Privacy Policy

Last updated: July 2026

1. Introduction

At Sabender, we believe trust is essential when people use technology to reflect on their wellbeing, resilience, and personal development.

Sabender combines behavioural science, Positive Health principles, Empowerment principles, and Artificial Intelligence to provide personalised reflection and resilience support through the Sabender platform and SAM, Sabender's proprietary AI mentor.

SAM is designed to support users through reflective conversations, helping them better understand their situation, explore new perspectives, and identify authentic next steps. Users remain the driver of their own growth, while SAM acts as a navigator supporting reflection and personal development.

This Privacy Policy explains how Sabender collects, uses, protects, and manages personal information when you use our services. It explains your privacy rights and how Sabender applies responsible data processing practices.

Sabender is committed to privacy by design, data minimisation, transparency, security by design, and responsible Artificial Intelligence.

2. Who We Are

The Sabender platform is operated by:

Sabender Inc.
80 Broad Street
New York, NY 10004
United States

Sabender Inc. is responsible for ensuring that personal information is processed responsibly and securely.

For users located in the European Union or European Economic Area, the European representative is:

Sabender / 360Outspoken B.V.
Feike de Boerlaan 177
1019 WG Amsterdam
The Netherlands

Contact email:
info@sabender.com

3. Our Privacy Commitment

Sabender follows internationally recognised privacy principles, with a primary focus on compliance with the General Data Protection Regulation (GDPR) for users located in the European Union and European Economic Area.

Our privacy approach is based on:

  • Privacy by Design;
  • Security by Design;
  • Data Minimisation;
  • Transparency;
  • Purpose Limitation;
  • Human Oversight;
  • Responsible Artificial Intelligence.

Sabender only processes information necessary to provide personalised resilience support, maintain platform security, and improve the quality of our services.

4. What Information We Process

Depending on how you use Sabender, we may process the following categories of personal information.

Account and Profile Information

This may include:

  • name;
  • email address;
  • account identifiers;
  • phone number (where provided);
  • age or age range;
  • country;
  • city or region;
  • living area information (where provided);
  • gender (where provided);
  • nationality (where provided);
  • employment type (where provided);
  • seniority level (where provided);
  • organisation information where applicable.

This information supports account management, personalised platform experiences, relevant content recommendations, and improvement of our services.

Wellbeing and Reflection Information

To provide personalised resilience support, Sabender may process information that you voluntarily provide, including:

  • responses to resilience assessments;
  • reflections shared during conversations with SAM;
  • personal goals;
  • experiences and situations you choose to explore;
  • topics you choose to discuss;
  • interactions with resilience modules and exercises;
  • progress within the platform.

This information supports reflection, self-awareness, resilience development, and identifying authentic next steps.

Technical Information

We may process technical information necessary to provide a secure service, including:

  • device information;
  • authentication information;
  • security logs;
  • platform usage information;
  • technical performance information.

5. How We Use Your Information

Sabender processes personal information for the following purposes.

Providing Personalised Support

To:

  • facilitate conversations with SAM;
  • provide personalised reflections;
  • recommend relevant modules, exercises, and practical tools;
  • support users in identifying meaningful next steps.

Improving the Platform

To:

  • improve usability;
  • monitor platform performance;
  • strengthen security;
  • evaluate user experience;
  • improve the quality and reliability of our technology.

Ensuring Safety and Security

To:

  • protect user accounts;
  • detect misuse;
  • maintain platform integrity;
  • prevent security incidents.

6. How Artificial Intelligence Processes Information

SAM uses Artificial Intelligence to support reflective conversations.

AI is used as a supportive technology and does not replace human expertise, professional judgement, or personal decision-making.

Sabender separates responsibilities between different technological components:

  • The Sabender platform securely manages user information.
  • Sabender's proprietary algorithms apply Sabender's scientifically grounded methodology.
  • SAM uses Artificial Intelligence to communicate supportive reflections and guidance in natural language.

The underlying Large Language Model (LLM) functions as a language generation component only. It does not diagnose conditions, make decisions on behalf of users, or independently change Sabender's methodology.

Personal information processed through the Large Language Model is not used to train the underlying AI model.

7. Data Minimisation and AI Processing

Sabender applies Privacy by Design and GDPR principles.

SAM only receives the information necessary for the specific interaction.

Complete personal profiles, historical conversations, and unnecessary personal information are not shared with SAM or the underlying AI language model unless required to provide the requested service.

Sabender applies technical and organisational safeguards to minimise unnecessary data exposure.

8. Healthcare and Patient Data

Sabender supports wellbeing, resilience, self-reflection, and self-management.

Sabender is not a medical device, diagnostic service, healthcare provider, or replacement for professional healthcare.

In healthcare collaborations, Sabender does not transfer identifiable patient conversations, reflections, or personal wellbeing information to healthcare providers unless explicitly agreed with the user and legally permitted.

Healthcare organisations do not receive access to individual SAM conversations or personal reflections.

Sabender is not currently HIPAA certified and does not represent itself as a HIPAA-covered entity. However, Sabender applies privacy and security safeguards designed to protect personal information and support responsible collaboration with healthcare stakeholders.

9. Employer and Organisation Access

For organisational customers, individual reflections, conversations with SAM, and personal wellbeing information remain private.

Employers or organisations do not receive access to individual conversations or personal reflection data.

Where organisational insights are provided, these are based on aggregated information designed to protect individual privacy and support organisational improvement.

10. Data Storage and Security

Sabender stores customer information using secure European infrastructure.

Our production environment is hosted in Frankfurt, Germany.

Sabender applies appropriate technical and organisational measures, including:

  • encryption of data in transit and at rest;
  • secure authentication;
  • access controls;
  • restricted production access;
  • vulnerability management;
  • secure software development practices;
  • security monitoring.

Access to personal information is limited to authorised personnel who require access for legitimate business purposes.

11. Data Retention

Sabender retains personal information only for as long as necessary to provide services, maintain security, and fulfil legal obligations.

Information processed by the Large Language Model is retained for a maximum of 30 days for operational reliability, security monitoring, and service integrity purposes.

Information stored within the Sabender platform remains available while your account is active.

When you request permanent deletion of your account, personal information associated with your account will be deleted within 30 days unless longer retention is required by applicable law.

12. Your Privacy Rights

Depending on applicable legislation, including GDPR where applicable, you may have the following rights:

  • access your personal information;
  • correct inaccurate or incomplete information;
  • request deletion of your information;
  • restrict certain processing activities;
  • object to specific processing;
  • receive your information in a structured, commonly used, machine-readable format and request transfer of your information to another service provider where applicable;
  • withdraw consent where processing is based on consent;
  • receive information about how your data is processed;
  • exercise your rights without discrimination or unfair treatment.

How to Exercise Your Rights

You can exercise your rights by contacting:

Sabender Inc.
80 Broad Street
New York, NY 10004
United States

or:

Sabender / 360Outspoken B.V.
Feike de Boerlaan 177
1019 WG Amsterdam
The Netherlands

Email:
info@sabender.com

To protect your privacy, we may request information to verify your identity before processing your request.

Sabender will acknowledge privacy requests within a reasonable timeframe and respond within the legally required period applicable to your location. Where GDPR applies, responses are generally provided within one month. If additional time is required, we will inform you.

13. Consent and User Choices

Depending on the type of processing, Sabender relies on different lawful bases, including providing the service, legitimate interests, contractual necessity, and consent where required.

Consent may be obtained through:

  • account registration;
  • onboarding processes;
  • explicit permission requests for optional processing activities.

Users may withdraw consent at any time where processing is based on consent.

Withdrawal of consent does not affect processing that was lawfully performed before withdrawal.

14. Children's Privacy

Sabender is designed for adults aged 18 and over.

Sabender is not validated, designed, or intended for children or young people under the age of 18.

We do not intentionally collect personal information from children.

If we become aware that personal information has been collected from a person under the applicable minimum age, we will take appropriate steps to review and delete such information where required.

15. Cookies and Similar Technologies

Sabender uses cookies and similar technologies where necessary to operate, secure, and improve the platform.

Cookies may be used for:

  • authentication and account security;
  • platform functionality;
  • performance monitoring;
  • improving user experience.

Where required by applicable legislation, Sabender requests consent before placing non-essential cookies.

Additional information is available in the Sabender Cookie Policy.

16. Data Sharing

Sabender does not sell personal information.

Personal information is only shared when necessary to:

  • provide our services;
  • maintain security;
  • operate our technology infrastructure;
  • comply with legal obligations.

External service providers process information only according to contractual agreements and appropriate privacy and security requirements.

17. International Data Transfers

Because Sabender operates internationally, personal information may be processed in different jurisdictions.

Where personal information is transferred internationally, Sabender applies appropriate safeguards consistent with applicable privacy legislation, including GDPR requirements where applicable.

18. Automated Decision-Making

Sabender does not use Artificial Intelligence to make decisions that create legal or similarly significant effects for individuals.

SAM does not:

  • diagnose medical conditions;
  • determine employment decisions;
  • evaluate employee performance;
  • determine access to healthcare services;
  • make decisions on behalf of users.

AI supports reflection and personal development while users remain in control of their own choices.

19. Changes to This Privacy Policy

Sabender may update this Privacy Policy from time to time to reflect changes in technology, legislation, services, or privacy practices.

The latest version will always indicate the date of revision.

20. Contact

For questions regarding privacy, data protection, or this Privacy Policy, please contact:

Sabender Inc.
80 Broad Street
New York, NY 10004
United States

Email:
info@sabender.com

Cookie Policy

Last updated: July 2026

1. Introduction

Sabender uses cookies and similar technologies to operate, secure, and improve our website and platform. These technologies help us authenticate users, remember preferences, maintain security, and, where you consent, understand how our services are used so we can continue improving them.

This Cookie Policy explains what cookies are, which types of cookies Sabender uses, how you can manage your preferences, and how these technologies relate to your privacy.

For more information about how we process personal information, please refer to our Privacy Policy.

2. Who We Are

The Sabender platform is operated by:

Sabender Inc.
80 Broad Street
New York, NY 10004
United States

For users located in the European Union or European Economic Area, the European representative is:

Sabender / 360Outspoken B.V.
Amsterdam
The Netherlands

For questions about this Cookie Policy, please contact:

Email: info@sabender.com

3. What Are Cookies?

Cookies are small text files that are stored on your device when you visit a website or use certain online services. Cookies help websites recognise your device, remember information about your visit, improve security, and provide a more consistent user experience.

Sabender may also use similar technologies, including browser Local Storage and session storage, which support secure authentication, user preferences, and platform functionality.

Sabender does not intentionally store directly identifiable personal information in cookies. Where cookies contain identifiers that may be considered personal data under applicable privacy legislation, they are processed in accordance with our Privacy Policy.

4. Cookies We Use

Sabender currently uses the following categories of cookies and similar technologies.

CategoryPurposeCan you opt out?
Essential Cookies Required for authentication, security, fraud prevention, session management, and core platform functionality. Most are session-based and expire when your browser closes. Some security cookies remain active for up to 3–4 months to support secure account access. No. These cookies are necessary for the platform to function correctly.
Analytics Cookies Google Analytics is used to understand website usage, improve performance, and enhance the user experience. Analytics cookies are only placed after consent where required by applicable law. Yes. You may accept or reject analytics cookies at any time.

5. Managing Your Cookie Preferences

When you first visit the Sabender website, you will be presented with a cookie banner that allows you to:

  • accept all cookies;
  • reject non-essential cookies; or
  • review additional information through the Privacy Preference Centre.

Google Analytics is only activated after you have provided consent. If you decline analytics cookies, they will not be loaded. If analytics cookies were previously active and you later withdraw your consent, they will be disabled.

Your cookie preferences are stored in your browser and, where applicable, within your account so they can be remembered across future visits.

You can change your preferences at any time through the Cookie Preferences section within your account settings.

6. Blocking or Deleting Cookies

Most web browsers allow you to manage cookies through their settings.

You may choose to:

  • block all cookies;
  • delete previously stored cookies;
  • receive notifications before cookies are placed; or
  • allow only selected categories of cookies.

Please note that disabling essential cookies may affect authentication, security, and the proper functioning of the Sabender platform. Certain features may become unavailable or operate incorrectly.

Deleting cookies from your browser does not automatically withdraw any consent previously recorded through the Sabender cookie preference system. You may update your preferences at any time using the Cookie Preferences settings.

7. Local Storage and Session Technologies

In addition to cookies, Sabender may use browser Local Storage and session storage technologies.

These technologies support:

  • secure authentication;
  • maintaining your signed-in session;
  • remembering user preferences;
  • improving platform performance and reliability.

Unlike cookies, Local Storage remains within your browser until it is cleared by you or by the application, while session storage is automatically removed when your browser session ends.

8. Children's Privacy

Sabender is designed exclusively for adults aged 18 years and over.

The platform is not intended for children or young people under the age of 18, and we do not knowingly collect personal information from minors.

Age is currently self-declared during onboarding and is not independently verified. If we become aware that personal information has been collected from someone under 18, we will take appropriate steps to delete the information and close the associated account where required.

Parents or guardians who believe that a child has provided personal information may contact us at info@sabender.com.

9. Changes to This Cookie Policy

Sabender may update this Cookie Policy from time to time to reflect changes in technology, legislation, or our services.

The latest version will always display the revision date at the top of this policy.

10. Contact

If you have any questions about this Cookie Policy or your cookie preferences, please contact:

Sabender Inc.
80 Broad Street
New York, NY 10004
United States

European Representative

Sabender / 360Outspoken B.V.
Amsterdam
The Netherlands

Email: info@sabender.com