Privacy Policy ============== Summary ======= Mindfulness is a deeply personal activity centered on mental health: we designed our app and website to respect and preserve your privacy. We do not use any cookies in our website (e.g. all fonts and images are served from our website without using any cookies). We do not collect any personal data or any identifiable data from our app (unless you sent them yourself, e.g. feedback form). In particular, your Mindfulplay Journal remains on-device and in your control. Minimal crash data and anonymized usage data is logged for the sole purpose of improving our app. Please read the full legalese version below for more details. ---------------------------------------------------------------------------------------------- Legal Version ============= This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We do not use Your Personal Data and only use aggregated data to improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. Interpretation and Definitions ============================== Interpretation -------------- The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. Definitions ----------- For the purposes of this Privacy Policy: * Account means a unique account created for You to access our Service or parts of our Service. * Application (App) means the software program provided by the Company downloaded by You on any electronic device, named Mindfulplay. * Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California. * Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to MindfulPlays LLC. For the purpose of the GDPR, the Company is the Data Controller. * Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose. * Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses. * Country refers to: United States * Data Controller , for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. * Device means any device that can access the Service such as a computer, a cellphone or a digital tablet. * Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. * Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You. * Service refers to the Application or the Website or both. * Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors. * Aggregated Data refers to combined data from groups of users that does not have any information relating to you and can not be linked to You * Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). * Website refers to Mindfulplay, accessible from https://www.mindfulplay.app * You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service. Collecting and Using Aggregated Data ==================================== Types of Data Collected ----------------------- Aggregated Data ~~~~~~~~~~~~~~~ While using Our Service, We may automatically collect and aggregate some information. Because Your information is immediately stripped off of any potential identifiable personal information and aggregated, Your Personal Data will not be stored, tracked, used, or transferred to third-parties. Such information may include but is not limited to: * Usage Data * Website and App Performance Data Usage Data ~~~~~~~~~~ Usage Data is collected automatically when using the Service. Usage Data may include information such as browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, that is not personally identifiable and aggregated, non-identifiable diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, and other non-identifiable diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device. Website and App Performance Data ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Website and App performance data is collected automatically when using the Service on App and when you visit Website. This data may include Website or App crashes, how long it takes for Website or App to function as intended. Use of Aggregated Data --------------------------------- The Company may use aggregated, non-identifiable data for the following purposes: * To provide and maintain our Service, including to monitor the usage of our Service. * For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. Retention of Your Aggregated Data --------------------------------------- The Company will retain Usage Data and Website and App performance for internal analysis purposes. 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 Service, or We are legally obligated to retain this data for longer time periods. Transfer of Aggregated Data -------------------------------------- Aggregated Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this 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. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that all data is treated securely and in accordance with this Privacy Policy and no transfer of any data will take place to an organization or a country. Disclosure of Aggregated Data ---------------------------------------- Law enforcement ~~~~~~~~~~~~~~~ Under certain circumstances, the Company may be required to disclose Aggregated Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Other legal requirements ~~~~~~~~~~~~~~~~~~~~~~~~ The Company may disclose Aggregated Data in the good faith belief that such action is necessary to: * Comply with a legal obligation * Protect and defend the rights or property of the Company * Prevent or investigate possible wrongdoing in connection with the Service * Protect against legal liability Security of Aggregated Data ------------------------------ The security of Aggregated Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect all data, We cannot guarantee its absolute security. Detailed Information on the Processing of Aggregated Data ==================================================================== The Service Providers We use may have access to Aggregated Data. These third-party vendors collect, store, use, process and transfer information about activities on Our Service in accordance with their Privacy Policies. Analytics --------- We may use third-party Service providers to monitor and analyze the use of our Service. * Visual Studio App Center Their Privacy Policy can be viewed at https://privacy.microsoft.com/en- us/privacystatement * CloudFlare web analytics Their Privacy Policy can be viewed at https://www.cloudflare.com/privacypolicy/ Email Marketing --------------- We may use Your Personal Data that you voluntarily provide to Us to contact You with newsletters, product updates, 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 or by contacting Us. We may use Email Marketing Service Providers to manage and send emails to You. * Postmark Their Privacy Policy can be viewed at https://wildbit.com/privacy-policy Payments -------- We may provide paid products and/or services within the Service. In that case, we may 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. * 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/ GDPR Privacy ============ Legal Basis for Processing Personal Data under GDPR --------------------------------------------------- We may process Personal Data only when You voluntarily provide to Us and You have given Your consent for processing Personal Data for one or more specific purposes. In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. Your Rights under the GDPR -------------------------- When you voluntarily provide Your Personal Data to Us, The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to: * Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You. * Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected. * Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes. * Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it. * Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You. * Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. Exercising of Your GDPR Data Protection Rights ---------------------------------------------- You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA. CCPA Privacy ============ This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California. Categories of Personal Information Collected -------------------------------------------- We do not collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information for your reference. Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but rather reflects our good faith belief to the best of our knowledge that none of that information from any applicable category have been collected. For example, certain categories of personal information would only be collected if You voluntarily provided such personal information directly to Us. * Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. Collected: No. * Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: No. * Category C: Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No. * Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: No. * Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No. * Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement. Collected: No. * Category G: Geolocation data. Examples: Approximate physical location. Collected: No. * Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No. * Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: No. * Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No. * Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No. Under CCPA, personal information does not include: * Publicly available information from government records * Deidentified or aggregated consumer information * Information excluded from the CCPA's scope, such as: * Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data * Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994 Sources of Personal Information ------------------------------- If We ever obtain the categories of personal information listed above, the sources are: * Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, such as Your feedback sent to our Service or from Your purchases on our Service. Use of Personal Information for Business Purposes or Commercial Purposes ------------------------------------------------------------------------ We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples: * To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service. * To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. Please note that the examples provided above are illustrative and not intended to be exhaustive. If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy. Sale of Personal Information of Minors Under 16 Years of Age ------------------------------------------------------------ We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission. We do not sell the personal information of Consumers We actually know are less than 16 years of age. If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information. Your Rights under the CCPA -------------------------- The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights: * The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used. * The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You: - The categories of personal information We collected about You - The categories of sources for the personal information We collected about You - The categories of third parties with whom We share that personal information - The specific pieces of personal information We collected about You * The right to delete Personal Data. You have the right to request the deletion of Your Personal Data. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records. * The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by: - Denying goods or services to You - Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties - Providing a different level or quality of goods or services to You - Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services Exercising Your CCPA Data Protection Rights ------------------------------------------- In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us: * By email: privacy@mindfulplay.app * By visiting this page on our website: https://mindfulplay.app/privacy Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information. Your request to Us must: * Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative * Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it We cannot respond to Your request or provide You with the required information if We cannot: * Verify Your identity or authority to make the request * And confirm that the personal information relates to You We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice. Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt. For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance. "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA) ============================================================================= Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser. Children's Privacy ================== Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. Changes to this Privacy Policy ============================== We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Contact Us ========== If you have any questions about this Privacy Policy, You can contact us: * By email: privacy@mindfulplay.app * By visiting this page on our website: https://mindfulplay.app/en/privacy