Legal · Product

Morgan Privacy Notice

Last updated 13 July 2026

Pre-launch draft — finalised before Morgan is generally available

This notice explains how Morgan, the product built by Emotional Computing Ltd, handles your personal data. It is separate from our website Privacy Policy, which covers this site only. Because Morgan is a companion you talk to, it necessarily works with more personal information than a website — so we set out clearly what that is, where it lives, and the control you keep over it.

Who we are

Emotional Computing Ltd — Company No. 17082850, registered in the United Kingdom — is the data controller for personal data processed by Morgan. Registered with the UK Information Commissioner’s Office (ICO), reference ZC198257. Contact: hello@emotionalcomputing.co.uk.

What Morgan processes

Your conversations — what you say to Morgan, by text or voice, and Morgan’s responses.
Voice audio — where you speak to Morgan, to understand you and to reply in a natural voice.
Memory — the things Morgan remembers to be a consistent companion: people, preferences, context, and the meaning of past conversations.
Settings & preferences — such as your chosen voice and how you like Morgan to behave.
Technical & usage data — information needed to run the service reliably and securely.

Why we use it

We use this information solely to provide Morgan to you — to understand you, remember context, respond, and keep the service reliable and safe. We do not sell your data, we do not profile you for advertising, and we do not use your conversations to train third-party AI models. Our lawful bases are your consent and performance of our agreement with you.

Where your data is held

Morgan runs on Microsoft Azure. Your memory is stored in the United Kingdom (UK West), and Morgan’s core reasoning runs primarily on models hosted in the United Kingdom (UK South). Some fast responses and image or video generation use a third-party AI provider that may process outside the UK, under appropriate safeguards and terms that never use your data for training. Your stored memory always stays in the United Kingdom.

As on-device technology matures (see Morgan OS), more of this will run locally on your own hardware, keeping even more of your data on your device.

Who processes it on our behalf

We rely on a small number of trusted sub-processors, each bound by data-protection terms that forbid using your data to train their AI models:

Microsoft Azure — hosting, storage, and most of Morgan’s AI reasoning, all within Microsoft’s environment.
Specialist AI providers — for certain features, such as fast responses and image or video generation, each under enterprise or paid terms that prohibit training on your data.

A current, full list of our sub-processors is available on request — just email hello@emotionalcomputing.co.uk.

Your control

You can review and delete what Morgan remembers, and ask us to delete your data entirely. We keep your data only while you use Morgan and for up to 18 months after your last activity — or sooner if you ask us to delete it — after which we remove it.

Security

Your data is encrypted in transit and at rest. Actions Morgan takes on your behalf pass through policy checks and are recorded in a tamper-evident log, sensitive steps ask for your confirmation first, and Morgan is designed to resist instructions hidden in the content it reads.

Older and vulnerable users

Morgan is intended to support connection and wellbeing, including for older adults. It is not a medical device and is not a substitute for professional, medical, or emergency care. Where Morgan is set up for someone who cannot give their own consent, it should be done by a person with the proper authority to do so on their behalf, and with their best interests in mind. We take safeguarding seriously and welcome contact from carers and families at hello@emotionalcomputing.co.uk.

Children

Morgan is not directed at children and is not intended for use by children without the consent and supervision of a parent or guardian.

International transfers

Where the optional avatar feature processes data in the EU, that transfer is protected by appropriate safeguards. We do not transfer your data outside the UK and EU.

Your rights

Under UK GDPR (and EU GDPR where applicable) you have the right to access, correct, delete, or receive a copy of your data, to withdraw consent, and to object to or restrict processing. To exercise these, email hello@emotionalcomputing.co.uk. You can also complain to the UK Information Commissioner’s Office (ico.org.uk).

Changes

Morgan is evolving, and we will finalise and update this notice as the product develops. The current version will always be available here.

Questions about how Morgan handles your data? Email hello@emotionalcomputing.co.uk.