PRIVACY AND COOKIE POLICY

Version 1.0 · Effective 31 July 2026

This Privacy and Cookie Policy explains how Tendn Ltd (Company No. 17154922) ("Tendn", "we", "us" or "our") collects, uses, stores and discloses personal data when you use our mobile application, our website at https://tendn.app (the "Website") and our related services (together, the "Services").

Tendn provides an educational and training tool for clinicians and trainees to develop musculoskeletal ultrasound scanning technique. The Services are strictly for training purposes and are not intended to diagnose, treat or replace clinical judgement or professional supervision.

We are committed to protecting your personal data and handling it in accordance with the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018 ("DPA 2018"). Please read this policy carefully so that you understand our practices regarding your personal data.

By using the Services, you acknowledge that you have read and understood this policy. If you do not agree with this policy, please do not use the Services.

1 WHO WE ARE AND HOW TO CONTACT US

Tendn is the data controller responsible for the personal data described in this policy, except in relation to Scan Data (as described in the section headed "Ultrasound scan data and our role as processor"), where our role and responsibilities differ.

If you have any questions about this policy or about how we handle your personal data, you can contact us at:

2 KEY DETAILS

Data controllerTendn Ltd (Company No. 17154922)
Registered address71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Emailsupport@tendn.app
Data protection contactHasan Iqbal

3 WHAT THIS POLICY APPLIES TO

This policy applies to personal data we collect from and about:

individual users who create an account and use the Services, including doctors, physiotherapists, sonography students, paramedics and medical students;

users who access the Services through an institution, such as a hospital or university, that has purchased access for its trainees; and

visitors to the Website.

This policy does not apply to any third party websites, applications or services that may be linked to from the Services. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

4 PERSONAL DATA WE COLLECT

We collect and process the following categories of personal data:

4.1 Information you provide to us

When you register for and use the Services, we collect information you provide directly, including:

your name and username;

your professional role and the institution you are associated with (if any);

your self-reported experience level (for example, beginner, intermediate or advanced) and your training goals;

details of the ultrasound scanner or probe you use;

your email address and account password; and

any other information you choose to provide, including when you contact us for support or provide feedback.

4.2 Information we collect from your use of the Services

When you use the Services, we automatically collect certain training and usage information, including:

session and scan performance metrics, such as the time taken to complete a scan and quality scores or percentages generated by the app;

records of your progress against the curriculum and supervisor feedback and sign-off within the app; and

technical information about the device you use, including device type, operating system, app version and log data.

5 ULTRASOUND SCAN DATA

The Services allow you to capture, save and review ultrasound scan footage and associated screen recordings ("Scan Data"). Scan Data may contain special category data concerning health within the meaning of Article 9 of the UK GDPR, whether it relates to you or to another individual you are scanning.

Where you use the Services to scan an individual, you (or the institution through which you access the Services) act as the controller of that Scan Data. Tendn processes Scan Data only on your behalf and on your documented instructions, as a processor. Tendn does not use Scan Data for its own purposes.

You should be aware that scan footage and screen recordings are processed by Tendn on your behalf, and are also processed by you within the app. Our processing of Scan Data as a processor, including the security measures, sub-processors, retention and return or deletion of Scan Data, is governed by a separate Data Processing Agreement rather than by this policy, available here: https://tendn.app/dpa.

Where an individual other than an account holder is scanned (for example, a friend, family member or colleague on whom a trainee practises), you are responsible for providing that individual with appropriate privacy information and for obtaining any consent required before capturing Scan Data.

6 HOW WE USE YOUR PERSONAL DATA AND OUR LAWFUL BASES

We use your personal data (as controller) for the purposes set out below. In each case we rely on one or more lawful bases under Article 6 of the UK GDPR.

6.1 To provide and manage the Services

We use your account and usage information to create and administer your account, provide the Services, deliver curriculum content, generate real-time feedback and progress tracking, and enable supervisor feedback and sign-off. Our lawful basis is the performance of our contract with you, or the taking of steps at your request before entering into a contract.

6.2 To communicate with you

We use your contact details to respond to your queries, provide support and send you service-related communications. Our lawful basis is our legitimate interests in operating and supporting the Services, and performance of our contract with you.

6.3 To improve the Services and train our models

We use de-identified and aggregated scan metrics, such as the time taken to complete a scan and quality scores or percentages, to improve, test and develop the Services, including to train and refine our AI models. Data used for this purpose is anonymised so that it does not identify you or any individual, and once anonymised it is no longer personal data. Where we process identifiable usage information for this purpose before anonymisation, our lawful basis is our legitimate interests in improving and developing the Services.

We do not use identifiable Scan Data (including scan footage or screen recordings) for the training of our models or for our own purposes. Any use of Scan Data is limited to our role as processor as described above.

6.4 To keep the Services secure and comply with our obligations

We use personal data to maintain the security and integrity of the Services, to detect and prevent fraud or misuse, and to comply with our legal and regulatory obligations. Our lawful bases are our legitimate interests and compliance with a legal obligation.

7 MARKETING

Where you have consented, or where we are otherwise permitted to do so, we may send you information about the Services and related offerings that may be of interest to you. You can opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting us. Opting out will not affect service-related communications.

8 WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with:

service providers and sub-processors who help us operate the Services, including cloud hosting, storage, payment processing and analytics providers, who are only permitted to process personal data in accordance with our instructions;

the institution through which you access the Services, where you use the Services as part of an institutional cohort, in relation to your progress and training records;

professional advisers, such as lawyers, accountants and auditors, where reasonably necessary;

a purchaser or successor in connection with any actual or proposed sale, merger or reorganisation of our business; and

regulators, law enforcement or other authorities where we are required or permitted to do so by law.

We do not sell your personal data to third parties.

9 INTERNATIONAL TRANSFERS

We are based in the United Kingdom. Some of our service providers and sub-processors may store or process personal data outside the UK.

Where we transfer personal data outside the UK, we will ensure that appropriate safeguards are in place to protect it, such as transfers to a country that the UK has determined provides an adequate level of protection, or the use of the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any supplementary measures required. You can request further information about these safeguards by contacting us.

10 HOW LONG WE KEEP YOUR PERSONAL DATA

We keep your personal data only for as long as necessary for the purposes for which it was collected, including to provide the Services, to comply with our legal, accounting or reporting obligations, and to resolve disputes.

When you close your account, we will delete or anonymise your personal data within a reasonable period, unless we are required to retain it for legal or regulatory reasons. The retention, return and deletion of Scan Data processed by us as a processor is governed by the separate Data Processing Agreement.

11 HOW WE KEEP YOUR PERSONAL DATA SECURE

We use appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. These measures include access controls, encryption in transit and at rest where appropriate, and restricting access to those who need it.

While we take reasonable steps to protect your personal data, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12 YOUR DATA PROTECTION RIGHTS

Subject to certain conditions and exceptions under the UK GDPR, you have the following rights in relation to your personal data:

the right to be informed about how we use your personal data;

the right to access the personal data we hold about you;

the right to have inaccurate or incomplete personal data corrected;

the right to have your personal data erased in certain circumstances;

the right to restrict or object to our processing of your personal data;

the right to data portability; and

where our processing is based on consent, the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the details set out in this policy. We will respond within the timeframes required by law. There is usually no fee, although we may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive. Where you wish to exercise your rights in relation to Scan Data processed by us as a processor, we will assist the relevant controller in accordance with the Data Processing Agreement.

13 COOKIES

Cookies are small text files that are placed on your device when you visit a website. We currently use cookieless analytics, provided by Plausible Analytics which tracks metrics without capturing personal data. If we later change our cookie use, we will update this section and, where required, obtain your consent before placing any non-essential cookies.

14 CHILDREN

The Services are intended for clinicians, trainees and students and are not directed at children under the age of 18. We do not knowingly collect personal data from children. If you believe we have collected personal data from a child, please contact us and we will take steps to delete it.

15 COMPLAINTS

If you have any concerns about how we handle your personal data, please contact us first so that we can try to resolve the matter. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection, at https://ico.org.uk or by calling 0303 123 1113.

16 CHANGES TO THIS POLICY

We may update this policy from time to time. Where we make material changes, we will notify you by appropriate means, such as through the Services or by email. This policy was last updated on 31 July 2026.

17 CONTACT US

If you have any questions or requests about this policy or your personal data, please contact us at support@tendn.app or at https://tendn.app/contact-us