Privacy

Last updated: September 1, 2025

1. Personal Data We Collect
2. How We Use Your Personal Data
3. Your Rights and Choices
4. Children's Privacy and Use Of The Services by Minors
5. How We Share Your Data
6. Data Transfers Outside EU/EEA
7. Security Measures
8. Data Retention
9. Legal Bases For Processing Your Personal Data
10. Changes to This Policy
11. Complaint to a Supervisory Authority
12. Contact Information

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Thank you for choosing Mindmymind (“Company”, “we”, “us”, or “our”), operated by Insula Sensorial Unipessoal LDA, a company incorporated in Portugal. 

We operate the website www.mindmymind.com (the “Site”), the Mindmymind mobile application for Android and iOS (the “App”), and other related services (collectively, the “Service”). 

The term “you” refers to any user of our Services.

This Privacy Policy explains how we collect, use, and disclose personal data that can identify you as an individual (referred to as “Personal Data”), as well as the rights and choices you have regarding these processes.

What Personal Data Do We Collect at Mindmymind?
We are committed to protecting the privacy and confidentiality of your Personal Data. When using the Mindmymind App, you may choose to share personal information as part of your conversations with your personal AI assistant. We only use your conversation data as described in this Privacy Policy, to make your interactions more secure and personal, and to help the AI better understand and adapt to your needs.

We may also collect technical and usage information from visits to our website (such as IP address, device type, and browsing behavior) in order to understand how our services are used and to promote them effectively.

‍We will never use or disclose the content of your conversations with the AI for marketing or advertising purposes.

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This Privacy Policy also explains the rights you have over your personal data. To learn more about your options and how to use them, please see Section 3 (“Your Rights and Choices”).

If you have any questions about this Privacy Policy or how we handle your personal data, please feel free to contact us at hello@mindmymind.com.
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Thank you for choosing Mindmymind (“Company”, “we”, “us”, or “our”), operated by Insula Sensorial Unipessoal LDA, a company incorporated in Portugal. 

We operate the website www.mindmymind.com (the “Site”), the Mindmymind mobile application for Android and iOS (the “App”), and other related services (collectively, the “Service”). 

The term “you” refers to any user of our Services.

This Privacy Policy explains how we collect, use, and disclose personal data that can identify you as an individual (referred to as “Personal Data”), as well as the rights and choices you have regarding these processes.

What Personal Data Do We Collect at Mindmymind?
We are committed to protecting the privacy and confidentiality of your Personal Data. When using the Mindmymind App, you may choose to share personal information as part of your conversations with your personal AI assistant. We only use your conversation data as described in this Privacy Policy, to make your interactions more secure and personal, and to help the AI better understand and adapt to your needs.

We may also collect technical and usage information from visits to our website (such as IP address, device type, and browsing behavior) in order to understand how our services are used and to promote them effectively.

‍We will never use or disclose the content of your conversations with the AI for marketing or advertising purposes.

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This Privacy Policy also explains the rights you have over your personal data. To learn more about your options and how to use them, please see Section 3 (“Your Rights and Choices”).

If you have any questions about this Privacy Policy or how we handle your personal data, please feel free to contact us at hello@mindmymind.com.
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1. Personal Data We Collect
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We collect the following categories of personal data:
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Personal data you provide to us directly
• Account and Contact Information: To create your Mindmymind account, you sign in using either your
Apple or Google account. When you do this, we receive basic information such as your name, email address, and phone number. We also generate a unique internal user ID to help manage your account securely and personalize your experience. For example, you might be assigned an ID like user12345.

• Inputs and Outputs: When you use the Service, you may share information by sending messages to your personal AI assistant. These messages can include facts about your life, your thoughts, or anything else you choose to share in either text or voice format. These messages are referred to as inputs. Based on your inputs, the AI provides responses known as outputs. These are designed to support your experience and adapt to your needs. Your messages may also include personal goals, areas of improvement, or reflections about your life. We use this information to personalise your experience and provide support that aligns with your development over time.

• Sensitive Information in Your Conversations: When using the Service, you may choose to share sensitive personal data, such as information about your health, religious beliefs, sexual orientation, political views, ethnic background, or other personal topics. We only use this information to provide and improve the Service, and never for marketing or advertising.

• Your Feedback: We welcome your feedback on how the Service works and how it can be improved. This includes suggestions, comments, or ratings of AI responses, which we refer to as feedback. For example, you might rate a response with a thumbs up or thumbs down.  When you submit feedback, we may save the related conversation so we can better understand the context of your input. This helps us improve the quality and relevance of the Service.  If we ask you to provide more detailed feedback, such as describing your experience or explaining an issue, we will always request your permission before collecting any additional personal information.

• Communication Information:If you contact us directly, such as by email or through a contact form, we may collect your name, email address, and the content of your message. This information is used to respond to your inquiry and provide support where needed.
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Personal Data We Collect Automatically
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When you use the Services, we automatically collect certain personal data related to your device, network, and how you interact with the platform. This type of data is sometimes referred to as “technical information” and includes the following:

• Device and Network information: We collect information about the device and internet connection you use to access the Service. This includes your operating system, device brand and model, browser type, language preferences, and general location such as city or region. We also collect technical identifiers like your IP address and cookie ID, which help us understand how the Service is used and ensure it works properly on your device.

• Usage Information: We collect data about how you use the Service. This includes actions you take within the app, such as buttons you tap, pages you view, and features you interact with.  We may also record the time and date of your activity to help us understand usage patterns and improve the experience.

• Cookies and Similar Technologies: We use cookies and similar technologies to operate and improve our services. These tools help us remember your preferences, keep the Service running smoothly, and enhance your overall experience.  If you use our services without creating an account, we may still use cookies to store information such as your language settings or other preferences, as described in this Privacy Policy. 

• Log and Troubleshooting Information: To maintain a stable and secure experience, we collect technical data about how the app functions during your use. This includes log files that help us detect and resolve issues. If an error occurs, we may collect information such as the time of the error, the part of the app you were using, the technical state of the app at that moment, and any relevant user input or system messages that help us understand and fix the issue.

If you download and use our app without creating an account, we may collect limited data to help us understand and improve the app. This may include:
• The features you explore
• How long you stay in the app
• General interaction patterns

This helps us learn how the app is used and improve your overall experience, even before you create an account.
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2. How We Use Your Personal Data
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We use your personal data to deliver and improve the Service. This includes:
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• Operating and maintaining your account
• Personalising your experience and AI conversations
• Responding to your requests and feedback
• Ensuring the security, integrity and reliability of the Service
• Detecting and preventing misuse, abuse or illegal activity
• Debugging and fixing technical issues
• Complying with legal obligations
• Improving the Service based on usage patterns and user needs
• Improving our AI systems to make them safer, more accurate, and more helpful for all users

You can find more information about the legal basis for using your data in Section 9.
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3. Your Rights and Choices
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Depending on where you live, privacy laws may give you the following rights:

‍• Access: Request a copy of your personal data
‍• Correction: Ask to update or correct your data
• Deletion: You can ask us to delete your personal data. In some cases, we may keep certain information if required by law or for legitimate business purposes.
• Restriction: You can ask us to limit how we use your data in certain situations. We may still keep or use the data if legally required.
• Data portability: Request your data in a transferable format
• Withdraw consent: If we process data based on your consent, you can withdraw it at any time
• Objection: You can object to certain uses of your personal data, especially when based on legitimate interests. We will consider your request, but we may continue processing if we have strong legal grounds.
• Automated decision-making: You have the right not to be subject to fully automated decisions that significantly affect you

To exercise any of these rights, contact us at hello@mindmymind.com. We may ask you to verify your identity before responding. We will not treat you differently for exercising your rights.

We’ve kept this overview simple so it’s easy to understand your rights. If you’re interested in the full details, you can read more here.
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4. Children’s Privacy and Use of the Service by Minors
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Our services are not intended for anyone under the age of 17. We do not knowingly collect, use, or share personal data from individuals under 17 years old. By using the Service, you confirm that you are at least 17. If we become aware that a user under the age of 17 has created an account or shared personal data, we will take steps to delete the data and deactivate the account.If you believe we may have collected information from a person under 17, please contact us at hello@mindmymind.com.
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5. How We Share Your Data
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We do not sell your personal data. We only share it when necessary to operate or improve the service, or when required by law. Below you can see who we may share data with, and what kind of information they might receive:
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• Service providers who help us run the app, store data, support users or understand how the service is used. They may receive technical data such as your IP address, device type, browser, and usage information. In some cases, they may also receive your email address or messages if they help us respond to support requests
‍• Authorities or legal bodies if we are required by law to share data, for example in connection with a legal case or investigation. This may include your account information, usage logs or other identifying details
‍• If ownership of the company changes, for example through a merger or acquisition, your profile and account data may be passed on as part of the business transfer
• With your permission, for example if you choose to connect Mindmymind with another app or platform, we may share the information you decide to include, such as your inputs or profile detailsWe only work with trusted partners and always require them to protect your information and use it only as we allow. If you want to know more about how we work with other companies and how your data is handled, you are welcome to contact us at hello@mindmymind.com
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6. Data Transfers Outside the EU/EEA
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We primarily process personal data within the European Union, where data protection laws apply equally. If your data is transferred outside the EU or European Economic Area, we ensure that appropriate safeguards are in place. This may include using standard contractual clauses approved by the European Commission or working with partners who adhere to recognized data protection frameworks.If you have questions about how we protect your data internationally, feel free to contact us at hello@mindmymind.com.
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7. Security Measures
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We take your privacy and data security seriously. To protect your information from unauthorised access, misuse, or disclosure, we use a variety of security practices:
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• We rely on secure login methods from Apple and Google. This means you can access the service without creating a separate password, reducing the risk of unauthorised access.
• Your phone number is used for verification purposes, to confirm that you are the rightful account holder and to help prevent abuse.
• We apply secure digital keys to control who can access your information inside our system. These keys make sure that only the right systems and authorised team members can access your data.
• Your data is stored using industry-level security standards, and only a limited number of people have access to it.

‍To help keep your information safe, we recommend the following:
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Use a trusted device when signing in
• Do not share access to your Apple or Google account
• Keep your phone number up to date so we can verify your identity if needed
• Always log out when you are done, and protect your device with a password or lock screen
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Please note that if someone gains access to your connected accounts or your device, they may be able to see personal data linked to your account.

‍Although we do everything we reasonably can to keep your data safe, no system is completely risk free. If a security incident happens that affects your data, we will inform you as quickly as possible in line with our legal obligations.
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8. Data Retention
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We keep your personal information for as long as you have an active account with us. If you choose to delete your account, we will remove or anonymise the personal information linked to it, unless we are required by law to keep it for a longer period.

In some situations, we may keep limited information for a short time after your account has been deleted. This may be necessary to meet legal requirements, handle financial reporting, or ensure the safety and integrity of our service.

When we decide how long to store your data, we consider the type of information, how sensitive it is, why we collected it, the risk of harm if it is misused, and whether the purpose can still be met in other ways. We always aim to store personal data only for as long as needed, and in line with the laws that apply.

‍How we store and use your message content
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When you interact with Sparks (your AI assistant), your conversations are securely stored to support a consistent and personalised experience across your devices.

To help improve the quality of responses and ensure better performance over time, we may process selected message content that has not been deleted by you. Before doing so, we take steps to remove information that could directly identify you, including any sensitive personal data you may have shared.

This process helps us improve the service while respecting your privacy. The choice is always yours: if you delete a conversation, it will be permanently removed from our systems and will not be used for further improvement.

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We never use your conversations for marketing or advertising, and we only use them to enhance the AI’s ability to respond more helpfully and naturally in future interactions.
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9. Legal Bases for Processing Your Personal Data
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To use your personal data, we must have a valid legal basis under applicable data protection laws. In this section, we explain the different legal bases we rely on and when each one applies.

To protect your rights and ensure transparency, we are committed to handling your data with care and in accordance with the law. To make it easier for you to understand how and why we process your personal data, we have organised this section by each legal basis.The legal bases we use are described in the following order:

• Consent: When we ask for your clear agreement to use your personal data for a specific purpose, such as sending you marketing updates. You can withdraw your consent at any time.

• Contractual Necessity: When we need to process your data in order to provide our services under a contract with you. This includes actions such as creating and managing your account or verifying information before entering into an agreement.

• Legitimate Interest: When we have a justified reason to use your data in a way that is necessary for our operations and does not unfairly affect your rights. For example, we may analyse general usage patterns to improve our services.
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You have the right to object to processing based on legitimate interests. However, we may continue processing your data if we can demonstrate that our reasons override your interests, rights, or freedoms. You are always welcome to contact us if you would like more information.

• Legal Obligation: When we must process certain data to comply with legal requirements, such as regulatory, tax, or accounting obligations.Each legal basis is explained in more detail in the following sections.:
Purpose
Type of Data
Legal basis
Marketing and advertising the services. This includes sending you emails or notifications about updates, features, or surveys, and showing you relevant ads.
• Account information (e.g. name, email)
• Device and network data (e.g. IP address, device type)
• Usage data (e.g. interaction patterns)
• Survey
Consent
Use of cookies and similar technologies to understand how users interact with the site, personalise content, and deliver relevant marketing. You can manage your cookie preferences at any time. Strictly necessary cookies are always active.
• Usage data (such as page views, clicks, and general interaction with the website)
Consent And Contractual necessity
Managing and supporting the Mindmymind services. This includes creating and maintaining your account, processing your inputs to provide responses, handling payments, responding to feedback, and sending service-related updates.
• Registration data
• User data
• Usage data
Contractual necessity
Diagnosing and resolving technical or service-related issues. This includes analysing error reports, reviewing user activity and content, and responding to feedback in order to ensure the stability and reliability of the service.
• Registration data
• User data
• Usage data
• User messages or content
Contractual necessity
Enabling core features within the service, such as content sharing, user interaction tools, and other expected platform functionality that is essential for delivering the service experience.
• Registration data
• User data
• Usage data
• Relevant message content where needed for functionality
Contractual necessity
Providing the core functionality of the app, including personalising the AI assistant, managing your profile and interests, syncing your conversation history across devices, and ensuring secure and individualised sessions.
• Registration data
• User data
• Usage data
• User messages or content
Contractual necessity
We process your personal data to help ensure the safety, security, and integrity of our services. This includes preventing fraud, misuse, and other harmful activity, as well as maintaining and supporting the underlying IT systems and infrastructure.
• Registration data
• User data
• Usage data
• User messages or content (only when strictly necessary to investigate suspected misuse or illegal activity)
Legitimate Interest
To improve and adapt our AI model, we may process message content from your interactions within the app. Before doing so, we remove information that could directly identify you, ensuring your privacy is respected while supporting model improvements. This helps us understand user needs and enhance the model’s ability to respond in a meaningful and personalised way. 
• Message content from your interactions with Sparks
This processing is based on our legitimate interest in developing and maintaining a high-quality, safe and relevant service. You have the right to object to this use of your data at any time.You also have full control over your data: if you delete a conversation in the app, the associated message content will also be deleted from our systems and will be excluded from any further processing.
We may use your information to enforce our terms, prevent fraud, respond to disputes, and protect our rights or those of other users.
• Registration data
• User data
• Usage data
Legitimate Interest  
We process your personal data to comply with legal obligations and protect our rights and services. This includes maintaining records, verifying user age, responding to lawful requests from authorities, fulfilling tax and regulatory requirements, enforcing our terms, preventing misuse or fraud, and handling disputes.
• Registration data
• User data
• Usage data
• Message content
Legal Obligations And Legitimate Interest 

10. Changes to This Policy
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We may update this Privacy Policy from time to time to reflect changes in our services, legal obligations, or other relevant developments. If we make material changes, we will notify you clearly, either through the app, by email, or by other appropriate means, depending on the nature of the change. We encourage you to review this policy regularly to stay informed about how we protect your personal data.
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11. Complaint to a Supervisory Authority
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If, as a data subject, you wish to file a complaint with the supervisory authority regarding our processing of your personal data, you can contact them at the following number or email.

Comissão Nacional de Proteção de Dados – CNPD  https://www.cnpd.pt 
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Phone number:(+351) 213 928 400 
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12. Contact Information
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If you have any questions or concerns about this Privacy Policy or how we handle your personal data, you can contact us at:
‍E-mail: hello@mindmymind.com

Write to the following address:
Rua Olivença 1a, 2765-262 Estoril, Portugal
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Insula Sensorial Unipessoal LDA  is the data controller of personal data processed under this Policy

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