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MINDid Privacy Policy

Last updated: August 31, 2020

 

Introduction

 

MINDid LLC ('we' or 'us' or 'our') respects the privacy of our users ('Data User' or 'you'). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and the MINDid mobile application (jointly the “Services”). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SERVICES. 

 

The questions that we address in this Privacy Policy are:

 

1. What information do we collect from you?

2. Where do we collect information from you and how do we use it?

3. With whom do we share your information?

4. How can you update, correct or delete your Personally Identifiable Information?

5. What are your choices regarding collection, use and distribution of your information?

6. What security precautions are in place to protect against the loss, misuse or alteration of your information?

7. Do we use “cookies”?

8. What should you know about privacy policies and data collection at any third party sites accessible from our site?

9. What else should you know about your privacy online?

 

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will let you know via email and/or a prominent notice on our Services prior to the change becoming effective, and update the “effective date” at the top of this Privacy Policy.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Services after the date such revised Privacy Policy is posted. 

 

This Privacy Policy does not apply to any third-party online/mobile store from which you install the Services or make payments, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party. 

 

Definitions

 

These are some of the defined terms that are used throughout this Privacy Policy.  Other terms are defined as parts of our answers to questions.

 

App means our MINDid mobile application.

 

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.  For the purpose of this Privacy Policy, we are a Data Controller of your Personally Identifiable Information.

 

Data Processor(s) (or Service Provider(s)) means any natural or legal person who processes the data on behalf of the Data Controller.  We may use the services of various Service Providers in order to process your data more effectively.

 

Data Subject (or User) is any living individual who is using our Services and is the subject of Personally Identifiable Information.

 

Information Collection and Use is our ongoing practice of collecting several different types of information for various purposes to provide and improve our Services.

 

Services means the Website and the App. 

 

Usage Data is data collected automatically either generated by the use of the Services or from the infrastructure of the Services themselves (for example, the duration of a page visit).

 

Website means our website mindidapp.com. 

 

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1.   What information do we collect from you?

 

In order to better provide you with our numerous services, we collect two types of information about our users: Personally Identifiable Information and Non-Personally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our Services.

 

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on the Services, such as registering for a membership, ordering a product or service, submitting content and/or posting content in discussion forums or other public areas, filling out a survey, or sending us feedback, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information, such as your first and last name, nickname, mailing address (including zip code), e-mail address, birthday, demographic location, time zone, uploaded photos, and other personal identifying information. When ordering products or services on the Services, you may be asked to provide a credit card number. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.

 

Non-Personally Identifiable Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Website’s Uniform Resource Locator (“URL”) that you just came from, which URL you go to next, what browser you are using, and your Internet Protocol (“IP”) address. An URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.

 

2.   Where do we collect information from you and how do we use it?

 

We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you:

 

(a) register for our Services and register your email address with us;

 

(b) send e-mail messages, submit forms or transmit other information by telephone or letter; or

 

(c) submit your credit card or other payment information when ordering and purchasing products and services on our Services.

 

We may also collect information from you at other points on our Services that state that such information is being collected.

 

Derivative Data and Uploaded Media is information our servers automatically collect when you access the Services, such as your native actions that are integral to the Services, and actions taken when creating entries, editing entries and uploading media to the Services. As such, we may also request access to your device’s photo roll or camera in order for us to upload your media to the Services. Any media uploaded in this fashion will be collected and stored on our servers. If you wish to change our access or permissions, you may do so in your device’s settings. 

 

We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

 

The Services may - if you choose to sign in with Facebook - access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page. 

 

We may also collect user information from social networking sites, such as Facebook, including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the Services. 

 

We may request access or permission to, and track location-based information from your mobile device, either continuously or while you are using the Services, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings. 

 

We may request access or permission to certain features from your mobile device, including your mobile device’s reminders and other features. If you wish to change our access or permissions, you may do so in your device’s settings. 

 

We may collect device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide. 

 

In addition, we may also collect, or any third party ad server and/or content server may collect, certain Non-Personally Identifiable Information. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer our site and to gather demographic information. Any third party ad servers will also provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon at our site.

 

We use the collected data for various purposes:

 

• To provide and maintain our Services

• To generate a personal profile about you to make future visits to the Services more personalized 

• To notify you about changes to the Services

• To allow you to participate in interactive features of the Services when you choose to do so

• To provide customer support

• To gather analysis or valuable information so that we can improve the Services

• To monitor the usage of our Services

• To detect, prevent and address technical issues

• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about, unless you have opted not to receive such information

 

We will primarily use your Personally Identifiable Information to provide the Services to you, as required by our agreements with you. We may use your Personally Identifiable Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the Unsubscribe link or instructions provided in any email we send.

 

We will also use Personally Identifiable Information to enhance the operation of our site, fill orders, improve our marketing and promotional efforts, statistically analyze site use, improve our product and service offerings, and customize our Services’ content, layout, and services. We may use Personally Identifiable Information to deliver information to you and to contact you regarding administrative notices. We may also use Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Terms and Conditions of Use and this Private Policy.

 

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personally Identifiable Information we collect and the specific context in which we collect it.  We may process your Personally Identifiable Information because:

 

• We need to perform a contract with you

• You have given us permission to do so

• The processing is in our legitimate interest and it’s not overridden by your rights

• For payment processing purposes

• To comply with the law

 

We will take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personally Identifiable Information.  If you wish to be informed what Personally Identifiable Information we hold about you and if you want it to be removed from our systems, please contact us.

 

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personally Identifiable Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personally Identifiable Information.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests.

 

You have the right to complain to a Data Protection Authority about our collection and use of your Personally Identifiable Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

3. With whom do we share your information?

 

We do not sell, trade, or rent your Personally Identifiable Information to others. We may provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties. We and any service partners use your Personally Identifiable Information to operate our Services and to deliver their features. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this site; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us provide customer service.

 

We may employ third party companies and individuals to facilitate our Services (“Service Providers”), to provide some of the features of the Services on our behalf, to perform specified related tasks, or to assist us in analyzing how our Services are used.

 

These third parties have access to your Personally Identifiable Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

We may use third-party Service Providers to monitor and analyze the use of our Services.

For example, Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

 

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en 

 

We may provide paid products and/or services within the Services. In that case, we use third-party services for payment processing (e.g. payment processors).

 

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

 

The payment processors we work with are:

 

Apple Store In-App Payments: Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/ 

 

Google Play In-App Payments: Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/ 

 

 We will encourage our service partners to adopt and post privacy policies. However, the use of your Personally Identifiable Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

 

Occasionally we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

 

We may also disclose your Personally Identifiable Information in the good faith belief that such action is necessary to:

 

• Comply with a legal obligation

• Protect and defend our rights or property

• Prevent or investigate possible wrongdoing in connection with the Services

• Protect the personal safety of users of the Services or the public

• Protect against legal liability

 

We may also provide Non-Personally Identifiable Information about our customers’ sales, traffic patterns, and related site information to third party advertisers, but these statistics do not include any Personally Identifiable Information.

 

4. How can you update or correct your Personally Identifiable Information?

 

We believe you should have the ability to access and edit the Personally Identifiable Information that you have provided to us. You may change any of your Personally Identifiable Information in your account online at any time by linking to your account in accordance with instructions posted elsewhere on the Services. You may also access and correct your personal information and privacy preferences by emailing us at hello@mindidapp.com.  Please include your name and e-mail address when you contact us.

 

We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this site. In addition, it may be impossible to completely delete your information without some residual information because of backups.

 

5. What are your choices regarding collection, use, and distribution of your information?

 

We may, from time to time, send you e-mails regarding our features. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about features or products that we feel may be of interest to you. Only MINDid LLC (or agents working on behalf of MINDid LLC and under confidentiality agreements) will send you these direct mailings and only if you indicated that you do not object to these offers. If you do not want to receive such mailings, simply tell us when you give us your personal information. Or, at any time you can easily edit your account information to no longer receive such offers and mailings.

 

You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our site may not work properly in your case.

 

6. What security precautions are in place to protect against the loss, misuse, or alteration of your information?

 

At our Website and App you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our users is of utmost concern to us. Your Personally Identifiable Information is protected in several ways. Access by you to your Personally Identifiable Information is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your Personally Identifiable Information resides on a secure server that only selected MINDid LLC personnel and contractors have access to via password. We encrypt your Personally Identifiable Information and thereby prevent unauthorized parties from viewing such information when it is transmitted to us.

 

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through the Services cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

 

We do not support Do Not Track (“DNT”) signals under the California Online Privacy Protection Act (CalOPPA). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.  You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

Personal information that you provide that is not Personally Identifiable Information also resides on a secure server and is only accessible via password. Since this information is not accessible from outside MINDid, you will not be asked to select a password in order to view or modify such information.

 

In order to most efficiently serve you, credit card transactions and any order fulfillments are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.

 

7. Do we use “cookies”?

 

We use cookies and similar tracking technologies to track the activity on our Services and hold certain information.

 

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services.

 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

 

Examples of Cookies we use:

 

• Session Cookies. We use Session Cookies to operate our Services.

• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

• Security Cookies. We use Security Cookies for security purposes

 

We may use an outside ad-serving company to display banner advertisements on our Services. As part of their service, they will place a separate cookie on your computer. We will not provide any third-party ad server with any of your Personally Identifiable Information or information about your purchases. We and any third party ad server will collect and use Non-Personally Identifiable Information about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular ad. Other advertisers may also place banner ads on our site in the same manner as above, but we will not disclose any Personally Identifiable Information to them.

 

8. What should you know about privacy policies and data collection at any third party sites accessible from our site?

 

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other sites accessible through our Services have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. Additionally, other companies which place advertising on our Services may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

 

9. What else should you know about your privacy online?

 

You must be at least 18 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 18 years of age.  If you are a parent or guardian and you are aware that your child has provided us with Personally Identifiable Information, please contact us. If we become aware that we have collected Personally Identifiable Information from children without verification of parental consent, we will take steps to remove that information from our servers.

 

You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e. your name, e-mail address, etc.) in any discussion forums or other public areas on this Services, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas on the Services are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you’re online.

 

We may request to send you push notifications regarding your account or the Services. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings. 

 

We will retain your Personally Identifiable Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personally Identifiable Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

 

Your information, including Personally Identifiable Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

 

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personally Identifiable Information, to the United States and process it there.

 

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

 

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.  No transfer of your Personally Identifiable Information to an organization or a country will take place unless there are adequate controls in place, including the security of your data and other personal information.

 

If you have any questions about this Privacy Policy, the practices of the Services, or your dealings with the Services, please contact us email at hello@mindidapp.com

MINDid is a private digital wellness platform that helps individuals reflect on their well-being and enables organizations to extend support between formal touchpoints.

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