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.
Full 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.
* Sentry
(Used for anonymous, non-personally-identifiable crash/analytics)
Their Privacy Policy can be viewed at https://https://sentry.io/privacy/
* 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