers configured server-side — currently Mistral AI through its EU regional inference endpoint — which processes the data on our behalf under their applicable contract and configured data-use settings. For Company Brain workflows, Mistral receives only the limited set of background information approved for that specific request and the task or transcript data needed to carry it out.
Zero data retention is enabled for our Mistral API organization. Mistral does not store our API calls for troubleshooting or analytics. DearestWatson stores the account content and generated results described in this notice under our own retention rules.
Your data is used for the enabled development, insight, manager-support, and governed staffing purposes described in this notice.
Watson does not make solely automated employment, evaluation, compensation, staffing, promotion, or work-allocation decisions. It cannot assign a person or update a talent record. A responsible human must verify evidence, consider corrections and make any consequential decision.
5. Your Rights & Control
You have the following data-protection rights and product controls:
- Access — You can request a paginated machine-readable export and readable summary in the product; shared and unstructured records are reviewed before the response is marked complete
- Correction — You can update inaccurate information
- Deletion — You can submit an erasure request in the product; deletion is verified and shared records, legal holds, and lawful exclusions are reviewed before completion
- External respondent requests — If you were invited as a Stakeholder Match respondent or onboarding contact, contact us or the inviting organization and we will coordinate the request
- Portability — You can request your data in a structured format
- Restriction & objection — You can limit or object to certain processing
- Withdraw consent — Where processing is based on consent, you may withdraw it at any time
- Company Brain rights — You can request usage receipts and relevant professional-context records, and ask to correct, delete, restrict, or object to their use
We respond to requests within one month.
6. Data Retention
- Account, profile, assessment, and Watson conversation data is stored as long as your account is active
- Raw behavioral event logs are retained for 30 days; only the synthesized coaching memory is kept beyond that
- Rebuildable Watson People Intelligence person-evidence profiles expire after 180 days, are invalidated when eligible source or scope data changes, and are deleted when the company disables the feature
- Meeting audio defaults to 90 days (company setting 30–365 days); transcripts and analysis default to 365 days (company setting 90–1,095 days), subject to audited legal holds
- Superseded or archived Company Brain versions default to 90 days (company setting 30–365 days); shared content and usage receipts may require privacy review
- Transactional email logs keep delivery status for operational support, and personal email-log fields are redacted after 180 days
- Public invitation tokens expire automatically and can be revoked by authorized administrators
- Private GDPR export artifacts expire after 24 hours
- Inactive-account cleanup begins after three years measured across relevant product activity. A warning is sent 30 days before eligibility, subject to legal holds and review
7. Data Security
We implement appropriate technical and organizational measures, including:
- Encrypted data transmission (HTTPS/TLS)
- Secure authentication systems
- Database and server-side access controls limit access by role, organization, team, assignment, and record ownership. Team leaders and organization administrators may access the named results and aggregate views described in section 4; raw assessment answers and private coaching content are not shared with them
- Regular security reviews
8. Data Sharing & Sub-processors
We do not sell your data.
We rely on the following trusted third-party providers to operate the platform:
Last updated: 05-10-2026
- Supabase (Supabase Pte. Ltd.)
- database, authentication, file storage, backend functions — Data stored in Stockholm, Sweden (EU); Edge Functions that process customer content run in Frankfurt, Germany (EU).
- Vercel (Vercel Inc.)
- hosting of the web application — Stockholm, Sweden (EU)
- Mistral AI (Mistral AI SAS, France)
- AI processing — EU
- Lettermint (Lettermint B.V., Netherlands)
- service e-mail — EU
- Amazon Web Services (AWS EMEA SARL, Luxembourg)
- encrypted backups and backup monitoring — Ireland and Stockholm (EU)
- Aikido Security (Aikido Security BV, Belgium)
- security scanning of code and cloud configuration — EU
- Microsoft (Microsoft Ireland Operations Limited)
- only if the customer enables the Teams app or Entra sign-in — Microsoft EU Data Boundary
Before a provider is enabled for production personal data, the applicable controller and processor must ensure that the required Article 28 terms, data-use and retention settings, subprocessor information, and transfer safeguards are documented. Current provider and transfer evidence is maintained in the operational vendor register.
9. EU Data Residency & Processing
The provider locations for production are listed in section 8. Our development environment is separate from production.
For further processing and transfer information, contact privacy@dearestwatson.com.
10. Complaints
If you believe your data rights have been violated, you have the right to lodge a complaint with a supervisory authority.
In Denmark:
Datatilsynet
www.datatilsynet.dk
11. Changes to This Policy
We may update this Privacy Policy from time to time. If changes are significant, you will be asked to review and re-acknowledge the updated notice before continuing to use the platform.
12. Contact
If you have any questions about this policy or your data: privacy@dearestwatson.com