Privacy Policy

Data controller

OYHI LTD is the data controller responsible for your personal data. OYHI LTD is a company registered in Scotland (company number SC908560). Registered office: Office 785, 18 Young Street, Unit Lge, Edinburgh, EH2 4JB, Scotland. Contact: hello@oyhi.co.uk.

OYHI LTD was incorporated on 10 November 2026. James Walker, Founder and Director, is responsible for website data administration and privacy requests. This notice concerns the OYHI website and Pioneer recruitment, not the future private member product.

Pioneer applications

We collect your first name, email address, your declaration that you are aged 18 or over and currently live in the United Kingdom, and your agreement to receive correspondence about your application and, if selected, participation. We record submission and agreement times, the UK-residence confirmation time, application status and necessary administration and acknowledgement information.

You may choose a broad area of interest to help us understand the kinds of experience applicants would like to explore. It is optional and is not a request for your personal history. James Walker selects up to 100 Pioneers manually, seeking a reasonable variety of ordinary interests, ambitions and experiences. Optional categories are not rigid eligibility requirements. We do not score or profile applicants, infer health, disability, vulnerability or other sensitive characteristics, or discriminate on protected characteristics. Applying does not guarantee selection; the six-week pilot and complimentary membership offer are described in the Pioneer Charter.

The public launch form does not ask for an age band, medical information, personal narratives or how you found us. We do not attach campaign-source tags to new applications. A fixed registration-route marker is administrative information, not campaign attribution.

Please do not put health, disability, addiction, recovery, criminal-offence or other sensitive details into your name or contact information. You are welcome here without sharing your story. Eligibility is a self-declaration, not independent verification of your age or residence.

Contact enquiries

Contact Us collects your name, email address, a general message and submission time so we can consider and respond to your enquiry. Please keep your message general and avoid sensitive personal information. Saving a message does not send an automatic email reply.

Purposes and lawful bases

Our assessed basis for minimal recruitment administration, eligibility, duplicate prevention and necessary application correspondence is legitimate interests under Article 6(1)(f) UK GDPR: managing a fair, limited Pioneer recruitment process requested by applicants. Our assessment considers necessity, reasonable expectations, optional information, restricted access and retention. The required correspondence agreement records your request; it is not optional marketing consent or explicit consent to process special-category data.

General enquiries, necessary security and authorised administration also use assessed legitimate interests, limited to those purposes. Article 6(1)(b) applies only where processing is genuinely necessary for steps you request towards a specific agreement or its performance. Article 6(1)(c) applies only to identified legal duties, such as handling applicable data-protection rights or required breach notifications. These bases are not interchangeable blanket permissions.

The website does not automatically make selection decisions or use application answers in an AI feature. We do not sell applicant data or use it for advertising. New applications do not provide marketing permission, and we do not send optional promotional emails without a separately approved lawful arrangement.

Application emails

For a successfully saved new application, the website requests one administrative acknowledgement containing your first name and receipt/selection information, not personal answers. Duplicate applications do not request another acknowledgement. Sender: hello@notify.oyhi.co.uk; replies: hello@oyhi.co.uk. Delivery may be prevented by provider suppression or other failures; service acceptance is not proof of inbox delivery. A saved application is not removed because email fails.

Browser storage and visits

The proposed public launch does not automatically save Pioneer drafts, campaign tags or visitor-count flags in browser storage and does not record new Pioneer page events. Obsolete Pioneer storage keys are removed when the updated site loads, without restoring their contents. An optional application-return hint is held only in the current page application's memory; chapter and reading-return context use the URL.

Administrator sign-in uses persistent authentication storage and session refresh needed for the requested protected service. Ordinary browser storage uses local storage; an editor preview may use Lovable's authentication-storage broker. Exact hosted platform cookies, identifiers and lifetimes remain subject to verification. We have not added advertising analytics or tracking pixels.

Google Fonts is requested to display the site's typography. Hosting, image delivery and diagnostics may receive connection information. The absence of our own visitor tracking is not a claim that providers collect no operational data. Provider-injected storage and email tracking defaults must be verified before final approval.

Security and access

Security controls validate requests, limit abusive submissions, restrict direct public writes and protect administrator reads and exports. Network addresses are processed in requests; rate limiting stores hashed network identifiers, category and time. Hashing does not make these identifiers anonymous. Only James Walker is authorised to administer identifiable website applications and messages through the portal. Relevant service-provider access is governed separately.

Unexpected sensitive disclosures require restricted handling and case-specific legal review. No general Article 9 condition or Article 10 authority is assumed. We do not infer conditions or use such disclosures for selection or promotion.

Service providers and international processing

We use Lovable for website hosting, Lovable Cloud database/authentication and managed email; underlying infrastructure and delivery providers may process data on its behalf. Google supplies externally requested fonts. Lovable publishes its subprocessors and locations at its Trust Center. This list does not establish that every listed supplier receives every OYHI record.

OYHI uses Lovable's Business package, which includes its Data Processing Agreement. Lovable's published transfer terms incorporate the EU Standard Contractual Clauses and the UK Addendum for relevant transfers. We do not claim UK-only hosting. OYHI LTD remains responsible for assessing applicable transfer safeguards and ensuring its customer details and processing arrangements are correctly recorded. Provider operational-data uses may have separate controller roles.

Lovable's written confirmation says unexpected special-category disclosures are not excluded by the contractual provisions it cited. This is not permission to request sensitive data or a UK GDPR Article 9 condition. Our restricted procedure requires case-specific lawful handling and safeguards; unresolved questions are referred for qualified review.

Retention

We adopted a manual monthly retention review procedure on 10 November 2026. Reviews begin in December 2026 and are James Walker's responsibility. These are review/deletion criteria, not exact-date automatic deletion promises; unnecessary information should not be kept until a maximum period expires. Justified extensions are documented, limited and reviewed again.

• Contact messages: review for deletion 12 months after the conversation ends.
• Unsuccessful or withdrawn applications: six months after the final decision or withdrawal.
• Accepted records: essential participation/entitlement information during the programme, reviewed 12 months after the relationship ends.
• Legacy optional narratives: within three months after selection concludes, once unnecessary; the new public form does not collect them.
• Historical page events and abuse controls: review after 90 days, with a documented active-security-investigation exception. Shorter routine abuse-identifier retention remains under assessment.
• Temporary CSVs: securely delete when unnecessary, normally within seven days.
• OYHI-controlled development backups: review and delete when unnecessary, normally within 30 days of verified replacement.
• Suppression information: only as necessary to respect communication preferences.

Lovable has confirmed that it does not publish fixed retention periods for managed backups, operational logs or email records. We therefore cannot promise a fixed erasure date for those provider copies. Deletion from the active database does not instantly erase every backup, provider log, recipient email or downloaded copy. Remaining historical copies and other records require their own lawful assessment. Rights requests and sensitive-disclosure handling do not wait for a monthly review.

Your rights and complaints

Depending on the circumstances, you may request access, rectification, erasure or restriction; object to processing based on legitimate interests; and receive portability where its legal conditions apply. Where consent is actually the basis, you may withdraw it without affecting earlier lawful processing. These rights are subject to applicable conditions, not an unconditional promise to delete every record immediately.

Write to hello@oyhi.co.uk. We will handle requests under applicable UK GDPR deadlines, normally one month, with any permitted extension explained. You can complain to the Information Commissioner's Office. We keep necessary, proportionate evidence of requests and decisions.

Changes and approval

This notice does not replace historical lawful bases. Changes to the member product, sensitive-data use, marketing or suppliers require a fresh assessment. Effective date: 11 November 2026.