Privacy
Last updated: 15. October 2024.
Thank you for joining Mindmymind (“Company”, “we”, “us”, “our”), which also refers to Insula Sensorial Unipessoal LDA, incorporated in Portugal.
We operate the website https://www.mindmymind.com (the “Site) and the mobile application Mindmymind on Android and iSO (the “App”), and other related services (collectively, the “Service”.
The term “you” refers to the user of the Services.
This privacy Policy explains how we collect, use, and disclose personal information that can identify you as an individual (referred to as “Personal Data” in this policy), as well as the choices and rights you have regarding these processes.
What is Personal information at Mindmymind?
We are committed to protecting the privacy and confidentiality of your personal information. When you use the app, you may choose to share personal information during conversations with your personal AI. We process this information solely as described in this Privacy Policy, including enabling personalised and secure conversation, as well as allowing the AI to adapt and enhance your experience based on your interaction. We may also use information about your visit to our website to promote our services.
We will never use or disclose the content of your conversations with the AI for marketing or advertising purposes.
If you have any questions, please feel free to contact us.
1. Personal data we collect about you.
These tables outline the categories of personal data we collect, divided into information you provide when registering and using the service, information you choose to share, and information we collect independently.
Account Information: We collect personal information about you when you register as a user of one of our services. Without it, you are not able to register. This information includes:
Contact, Account and Profile information
To create an account at our service we need information about you. This may include your:
• Full name
• Email address
• Password
• Phone number
• Date of birth
• Gender
• Street address
• Country
Payment and transaction information
You need to provide your bank account information to register as a user. It will include information such as:
• Name
• Date of birth
• Payment method type
• If using a debit or credit card, the card type, expiration date, and certain digits of your card number
• ZIP/postal code
• Mobile phone number
• Details of your purchase and payment history
For security reasons, we do not store your full card number.
Information You Choose to Share:
Below is the information you have chosen to share with us.
Messages and content:
You may provide information through the messages you send and receive through the Service. You may provide us facts about you or your life, and any voice and text messages you provide.
Goals and Personal Development Information:
You may choose to share information about your personal goals, what you hope to achieve, and areas where you feel you have weaknesses. We may collect this information to better personalise your experience and provide guidance tailored to your development needs. Additionally, through your interactions with the service, we may learn more about your goals and challenges over time to further customise your experience.
Survey and Research Data:
When you participate in a survey or user research, we collect and use the personal data you share.
Cookies and Similar Technologies:
We use cookies and similar tools to run and manage our services while enhancing your overall experience. If you access our services without creating an account, we may use cookies to store certain information mentioned in this policy—such as maintaining your preferences across browsing sessions.
Information We Collect:
We automatically collect certain information about you, including your device, your network, and your interactions with our Services over time.
Device and Network information:
This includes details about your computer or mobile device such as operating system, manufacturer, model, browser type, device and cookie identifiers, language settings, and general location information like city, state, or geographic area.
Usage Information:
This includes data on how you use our services, such as your interactions within the app, links and buttons you click, and pages you visit.
Cookies and Similar Technologies:
We use cookies and similar tools to run and manage our services while enhancing your overall experience. If you access our services without creating an account, we may use cookies to store certain information mentioned in this policy—such as maintaining your preferences across browsing sessions.
If you download our app and explore it without creating an account, we collect limited data about your app usage, including basic usage information. This helps us understand how you access and interact with the app, allowing us to enhance the user experience.
IMPORTANT INFORMATION REGARDING SENSITIVE DATA
Our services allow you to share information that may be considered sensitive and is protected under certain laws. This section explains how we handle and safeguard such information.
Sensitive information you may provide in conversations and content:
During your interactions with the AI, you may choose to share information regarding your religious beliefs, sexual orientation, political views, health, racial or ethnic background, philosophical beliefs, or trade union membership. By sharing this information, you consent to our use of it as outlined in this Privacy Policy.
Please note that we will never use your sensitive information – or any content from your conversations – for marketing or advertising purposes. Additionally, we do not use any data from your interactions to train our AI model. Your data is solely used to provide and enhance our services, with full respect for your privacy.
2. Your personal data rights and controls
Various privacy laws grant individuals rights over their personal data, including the General Data Protection Regulation (GDPR).
Below outlines:
1) Your rights
2) The conditions under which they apply (such as the required legal basis),
3) Instructions on how to exercise them.
It’s your right to:
- Be informed
Receive information about the personal data we process about you and the ways in which we handle it.
We inform:
• when you create an account
• through this Privacy Policy Through information provided as you use our service
• By answering specific questions and requests when you contact us.
We recommend reading all information carefully.
- Get access
Request access to the personal data we hold and process about you.
You can contact us at hello@mindmymind.com We will get back to you as soon as possible, in accordance with GDPR regulations.
- Rectification
If the information we hold about you is inaccurate or incomplete, you have the right to request that we correct or update your personal data. You can update your User Data through the 'Edit Profile' option in your account or by reaching out to us on following: hello@mindmymind.com
- Withdraw your consent
Withdraw your consent for us to collect or use your personal data. This applies if we are processing your personal data based on your consent. To withdraw your consent, you can:
• Adjust the relevant settings in your account,
• Contact us directly at hello@mindmymind.com
Please note that certain information is required for the service to function, and by withdrawing your consent, you will no longer be able to use the service.
- Object
Object to our processing of your personal data. You may do this if:
• We are processing your personal data based on legitimate interests, or
• We are processing your personal data for personalised advertising.
If you wish to exercise your right to object, please contact us at hello@mindmymind.com
- Not to be subjected to automated decision-making
Under GDPR, you have the right not to be subjected to decisions based solely on automated processing (decisions made without human involvement), including profiling, when such decisions have a legal impact on you or similarly significant effects.
Under no circumstances do we carry out this type of automated decision-making in our service.
- Right to erasure (right to be forgotten)
You have the right to request the deletion of your personal data.
In accordance with our commitment to integrity and confidentiality, please contact us via email at hello@mindmymind.com to request data deletion.
Right to lodge a Complaint
If you have any questions or concerns about our handling of your personal data, you have the right to lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados - CNPD). You can find contact information for the Portuguese Data Protection Authority here.
3. How we use your information
To use your information, we must have a valid legal basis. We explain the different legal bases and when each one is applied. To ensure your rights and protect your privacy, we are committed to handling your data with the utmost care and transparency.
To make it easier for you as a user to understand the legal bases we rely on for processing your information, the following section is organised by each legal basis. These will be explained in the following order:
a) Consent: When we request your explicit agreement to use your personal data for a particular purpose.
b) Contractual necessity: When necessary to fulfil our obligations to you under a contract, such as providing our service according to our Terms of Use or verifying information before starting a new contract
c) Legitimate Interest: When we have a justified reason to use your personal data in a way that balances any potential risks to you and other users. For instance, we may use usage data to improve our service. Contact us if you would like more information about a specific justification.
d) Compliance with Legal Obligations: When processing is required to fulfil legal obligations.Consent In some cases, we rely on your consent to process your personal data. This means that we will ask for your explicit permission to use your data for specific purposes, ensuring you have full control over how your information is used.
The following applies in relation to this:
Purpose
Why and how we collect Categories of personal data used for the purpose
- Marketing and advertising the Services
Providing you with emails or in-app notifications with information we believe may interest you, such as details about our services, features, and surveys. Displaying and targeting advertisements for our services online.
• Account information.
• Device and network data.
• Usage data
• Survey and Research Data
- Optional Features
To offer certain additional, optional features of the mindmymind service, we will clearly request your consent when necessary.
This allows us to offer enhanced, personalised experiences while ensuring you have control over the data you share with us.
• User Data
• Usage Data
• Survey and Research Data
• Payment and Purchase Data
- Cookies and Similar Technologies
You have the option to make your own choices regarding cookie preferences. Opting out of cookies such as those for analytics, marketing, or personalization will not impact your ability to use the website. Strictly necessary cookies will remain enabled to ensure basic website functionality, but you are free to manage the other cookie types in the settings at any time.
• User Data Usage
- Contractual necessity
In some cases, we process your personal data because it is necessary to fulfill our contractual obligations to you. This means we use your information to provide the core features and services you signed up for, ensuring we can meet the terms of our agreement.
The following applies in relation to this:
Purpose
Why and how we collect Categories of personal data used for the purposeManaging and Supporting the ServicesTo provide, support, and maintain the content and functionality of the mindmymind services, as well as to fulfill our contractual obligations to you.
This includes:
• Creating and personalising your account and profile,
• Facilitating payments and transactions, including purchases of premium features and managing rewards
Responding to your inquiries, feedback, and troubleshooting requests
•Managing our relationship with you, including sending administrative information related to our services.
- Data Collected During Registration:
• User Data
• Usage Data
• Payment and Purchase Data
•Issue Resolution
We use your information to diagnose, identify, and resolve any issues with the service. This may include analysing error reports, monitoring service usage, and reviewing feedback to quickly address any technical problems and improve overall performance.
- Data Collected During Registration
• User Data
• Usage Data
• Payment and Purchase Data
• Messages and content
• Marketing and advertising the Services
Sending you emails in-app notifications with information we believe may interest you, such as details about our services, features, and surveys. Displaying and targeting advertisements for our services online.
• Account information.
• Device and network data.
• Usage data
• Survey and Research Data
• Legitimate Interest
In some cases, we process your personal data based on our legitimate interest. This means that we use your information in ways that are necessary for improving our services, provided that this does not override your rights and freedoms. We ensure that our use of data is balanced and beneficial for both you and the service.The following applies in relation to this:
Purpose
Why and how we collect
Categories of personal data used for the purpose
Enhancing Service Features
We use your personal data to provide additional features within the Service. For example, this allows you to share a link to content with others, enhancing your experience and enabling greater interaction within the platform.
We process your data under Legitimate Interest to keep the Service running smoothly and to ensure all essential functions are operational, allowing users to access and fully utilise the features of the service.
Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and content
Core App Features and Functionality
Delivering the essential functionality of the app, providing you with a personalised AI, and enabling you to customise your profile, interests, and AI interactions. This includes ensuring individualised, secure conversations and allowing your AI to learn from your interactions to enhance future conversations. Additionally, syncing your interaction history across all devices you use to access the service.
- Data Collected During Registration
• User Data Usage Data
• Payment and Purchase Data
• Messages and content
• Interests and preferences
Enhancing Features and User Experience
We use your information to evaluate and develop new features, technologies, and improvements for the mindmymind service. This helps us enhance the service and create a better experience for you. Our legitimate interest is in continuously improving our products and features. Importantly, we do not use personal data to train our AI, ensuring your data is used solely to support and enhance your experience with the service.User Data Usage Data Survey and Research Data
Safeguarding and Maintaining the Services
Preventing fraud, criminal activity, and misuse of our services, while ensuring the security of our IT systems, infrastructure, and networks (including testing, system maintenance, support, and data hosting).Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and contentInterests and preferences
Advertising the Services
We may use your information for marketing and advertising our services based on our legitimate interest. This includes promoting features or updates we believe may be relevant to you, while balancing our interests with respect for your privacy.Account information.Device and network data. Usage dataSurvey and Research Data
Ensuring Compliance and Protecting Rights
We use your information to enforce our agreements, uphold our terms and policies, and comply with legal obligations. This includes protecting our rights, privacy, safety, and property, as well as those of our users. We also work to maintain the integrity of our services, verify the age of registered users, defend against legal claims and disputes, recover payments owed to us, keep records of transactions, and comply with legal processes as required.Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and contentInterests and preferences
Research and surveys
We use your information for research and surveys to better understand user needs and improve our services. This falls under our Legitimate Interest in enhancing the user experience and developing relevant features. By conducting research and gathering feedback through surveys, we can make informed improvements that benefit all users.User Data Usage Data Survey and ResearchData
Cookies and Similar Technologies
You have the option to manage your cookie preferences. Strictly necessary cookies are essential for the website to function properly and cannot be disabled.
•User data
•Usage data
• Survey and Research Data
Compliance with Legal ObligationsIn some cases, we process personal data to comply with legal and regulatory requirements. This ensures that we meet our obligations under applicable laws, protect user rights, and respond appropriately to legal requests or proceedings.
The following applies in relation to this:
Purpose
Why and how we collect Categories of personal data used for the purposeResponding to Legal Requests and InvestigationsWe may process certain information as required by law, including responding to valid legal requests (e.g., search warrants or subpoenas) from regulators, law enforcement, or other entities. For example, we may be required to provide specific information such as your IP address or profile details in relation to a legal investigation. Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and contentInterests and preferences
4. Who do we share your information with?
Information we may share:
Recipients
Information regarding why
Categories of personal data
Service Provider And Marketing Partners
We share your information with companies and individuals who provide services on our behalf or assist us in operating our services and business (such as hosting, IT support, customer service, and website analytics). We also share information with companies that provide marketing services for us; however, we do not share the content of your conversations for marketing or advertising purposes.
For example, we may share usage data with analytics providers to better understand how users engage with our service and to help identify others who may be interested. We require these providers to agree not to use this data for any other purpose, ensuring they only use it to provide their services to us.
- Data Collected During Registration
• User Data
• Usage Data
• Payment and Purchase Data
• Interests and preferences
• Payment Partners
We share subscription-related information with payment partners, such as Google Play and the App Store, to process and manage payments. Details regarding these transactions are outlined in our Terms and Conditions, which you can read here.
User Data
Payment and Purchase Data
Law Enforcement and Legal ProceedingsWhen we believe in good faith that it is necessary, we may share information with law enforcement, government authorities, or relevant third parties.
This may occur, for example:
to fulfill a legal obligation,to respond to a valid legal process (such as a search warrant, court order, or subpoena), orto protect our own or a third party’s legitimate interests, including in matters of:national security,law enforcement,ongoing litigation,criminal investigations,ensuring someone’s safety, orpreventing death or imminent bodily harm.
Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and contentInterests and preferences
Business Transfers and Acquisitions
We may share information with acquirers or other relevant parties involved in business transactions or negotiations, such as mergers, acquisitions, reorganisations, or sales of all or part of our business or assets. In the event of such a transaction (including bankruptcy or similar proceedings), your personal data may be transferred to the acquiring party or affiliate as part of the transition.User Data Data UsageData Payment and PurchaseData Survey and Research Data
5. Keeping your personal data safe
We implement a range of industry-standard security measures and protocols to safeguard your data from unauthorised access, misuse, or disclosure.
Apple and Google authentication:
We prioritise your privacy and security by utilising authentication methods provided by Apple and Google. We use your phone number for verification to confirm that it belongs to you and to prevent misuse.
This approach prevents unauthorised access while ensuring a seamless and secure login experience.
To maintain the highest level of security:
Only use trusted devices for login.
Avoid sharing your linked Apple or Google accounts with others.Ensure your phone number remains up-to-date for verification purposes.
Please note: If others gain access to your authenticated accounts or devices, they may view your personal data, settings, and services linked to your account. Always log out when finished and secure your device to prevent misuse.
Security:
To ensure secure access to your data, we use personalised access tokens when retrieving information via our API. These tokens provide an added layer of security by allowing only authorised access to your data within the system. Access tokens are uniquely assigned, limiting who can view or interact with your information, and are a crucial part of our efforts to protect your data from unauthorised access or misuse. Although we make commercially reasonable efforts to secure your data, no technology, data transmission, or system can be completely guaranteed as 100% secure. If a security breach occurs that results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access to your data, we will inform you promptly upon identifying the issue.
6. Data retention
We will retain your personal information for as long as you have an active account with us. Once you delete your account, all personal information associated with it will be removed.
Please note that conversations between you and the AI are not stored or retained. We ensure that your data is kept only as long as necessary to provide the service and fulfill any legal or reporting obligations.In determining the retention period, we consider factors such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use, and whether the purposes for processing can be achieved by other means, in compliance with applicable legal requirements.
7. Information from minors
We do not knowingly collect or share information from anyone under 18 years old, nor do we target our services to them. By using our services, you confirm that you are 18 or older. If we find out that a user has created an account despite being under 18, we will deactivate the account and delete the information. If you know of any data we may have from a person under 18, please contact us at hello@mindmymind.com
8. Transfer to other countries
Our services are operated from Portugal. If you are located in another country, please be aware that the information you provide to us may be transferred to, stored, and processed in Portugal, which are subject to EU privacy regulations. Regardless of the location, it is essential that we comply with all applicable rules, ensuring that your personal information is not transferred in a way that violates your rights.
9. Changes to this Policy
We may update this Policy from time to time. If we make significant changes, we will provide you with clear notice, either via email or a notification within the app, depending on the situation.
10. Complaint to a Supervisory Authority
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
Phone number:(+351) 213 928 400
Email: geral@cnpd.pt
11. Contact information
If you have any questions or concerns regarding this Policy, please contact our Data Protection Officer using any of the following methods:
E-mail: hello@mindmymind.com
Write to the following address: Mindmymind, Rahbeks Alle 21, 1801 Frederiksberg C
Insula Sensorial Unipessoal LDA is the data controller of personal data processed under this Policy
Thank you for joining Mindmymind (“Company”, “we”, “us”, “our”), which also refers to Insula Sensorial Unipessoal LDA, incorporated in Portugal.
We operate the website https://www.mindmymind.com (the “Site) and the mobile application Mindmymind on Android and iSO (the “App”), and other related services (collectively, the “Service”.
The term “you” refers to the user of the Services.
This privacy Policy explains how we collect, use, and disclose personal information that can identify you as an individual (referred to as “Personal Data” in this policy), as well as the choices and rights you have regarding these processes.
What is Personal information at Mindmymind?
We are committed to protecting the privacy and confidentiality of your personal information. When you use the app, you may choose to share personal information during conversations with your personal AI. We process this information solely as described in this Privacy Policy, including enabling personalised and secure conversation, as well as allowing the AI to adapt and enhance your experience based on your interaction. We may also use information about your visit to our website to promote our services.
We will never use or disclose the content of your conversations with the AI for marketing or advertising purposes.
If you have any questions, please feel free to contact us.
1. Personal data we collect about you.
These tables outline the categories of personal data we collect, divided into information you provide when registering and using the service, information you choose to share, and information we collect independently.
Account Information: We collect personal information about you when you register as a user of one of our services. Without it, you are not able to register. This information includes:
Contact, Account and Profile information
To create an account at our service we need information about you. This may include your:
• Full name
• Email address
• Password
• Phone number
• Date of birth
• Gender
• Street address
• Country
Payment and transaction information
You need to provide your bank account information to register as a user. It will include information such as:
• Name
• Date of birth
• Payment method type
• If using a debit or credit card, the card type, expiration date, and certain digits of your card number
• ZIP/postal code
• Mobile phone number
• Details of your purchase and payment history
For security reasons, we do not store your full card number.
Information You Choose to Share:
Below is the information you have chosen to share with us.
Messages and content:
You may provide information through the messages you send and receive through the Service. You may provide us facts about you or your life, and any voice and text messages you provide.
Goals and Personal Development Information:
You may choose to share information about your personal goals, what you hope to achieve, and areas where you feel you have weaknesses. We may collect this information to better personalise your experience and provide guidance tailored to your development needs. Additionally, through your interactions with the service, we may learn more about your goals and challenges over time to further customise your experience.
Survey and Research Data:
When you participate in a survey or user research, we collect and use the personal data you share.
Cookies and Similar Technologies:
We use cookies and similar tools to run and manage our services while enhancing your overall experience. If you access our services without creating an account, we may use cookies to store certain information mentioned in this policy—such as maintaining your preferences across browsing sessions.
Information We Collect:
We automatically collect certain information about you, including your device, your network, and your interactions with our Services over time.
Device and Network information:
This includes details about your computer or mobile device such as operating system, manufacturer, model, browser type, device and cookie identifiers, language settings, and general location information like city, state, or geographic area.
Usage Information:
This includes data on how you use our services, such as your interactions within the app, links and buttons you click, and pages you visit.
Cookies and Similar Technologies:
We use cookies and similar tools to run and manage our services while enhancing your overall experience. If you access our services without creating an account, we may use cookies to store certain information mentioned in this policy—such as maintaining your preferences across browsing sessions.
If you download our app and explore it without creating an account, we collect limited data about your app usage, including basic usage information. This helps us understand how you access and interact with the app, allowing us to enhance the user experience.
IMPORTANT INFORMATION REGARDING SENSITIVE DATA
Our services allow you to share information that may be considered sensitive and is protected under certain laws. This section explains how we handle and safeguard such information.
Sensitive information you may provide in conversations and content:
During your interactions with the AI, you may choose to share information regarding your religious beliefs, sexual orientation, political views, health, racial or ethnic background, philosophical beliefs, or trade union membership. By sharing this information, you consent to our use of it as outlined in this Privacy Policy.
Please note that we will never use your sensitive information – or any content from your conversations – for marketing or advertising purposes. Additionally, we do not use any data from your interactions to train our AI model. Your data is solely used to provide and enhance our services, with full respect for your privacy.
2. Your personal data rights and controls
Various privacy laws grant individuals rights over their personal data, including the General Data Protection Regulation (GDPR).
Below outlines:
1) Your rights
2) The conditions under which they apply (such as the required legal basis),
3) Instructions on how to exercise them.
It’s your right to:
- Be informed
Receive information about the personal data we process about you and the ways in which we handle it.
We inform:
• when you create an account
• through this Privacy Policy Through information provided as you use our service
• By answering specific questions and requests when you contact us.
We recommend reading all information carefully.
- Get access
Request access to the personal data we hold and process about you.
You can contact us at hello@mindmymind.com We will get back to you as soon as possible, in accordance with GDPR regulations.
- Rectification
If the information we hold about you is inaccurate or incomplete, you have the right to request that we correct or update your personal data. You can update your User Data through the 'Edit Profile' option in your account or by reaching out to us on following: hello@mindmymind.com
- Withdraw your consent
Withdraw your consent for us to collect or use your personal data. This applies if we are processing your personal data based on your consent. To withdraw your consent, you can:
• Adjust the relevant settings in your account,
• Contact us directly at hello@mindmymind.com
Please note that certain information is required for the service to function, and by withdrawing your consent, you will no longer be able to use the service.
- Object
Object to our processing of your personal data. You may do this if:
• We are processing your personal data based on legitimate interests, or
• We are processing your personal data for personalised advertising.
If you wish to exercise your right to object, please contact us at hello@mindmymind.com
- Not to be subjected to automated decision-making
Under GDPR, you have the right not to be subjected to decisions based solely on automated processing (decisions made without human involvement), including profiling, when such decisions have a legal impact on you or similarly significant effects.
Under no circumstances do we carry out this type of automated decision-making in our service.
- Right to erasure (right to be forgotten)
You have the right to request the deletion of your personal data.
In accordance with our commitment to integrity and confidentiality, please contact us via email at hello@mindmymind.com to request data deletion.
Right to lodge a Complaint
If you have any questions or concerns about our handling of your personal data, you have the right to lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados - CNPD). You can find contact information for the Portuguese Data Protection Authority here.
3. How we use your information
To use your information, we must have a valid legal basis. We explain the different legal bases and when each one is applied. To ensure your rights and protect your privacy, we are committed to handling your data with the utmost care and transparency.
To make it easier for you as a user to understand the legal bases we rely on for processing your information, the following section is organised by each legal basis. These will be explained in the following order:
a) Consent: When we request your explicit agreement to use your personal data for a particular purpose.
b) Contractual necessity: When necessary to fulfil our obligations to you under a contract, such as providing our service according to our Terms of Use or verifying information before starting a new contract
c) Legitimate Interest: When we have a justified reason to use your personal data in a way that balances any potential risks to you and other users. For instance, we may use usage data to improve our service. Contact us if you would like more information about a specific justification.
d) Compliance with Legal Obligations: When processing is required to fulfil legal obligations.Consent In some cases, we rely on your consent to process your personal data. This means that we will ask for your explicit permission to use your data for specific purposes, ensuring you have full control over how your information is used.
The following applies in relation to this:
Purpose
Why and how we collect Categories of personal data used for the purpose
- Marketing and advertising the Services
Providing you with emails or in-app notifications with information we believe may interest you, such as details about our services, features, and surveys. Displaying and targeting advertisements for our services online.
• Account information.
• Device and network data.
• Usage data
• Survey and Research Data
- Optional Features
To offer certain additional, optional features of the mindmymind service, we will clearly request your consent when necessary.
This allows us to offer enhanced, personalised experiences while ensuring you have control over the data you share with us.
• User Data
• Usage Data
• Survey and Research Data
• Payment and Purchase Data
- Cookies and Similar Technologies
You have the option to make your own choices regarding cookie preferences. Opting out of cookies such as those for analytics, marketing, or personalization will not impact your ability to use the website. Strictly necessary cookies will remain enabled to ensure basic website functionality, but you are free to manage the other cookie types in the settings at any time.
• User Data Usage
- Contractual necessity
In some cases, we process your personal data because it is necessary to fulfill our contractual obligations to you. This means we use your information to provide the core features and services you signed up for, ensuring we can meet the terms of our agreement.
The following applies in relation to this:
Purpose
Why and how we collect Categories of personal data used for the purposeManaging and Supporting the ServicesTo provide, support, and maintain the content and functionality of the mindmymind services, as well as to fulfill our contractual obligations to you.
This includes:
• Creating and personalising your account and profile,
• Facilitating payments and transactions, including purchases of premium features and managing rewards
Responding to your inquiries, feedback, and troubleshooting requests
•Managing our relationship with you, including sending administrative information related to our services.
- Data Collected During Registration:
• User Data
• Usage Data
• Payment and Purchase Data
•Issue Resolution
We use your information to diagnose, identify, and resolve any issues with the service. This may include analysing error reports, monitoring service usage, and reviewing feedback to quickly address any technical problems and improve overall performance.
- Data Collected During Registration
• User Data
• Usage Data
• Payment and Purchase Data
• Messages and content
• Marketing and advertising the Services
Sending you emails in-app notifications with information we believe may interest you, such as details about our services, features, and surveys. Displaying and targeting advertisements for our services online.
• Account information.
• Device and network data.
• Usage data
• Survey and Research Data
• Legitimate Interest
In some cases, we process your personal data based on our legitimate interest. This means that we use your information in ways that are necessary for improving our services, provided that this does not override your rights and freedoms. We ensure that our use of data is balanced and beneficial for both you and the service.The following applies in relation to this:
Purpose
Why and how we collect
Categories of personal data used for the purpose
Enhancing Service Features
We use your personal data to provide additional features within the Service. For example, this allows you to share a link to content with others, enhancing your experience and enabling greater interaction within the platform.
We process your data under Legitimate Interest to keep the Service running smoothly and to ensure all essential functions are operational, allowing users to access and fully utilise the features of the service.
Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and content
Core App Features and Functionality
Delivering the essential functionality of the app, providing you with a personalised AI, and enabling you to customise your profile, interests, and AI interactions. This includes ensuring individualised, secure conversations and allowing your AI to learn from your interactions to enhance future conversations. Additionally, syncing your interaction history across all devices you use to access the service.
- Data Collected During Registration
• User Data Usage Data
• Payment and Purchase Data
• Messages and content
• Interests and preferences
Enhancing Features and User Experience
We use your information to evaluate and develop new features, technologies, and improvements for the mindmymind service. This helps us enhance the service and create a better experience for you. Our legitimate interest is in continuously improving our products and features. Importantly, we do not use personal data to train our AI, ensuring your data is used solely to support and enhance your experience with the service.User Data Usage Data Survey and Research Data
Safeguarding and Maintaining the Services
Preventing fraud, criminal activity, and misuse of our services, while ensuring the security of our IT systems, infrastructure, and networks (including testing, system maintenance, support, and data hosting).Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and contentInterests and preferences
Advertising the Services
We may use your information for marketing and advertising our services based on our legitimate interest. This includes promoting features or updates we believe may be relevant to you, while balancing our interests with respect for your privacy.Account information.Device and network data. Usage dataSurvey and Research Data
Ensuring Compliance and Protecting Rights
We use your information to enforce our agreements, uphold our terms and policies, and comply with legal obligations. This includes protecting our rights, privacy, safety, and property, as well as those of our users. We also work to maintain the integrity of our services, verify the age of registered users, defend against legal claims and disputes, recover payments owed to us, keep records of transactions, and comply with legal processes as required.Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and contentInterests and preferences
Research and surveys
We use your information for research and surveys to better understand user needs and improve our services. This falls under our Legitimate Interest in enhancing the user experience and developing relevant features. By conducting research and gathering feedback through surveys, we can make informed improvements that benefit all users.User Data Usage Data Survey and ResearchData
Cookies and Similar Technologies
You have the option to manage your cookie preferences. Strictly necessary cookies are essential for the website to function properly and cannot be disabled.
•User data
•Usage data
• Survey and Research Data
Compliance with Legal ObligationsIn some cases, we process personal data to comply with legal and regulatory requirements. This ensures that we meet our obligations under applicable laws, protect user rights, and respond appropriately to legal requests or proceedings.
The following applies in relation to this:
Purpose
Why and how we collect Categories of personal data used for the purposeResponding to Legal Requests and InvestigationsWe may process certain information as required by law, including responding to valid legal requests (e.g., search warrants or subpoenas) from regulators, law enforcement, or other entities. For example, we may be required to provide specific information such as your IP address or profile details in relation to a legal investigation. Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and contentInterests and preferences
4. Who do we share your information with?
Information we may share:
Recipients
Information regarding why
Categories of personal data
Service Provider And Marketing Partners
We share your information with companies and individuals who provide services on our behalf or assist us in operating our services and business (such as hosting, IT support, customer service, and website analytics). We also share information with companies that provide marketing services for us; however, we do not share the content of your conversations for marketing or advertising purposes.
For example, we may share usage data with analytics providers to better understand how users engage with our service and to help identify others who may be interested. We require these providers to agree not to use this data for any other purpose, ensuring they only use it to provide their services to us.
- Data Collected During Registration
• User Data
• Usage Data
• Payment and Purchase Data
• Interests and preferences
• Payment Partners
We share subscription-related information with payment partners, such as Google Play and the App Store, to process and manage payments. Details regarding these transactions are outlined in our Terms and Conditions, which you can read here.
User Data
Payment and Purchase Data
Law Enforcement and Legal ProceedingsWhen we believe in good faith that it is necessary, we may share information with law enforcement, government authorities, or relevant third parties.
This may occur, for example:
to fulfill a legal obligation,to respond to a valid legal process (such as a search warrant, court order, or subpoena), orto protect our own or a third party’s legitimate interests, including in matters of:national security,law enforcement,ongoing litigation,criminal investigations,ensuring someone’s safety, orpreventing death or imminent bodily harm.
Data Collected During Registration User Data Usage DataPayment and Purchase DataMessages and contentInterests and preferences
Business Transfers and Acquisitions
We may share information with acquirers or other relevant parties involved in business transactions or negotiations, such as mergers, acquisitions, reorganisations, or sales of all or part of our business or assets. In the event of such a transaction (including bankruptcy or similar proceedings), your personal data may be transferred to the acquiring party or affiliate as part of the transition.User Data Data UsageData Payment and PurchaseData Survey and Research Data
5. Keeping your personal data safe
We implement a range of industry-standard security measures and protocols to safeguard your data from unauthorised access, misuse, or disclosure.
Apple and Google authentication:
We prioritise your privacy and security by utilising authentication methods provided by Apple and Google. We use your phone number for verification to confirm that it belongs to you and to prevent misuse.
This approach prevents unauthorised access while ensuring a seamless and secure login experience.
To maintain the highest level of security:
Only use trusted devices for login.
Avoid sharing your linked Apple or Google accounts with others.Ensure your phone number remains up-to-date for verification purposes.
Please note: If others gain access to your authenticated accounts or devices, they may view your personal data, settings, and services linked to your account. Always log out when finished and secure your device to prevent misuse.
Security:
To ensure secure access to your data, we use personalised access tokens when retrieving information via our API. These tokens provide an added layer of security by allowing only authorised access to your data within the system. Access tokens are uniquely assigned, limiting who can view or interact with your information, and are a crucial part of our efforts to protect your data from unauthorised access or misuse. Although we make commercially reasonable efforts to secure your data, no technology, data transmission, or system can be completely guaranteed as 100% secure. If a security breach occurs that results in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access to your data, we will inform you promptly upon identifying the issue.
6. Data retention
We will retain your personal information for as long as you have an active account with us. Once you delete your account, all personal information associated with it will be removed.
Please note that conversations between you and the AI are not stored or retained. We ensure that your data is kept only as long as necessary to provide the service and fulfill any legal or reporting obligations.In determining the retention period, we consider factors such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use, and whether the purposes for processing can be achieved by other means, in compliance with applicable legal requirements.
7. Information from minors
We do not knowingly collect or share information from anyone under 18 years old, nor do we target our services to them. By using our services, you confirm that you are 18 or older. If we find out that a user has created an account despite being under 18, we will deactivate the account and delete the information. If you know of any data we may have from a person under 18, please contact us at hello@mindmymind.com
8. Transfer to other countries
Our services are operated from Portugal. If you are located in another country, please be aware that the information you provide to us may be transferred to, stored, and processed in Portugal, which are subject to EU privacy regulations. Regardless of the location, it is essential that we comply with all applicable rules, ensuring that your personal information is not transferred in a way that violates your rights.
9. Changes to this Policy
We may update this Policy from time to time. If we make significant changes, we will provide you with clear notice, either via email or a notification within the app, depending on the situation.
10. Complaint to a Supervisory Authority
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
Phone number:(+351) 213 928 400
Email: geral@cnpd.pt
11. Contact information
If you have any questions or concerns regarding this Policy, please contact our Data Protection Officer using any of the following methods:
E-mail: hello@mindmymind.com
Write to the following address: Mindmymind, Rahbeks Alle 21, 1801 Frederiksberg C
Insula Sensorial Unipessoal LDA is the data controller of personal data processed under this Policy
