Last Updated: January 12, 2019
- What Information We Collect
- Cookies and Other Similar Technologies
- How We Use Your Information
- Legal Bases for Processing
- Collection and Use of Information from Children
- With Whom We Share Your Information
- Notice Regarding Public Posting Areas
- International Data Transfers
- Opting Out of Communications
- Third Party Websites
- Security and Data Retention
- Your Rights
- Your California Privacy Rights and How We Respond to “Do Not Track” Signals
- Contact Us
WHAT INFORMATION WE COLLECT
We collect both personal information and non-personal information. “Personal information” is any information relating to an identified or identifiable natural person. “Non-personal information” includes technical information that does not identify an individual personally. Please note that over time, non-personal information may become personal information due to regulatory developments, technological advancements, or the co-mingling of personal and non-personal information. We collect the following information from and about you, and in the following ways:
- When you create a Mindworks account, we ask for your name, email address and password. We do not collect payment method details (payment account number and billing address); this is handled by either the Apple App Store or Google Play.
- If you sign in to Mindworks using your Facebook, we will use that service to authenticate your identity. We also receive other information that you have agreed may be provided by Facebook such as your username and e-mail address.
- When you use Mindworks, information is automatically submitted about the computer, mobile device, or other devices you use to access Mindworks and about how you use Mindworks. We receive data about the meditations you use and the amount of completion or time spent in that meditation. We also receive your browser type, IP address, language, operating system, unique device identifier, the date and time of your visit, the pages you view and the websites you visited immediately before and after visiting Mindworks. In some cases, we link this automatically collected data to other information we collect about you.
We do this to improve the content of the app and Website to provide a more personalized experience. We use this aggregated information to understand and optimize how our site is used, improve our marketing efforts, and provide content and features that are of interest to you.
From time to time we use push notifications in our mobile applications to send you messages about Mindworks or your account. You may opt out of receiving push notifications through your mobile device.
- COOKIES AND OTHER SIMILAR TECHNOLOGIES
- Essential. Some cookies are essential in order to enable you to move around our website and mobile applications and use their features, such as accessing secure areas of the Services. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
- Browsing and Functionality. We use these cookies to remember choices you make on the Services, such as your preferred language and the country from which you are visiting, and to provide enhanced, more personalized features.
- Performance and Analytics. We use third party cookies to see how you use our Services in order to improve their performance and develop them according to your preferences. In particular, we use mobile analytics tools to better understand the functionality of our mobile applications. These tools may record information about your usage, including how often you use the app, the events that occur within the app, and from where the app was downloaded. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
- Targeting Advertising. We receive audience based data (such as pixel traffic and conversion data) from social media platform providers. We use this information to help us advertise Mindworks.
- With your prior consent, we use Facebook Pixel. This pixel collects information about the usage of our Services and transmits this information to the social network Facebook, which uses this information for advertising and profiling purposes. The Facebook Pixel allows us to target you with personalized advertisements in the Facebook network. If you want to stop this tool from collecting data, you can opt-out here.
- We also receive data from Instagram. To block or limit this activity, you can manage your choices in your Facebook ad preferences and ad settings.
In the US, the Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit here to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.
- HOW WE USE YOUR INFORMATION
We use your information for the following purposes:
- Periodically informing you about changes on our Services, and about new products and services;
- Authenticating your login and processing payments;
- Allowing you to monitor your meditation use and progress in Mindworks; for example, by presenting updated results of your meditation progress;
- Performing statistical analyses of users of the site, and their viewing and participation patterns and for product development;
- Customizing and delivering information about our events, Mind Talks, and offerings by email;
- Providing customer support and sending confirmations about your account;
- Managing Mindworks and our events and trainings.
- LEGAL BASES FOR PROCESSING
We process personal information per applicable law and with transparency and fairness. The legal bases for each processing activity listed above are as follows:
- For marketing, processing is based on your consent (Art. 6(1)(1) GDPR).
- To provide our Services to you and process customer inquiries and requests, processing is necessary to establish and fulfill a contract with you (Art. 6(1)(b) GDPR).
- COLLECTION AND USE OF INFORMATION FROM CHILDREN
We do not knowingly collect information from children under the age of 16. In the event that we learn that a person under the age of 16, has provided us with personal information, we will delete such personal information.
- WITH WHOM WE SHARE YOUR INFORMATION
We share or disclose your personal information in the following instances and to the following parties:
- We employ contractors and service providers to perform the following site-related services: database management, maintenance services, analytics, marketing, and billing and email distribution. These third parties have access to your information only to perform these tasks on our behalf.
- We may share information with third parties which may be the result of any mergers, acquisitions, asset sales, joint ventures, etc.
- We share information with third parties when we have a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Terms of Service; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, or that of our users, affiliates, or the public.
- NOTICE REGARDING PUBLIC POSTING AREAS
Please note that any information you include in a message you post to any public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN THESE PUBLIC POSTING AREAS.
- INTERNATIONAL DATA TRANSFERS
- OPTING OUT OF COMMUNICATIONS
We communicate with users who subscribe to our Services on a regular basis via email. For example, we may use your email address to send you information about changes to our services and other disclosures as required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional.
We do provide you with the opportunity to opt-out of marketing communications from us, such as emails or updates regarding new services we are offering, by clicking the “unsubscribe” link within the text of the email or by contacting us at [email protected] We will process your unsubscribe as soon as possible, but please be aware that in some circumstances, you may receive a few more messages before the unsubscribe is processed.
- THIRD PARTY WEBSITES
Our Services contain links to other sites. We are not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.
- SECURITY AND DATA RETENTION
We have implemented reasonable measures to protect against unauthorized access to and unlawful interception or processing of personal information that we store and control. That said, please understand that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via the Services if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
- YOUR RIGHTS
You can request that your account be deleted at any time by contacting us. When your account is deleted, your user profile and all public activities (comments, conversation topics) will be removed.
Additionally, residents of the EU have a right to:
- Obtain confirmation as to whether or not their personal information exists and to be informed of its content and source, verify its accuracy and request its completion, update or amendment;
- Request the deletion, anonymization or restriction of the processing of their personal information processed in breach of the applicable law;
- Object to the processing, in all cases, of their personal information for legitimate reasons;
- Receive an electronic copy of their personal information, if they would like such a copy for themselves or to port their personal information to a different provider;
- Lodge a complaint with the relevant data protection supervisory authority.
- YOUR CALIFORNIA PRIVACY RIGHTS AND HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
California Civil Code Section 1798.83 permits visitors to the Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not provide your personal information to third parties for their marketing purposes.
At this time our Sites do not recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal and non-personal information collected via the Services.