1. Introduction
Welcome to Anxiety Checklist, operated by HOLDXB Trading FZCO (“HOLDXB,” “we,” “us,” or “our”).
We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, disclose, and protect your information when you:
- Use our website www.anxietychecklist.com
- Use our mobile and web applications (“Apps”)
- Communicate with us via email, support, or social media
By using our Products, you consent to this Privacy Policy.
2. Summary of Key Points
- We do not sell or rent your personal data.
- We use end-to-end encrypted communication for sensitive features (journaling, SOS, etc.).
- We store your data on secure servers located in the European Union and/or the United Arab Emirates.
- We collect only what’s necessary to operate and improve the App.
- You may request access, correction, or deletion of your data anytime.
- The App is not intended for medical diagnosis or emergency use.
- If you use the optional AI Companion, your messages are sent to OpenAI to generate replies (see Section 7).
- We never send your journal, mood, AI Companion conversations or other health content to analytics or advertising partners. On our website, optional analytics and marketing cookies follow your choices (see Section 14).
3. Information We Collect
3.1 Information You Provide
When you use Anxiety Checklist, we may collect:
- Account Information: Email address, password, language, country
- Profile Information: Age range, gender (optional), usage preferences
- Journal & Mood Entries: Notes, tags, or check-in responses you enter manually (stored securely and privately for your account only)
- Assessment Results: Scores from wellness tests (e.g., GAD-7, PHQ-9, DASS-21, OASIS, STAI, etc.) these are stored to track your personal progress only
- AI Companion Content: Messages you write to the AI Companion and, only if you choose, saved chat history and memory notes (see Section 7)
- Support Requests: Messages or attachments you send to our team
- Payment Information: Only processed by Apple, Google, or our secure payment partners (we never store full credit card data)
3.2 Information We Collect Automatically
When you access our App or website, we may automatically collect:
- Device type and model
- Operating system and version
- IP address and general location (city-level)
- App version and usage patterns (e.g., feature frequency, session duration)
- Crash reports and performance logs
- Cookie and device identifiers, such as analytics and advertising cookie IDs on our website, and in the App an app instance ID and your device’s advertising identifier (on iPhone and iPad only if you allow tracking; see Section 14)
- Which link or ad led you to our website or to install the App (for example, a tap on an App Store or Google Play button on our website)
This helps us maintain and improve functionality, and understand which of our ads and links help people find the App.
3.3 Information from Third Parties
We may receive data from:
- App Store/Google Play (purchase confirmation, subscription status)
- RevenueCat, our subscription management provider (subscription and trial status, renewals, and cancellations)
- Analytics, attribution and advertising partners (usage metrics, and which ad or link led to a website visit, an App install, a trial or a subscription; never your journal, mood or AI Companion content)
- Social or email integrations (only if you voluntarily connect an account)
4. How We Use Your Information
We process your data to:
- Provide the App: Create and manage your account, deliver personalized features, and save your wellness entries.
- Improve Functionality: Analyze usage data, linked to a pseudonymous identifier rather than your name or email address, to enhance user experience and reliability.
- Measure Our Marketing: Understand which of our ads and links lead people to visit our website, install the App, start a free trial or subscribe (see Sections 9 and 14).
- Communicate with You: Send updates, respond to support requests, and deliver optional newsletters.
- Ensure Compliance: Prevent fraud, abuse, or unauthorized access.
- Fulfill Legal Obligations: As required by applicable law, court order, or lawful government request.
We will never use your journal or assessment data for advertising or resale.
5. Legal Basis for Processing (GDPR / PDPL)
We process data under the following lawful bases:
- Consent: When you explicitly agree (e.g., creating an account or receiving emails, or allowing optional analytics and marketing cookies on our website where the law requires your consent)
- Contractual Necessity: To deliver services you requested
- Legitimate Interests: To secure and improve the App
- Legal Obligation: Where required by UAE or international law
6. Health & Sensitive Data
The App may process data related to your mental wellbeing (e.g., anxiety levels, mood trends). This data is self-entered, stored privately, and encrypted in transit and at rest.
We do not analyze or share this data with advertisers, insurers, or employers. It is intended solely for educational and self-improvement purposes, not for diagnosis or treatment.
We never send your journal entries, mood or anxiety ratings, assessment answers or results, AI Companion conversations, or anything else you write in the App to our analytics or advertising partners.
7. AI Companion
The AI Companion is an optional chat feature in the App, included with an active subscription. It uses artificial intelligence and techniques drawn from Cognitive Behavioral Therapy (CBT) to reply to what you write and to suggest exercises in the App. It is a self-help tool, not therapy, medical advice, or an emergency service.
What you write to the AI Companion is likely to be about your mental health, so we treat all AI Companion content as health data.
7.1 What We Process and Why
When you use the AI Companion, we process:
- Your Messages: The text you write, together with recent messages from the same conversation, so that a reply can be generated.
- Context You Allow Us to Use: If you have switched on memory, the notes it has saved about you, short summaries of your recent previous conversations, the next steps (“missions”) you agreed on, and your before-and-after ratings from exercises in the App.
- Exercise Activity: Which exercises it suggested, whether you opened or completed them, the ratings you give, and, if you save your chat history, any reflection you write after an exercise.
- Safety Information: The results of automated safety checks on your messages (see Section 7.4).
- Technical Records: For each message, a record that does not contain what you wrote, such as the time, the safety category assigned, the AI model used, the response time, usage volume, and error codes.
We use this information only to provide the AI Companion, keep it safe, prevent misuse, and check that it works reliably. We do not use your AI Companion content for advertising, and we do not use it to train AI models.
7.2 OpenAI, Our AI Service Provider
Replies are generated by OpenAI, through its API. OpenAI also runs part of the automated safety checks and the search that finds relevant content in the App. To do this, we send OpenAI:
- Your messages and recent messages from the same conversation
- The context described in Section 7.1 that you have allowed us to use, and a short description of your account type and your saving choices
- Short search phrases describing what you need, and draft replies so they can be checked before you see them
- If you save chat history and have memory switched on, your saved conversations, so that short summaries can be created; and, when you delete or correct a memory, the old note and your saved summaries, so that the fact can be removed from those summaries
We do not send OpenAI your email address, password, payment details, or account ID. Your name is only sent if you asked the AI Companion to remember it.
The GAD-7 anxiety test on our website also uses OpenAI: when you ask for your results, we send your answers (never your name or email address) to OpenAI to generate a short analysis. We do not store your answers or the analysis.
OpenAI processes this data in the United States. See Section 11 for how we handle international transfers.
OpenAI’s API data policy states that it does not use data sent through its API to train its models by default. When we ask OpenAI to generate text, we switch off OpenAI’s option to store the response for later use. Under OpenAI’s own policy, OpenAI may still keep API data for up to 30 days, for example to monitor for abuse.
7.3 Your Choices: Chat History and Memory
- Before your first conversation, the App shows a “Before you start” screen explaining what the AI Companion is, what is sent to OpenAI, and what we store. You can only start chatting after you tap Continue on that screen.
- Chat history is saved only if you switch on “Save my chat history”. If you do not, your conversation is kept only temporarily on our server while you use it (for up to 3 hours) and is not saved to our database.
- Memory is off until you switch on “Remember helpful notes”. Memory notes are short facts you stated, such as your goals or what has helped you.
- Saving chat history and memory is only available for registered accounts with an email address, after you confirm the account is yours with a 6-digit code we email to you. To check this confirmation later, we keep a one-way coded (hashed) form of your email address.
- If you do not save chat history, the records of exercises suggested in that conversation, and any ratings you gave for them, are deleted automatically after about 24 hours.
- You can switch either setting off at any time in the App. Switching a setting off stops future saving and use, but does not delete what is already saved. Use the delete options in Section 7.5 for that.
7.4 Automated Safety Checks
- Every message you send is checked automatically before a reply is shown: by OpenAI’s moderation service, by an AI classifier that reads the recent conversation, and by fixed word-matching rules.
- If these checks suggest you may be at risk, for example of self-harm or a medical emergency, the AI Companion replies with a safety-focused message and a link to our Get help now page instead of suggesting exercises.
- Replies are also checked automatically before you see them, and are replaced with a standard message if they fail those checks.
- The AI Companion cannot contact emergency services or anyone else on your behalf, and no one monitors conversations in real time.
- The safety category is stored with your saved messages and in the technical records described in Section 7.1.
- These checks only change how the AI Companion replies. The AI Companion does not make decisions about you that have legal or similarly significant effects.
7.5 Retention and Deletion
Saved chat history, memory notes, conversation summaries, missions, exercise records, and ratings are kept until you delete them or delete your account. In the App, you can:
- Correct or delete a single memory. We then also automatically try to remove that fact from your saved conversation summaries.
- Delete all memories. This also deletes your conversation summaries, but not your chat history.
- Delete all chat history. This deletes your saved messages. Memories and summaries are kept unless you delete them too.
- Delete all my AI data. This permanently deletes your conversations and messages, conversation summaries, memories, missions, exercise records and reflections, ratings, your AI Companion privacy choices, and your email confirmation for the AI Companion.
When you delete your account, all of the AI Companion data listed above is deleted as part of the deletion.
The technical records described in Section 7.1 do not contain what you wrote. When you use “Delete all my AI data” or delete your account, they are permanently unlinked from you and your conversations, so that only anonymous usage statistics remain.
Data held by OpenAI is kept as described in Section 7.2.
7.6 Legal Basis and Consent
We process your AI Companion content, which is health data, on the basis of your explicit consent. You give it on the “Before you start” screen before your first conversation, and you give separate consent to save chat history and memory using the settings described in Section 7.3.
You can withdraw your consent at any time: stop using the AI Companion and use “Delete all my AI data”, which also resets your choices so that the “Before you start” screen appears again. You can also switch off chat history and memory separately. Withdrawing consent does not affect processing that took place before you withdrew it.
7.7 Your Rights
The rights described in Section 12 apply to your AI Companion data. In addition to the controls in the App, you can exercise them by emailing [email protected].
8. Data Storage & Retention
- Data is stored on secure cloud servers located in the EU and/or UAE.
- We retain your account data only as long as necessary to provide our services or as required by law.
- You can delete your account anytime, and all personal data (including journal entries) will be permanently deleted within 30 days.
10. Data Security
We use industry-standard safeguards, including:
- AES-256 encryption for stored data
- HTTPS/TLS 1.3 secure connections
- Password hashing (bcrypt/scrypt)
- Role-based internal access control
- Regular vulnerability audits and backups
However, no system is 100% secure.
You acknowledge and accept inherent risks of online communication.
11. International Data Transfers
Your data may be processed or stored in multiple jurisdictions (including the EU, UAE, and the U.S.) for redundancy and reliability. We ensure all transfers comply with applicable data protection regulations, including GDPR adequacy mechanisms and UAE PDPL safeguards.
If you use the AI Companion, your messages and related data are processed by OpenAI in the United States (see Section 7).
Our analytics, attribution and advertising partners listed in Section 9 may also process data in the United States and other countries.
12. Your Rights
Depending on your jurisdiction, you may have the right to:
- Access your personal data
- Correct inaccurate or incomplete information
- Delete your data (“Right to be Forgotten”)
- Withdraw Consent at any time
- Request Data Portability (export in readable format)
- Lodge a Complaint with a supervisory authority (e.g., UAE Data Office, EU DPA)
To exercise these rights, email [email protected].
13. Children’s Privacy
Anxiety Checklist is not intended for children under 13 years old (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have collected information from a minor without parental consent, we will delete it immediately.
15. Communications
We may contact you to:
- Confirm registration or purchases
- Provide important service or security updates
- Offer optional educational newsletters or challenges (opt-in)
You can unsubscribe anytime via email footer links or by contacting [email protected].
16. Third-Party Links
The App and Website may include links to third-party resources (e.g., WHO, APA, NIMH). We do not control or endorse their privacy practices. Review their policies before interacting with them.
17. Legal Compliance & Law Enforcement
We may disclose your information where required by applicable law, regulation, or legal process — including valid requests from law enforcement or regulators — provided such requests comply with UAE and international privacy principles.
18. Apple App Store Compliance
This app complies with Apple’s App Store Review Guidelines, including Guideline 5.1 (Data Collection and Storage). All personal and health-related data is processed in accordance with this Privacy Policy.
Apple is not responsible for the collection or use of your data by HOLDXB Trading FZCO.
19. DMCA and Copyright
We comply with the Digital Millennium Copyright Act (DMCA) and UAE Federal Law No. 38 of 2021 on copyright. If you believe your copyrighted work has been infringed, please contact [email protected] with the details listed in our Terms & Conditions (Section 17).
20. Changes to This Policy
We may update this Privacy Policy from time to time.
The latest version will always be available at https://anxietychecklist.com/privacy-policy. Material changes will be communicated via email or in-app notice.
What changed on September 16, 2026. We reviewed every tool on our website and in the App. Tracking now runs only from our own code, behind the cookie banner, with the providers listed in this policy. We stopped using Google Tag Manager (including a server-side setup hosted on Google Cloud) and the tools that older setup loaded on our website: Hotjar (heatmaps and session recordings), the TikTok Pixel, Brevo and an older Meta Pixel configuration. We also removed Singular and Mixpanel from our website and App. None of these receive new data from us.
Last Updated: September 16, 2026
21. Contact Us
If you have any questions or concerns regarding privacy, data handling, or this Policy, contact:
HOLDXB Trading FZCO
Dubai Silicon Oasis, DDP Building A2
Dubai, United Arab Emirates
- [email protected]
- [email protected] (Data Rights)
- [email protected] (Legal & Compliance)

