Privacy Policy

This Privacy Policy explains how LIMITED LIABILITY COMPANY "MINDSHIP" (TOV "MAINDSHYP"), identification code 45964647, registered at 17 Hlybochytska St., building 1-A, non-residential premises 417, Kyiv, 04052, Ukraine ("Mindship", "we", "us", "our"), collects, uses, stores, shares and protects your personal data when you use the Mindship mobile application, the website mindship.me and related services, including corporate (B2B) wellbeing programmes (together, the "Services").

We are the controller of your personal data: we decide why and how it is processed. If you do not agree with this Privacy Policy, please do not use the Services.

Contact for all privacy matters: support@mindship.me (subject line "Privacy request").

Summary of key points

This summary is for convenience only; the full Privacy Policy below applies.

• What we collect. Your account details, what you tell the app about how you feel (goals, check-ins and how you feel after practices), the requests you type or say, your practice history, the results of the breathing test if you take it, and technical and usage data from the app and the website.
• Health-related data. Your check-ins, requests and breathing test results may reveal information about your physical or emotional wellbeing. We use them to provide and improve the Services and never for advertising.
• Breathing test. The test is optional. We delete the recording once it has been analysed and keep the results. Recordings in which no speech is detected may be kept, with nothing linking them to you, to improve our analysis (Section 3).
• AI. An AI model chooses practices based on what you type or say. Today these requests are processed by Google's Gemini models; Section 5 lists the AI providers we may use. AI makes no decisions with legal or similarly significant effects on you.
• Analytics and advertising measurement. The app uses analytics, crash reporting and install attribution tools from the moment you open it (Section 11). We do not share your requests, check-ins, ratings or breathing data with advertising platforms.
• Corporate programmes. If you use Mindship through your employer, the employer sees your email address, how much you use the app and statistics across the programme, but not your requests, breathing data or individual answers and ratings (Section 13).
• Your rights. You can delete your account in the app at any time, and ask us by email for a copy of your data or to exercise your other rights (Section 10).
• Not medical advice. Mindship is a wellbeing tool, not a medical device. See our Terms of Service and Health Disclaimer.

1. Scope and who we are

1.1. This Privacy Policy applies to personal data processed through the Services. It describes the Mindship app from version 2.1.1; earlier versions may work differently, so please keep the app updated. It does not apply to third-party websites, apps or services that may be linked from the Services (for example, Apple App Store, Google Play or social networks); their own privacy policies apply.

1.2. We comply with the Law of Ukraine "On Personal Data Protection", the EU General Data Protection Regulation 2016/679 ("GDPR"), the UK GDPR and the Data Protection Act 2018 to the extent they apply to you, and other applicable data protection laws.

1.3. Data protection contact. Send requests and questions about personal data to support@mindship.me.

1.4. Nature of this Policy. This Privacy Policy is an information notice provided under data protection laws. It is not a contract and does not create rights or obligations beyond those established by applicable law. The liability of Mindship in connection with the Services is governed by the Terms of Service, to the extent permitted by law.

2. What personal data we collect

2.1. Data you provide to us

• Account and sign-in data. When you first open the app, it creates an anonymous account with a random account ID, so that your answers and practices can be saved before you sign in. If you sign in, we also process your email address. With email sign-in, your password passes through our server to Firebase Authentication (Google), which checks it; we do not store it. If you sign in with Apple or Google, we receive the basic profile data they share with us: your name and email address, or a private relay email if you hide your email with Apple.
• Your profile. Your name, if you give it to us or it comes from Apple or Google; the language of the app; your time zone; your notification and reminder settings; and the companion you pick in the app and the name you give it.
• How you feel. Your goals (for example, to feel less anxious, sleep better or have more energy); at a check-in, the state you choose (for example, anxious, sad or low on energy) and, if you add them, words that describe your feelings; and after a practice, how you feel now (your rating) and whether you feel better.
• Requests. What you type or say when you ask the app for a practice (for example, "I feel anxious before a presentation"). Section 5 explains how requests and voice recordings are processed.
• Breathing test. If you take the breathing test, a recording of your breathing (Section 3).
• Confirmations you give. When you tap "I agree" on the "Before we begin" screen, we record the date and time, and that "Save how I feel" is on.
• Communications. Messages you send to our support team and feedback you give us, including in the app.
• Device permissions. The app asks for access to the microphone (for voice requests and the breathing test) and to send notifications. On iPhone, it may also ask for permission to add images to your photo library; it cannot see your photos. You can change these permissions at any time in your device settings; the app keeps working without them, with the related features unavailable.
• Corporate programme data. If you join through an organisation, your work email address and, if the organisation gives it to us, your name (Section 13).
• Quizzes and contact forms. If you take a Mindship quiz or leave your contact details on one of our web pages (for example, to learn about corporate programmes), your email address and answers, together with your IP address and information about your browser.

You must provide true, complete and accurate information and keep it up to date. Do not provide personal data of other people.

2.2. Data collected automatically

• Usage data: the practices you start and complete and their duration, your favourites and programmes, the screens you view, the notifications you receive and open, and other in-app events.
• Device and technical data: device model, operating system and version, app version, language, time zone, device identifiers (the identifier for vendor on iPhone, the Android ID on Android), your device's advertising identifier (on iPhone only if you allow tracking), IP address, push notification tokens, crash reports and diagnostic logs.
• Approximate location: your country and city, estimated from your IP address by our product analytics provider, and the country of your app store account. We do not collect precise (GPS) location.
• Purchase data: subscription status, plan, price and currency, trial, renewal and cancellation dates, the store's reason code for a cancellation (for example, that you cancelled or that a payment failed), and transaction identifiers. Payments are processed by Apple or Google; we do not receive your card details.
• Install source: the advertising campaign or link through which you installed the app, if any (Section 11.3).

2.3. Data from other sources

We receive limited data from: Apple and Google, if you sign in with them (Section 6.4); Apple App Store, Google Play and RevenueCat, about your purchases and subscription status; AppsFlyer, about the advertising campaign or link through which you installed the app; and the organisation that invited you to a corporate programme (your work email address and, if provided, your name). We do not buy personal data from data brokers. Our use of information received from Google APIs complies with the Google API Services User Data Policy, including its Limited Use requirements.

Subscriptions are offered to individual (B2C) users only; corporate (B2B) users do not make in-app purchases unless they choose a separate personal subscription.

2.4. Sensitive data

We do not ask for information about racial or ethnic origin, political opinions, religious beliefs, sexual orientation or criminal records, and we do not collect precise location. Please do not include such information in your requests. Your check-ins, requests and breathing test results may reveal information about your health or emotional state; we use such information only as described in this Privacy Policy and never for advertising. If you choose to include information about your health, emotional state or other special categories of data in your requests, you do so voluntarily and give your explicit consent to its processing as described in this Privacy Policy (Art. 9(2)(a) GDPR; Art. 7 of the Law of Ukraine "On Personal Data Protection"). You are responsible for any personal data of other people that you enter; do not enter it without their consent.

2.5. New features

We describe here only the features that currently exist in the app. If we introduce new features that involve new categories of data (for example, integration with wearable devices or health apps), we will update this Privacy Policy before launch and, where required, ask for your separate consent before collecting such data.

3. Breathing test and microphone data

3.1. What the test does. The breathing test is optional: without it, practices use a standard pace. If you take it, the app records 15 to 60 seconds of your breathing through your phone's microphone and uploads the recording to our servers, together with the local time of the test. There, our analysis software — signal processing and machine-learning models — estimates the length of your inhales, exhales and pauses, your breathing rate and how even your rhythm is, and describes your breathing pattern. We use the results to adapt the pace of practices to you and to show you your results and how they change over time.

3.2. Speech check and a third-party AI model. Our software checks whether a recording contains speech. When our models cannot reliably analyse a recording, for example because of background noise, we send an image of its sound — a spectrogram, which shows how the frequencies of the sound change over time, not the audio itself — to Google's Gemini model on the Vertex AI platform, which helps identify the phases of your breathing. This happens for some recordings only. Under Google's terms, Google does not use this data to train its models.

3.3. How long we keep recordings. We delete the uploaded recording as soon as the analysis is finished: usually within minutes, and within about two hours if the analysis has to be retried. Recordings that could not be analysed are deleted after two days. Deleted files may remain in our cloud storage's recovery area for up to seven more days before they are erased.

3.4. Recordings kept to improve the analysis. If you use Mindship as an individual (not through a corporate programme) and no speech is detected in your recording, we may keep a copy of it to train and test our breathing analysis. The copy is stored without your account ID, email address or test result, so nothing links it to you — which is also why we cannot find it to delete it at your request. We currently keep these copies without a fixed time limit. We do not keep such copies of recordings in which speech is detected, or of any recordings made in corporate programmes.

3.5. Your results. Your results are stored linked to your account ID. The average values that set the pace of your practices are stored encrypted and kept until you delete your account; the detailed analysis of each test is kept for 365 days. Our product analytics record that you took the test and a short code for the breathing pattern it showed, and our messaging tool records whether you have taken or skipped the test.

3.6. No identification. We do not use breathing recordings to identify you, to create a voiceprint or to recognise emotions.

3.7. Voice requests are processed differently from the breathing test: see Section 5.1.

3.8. Your choices. You decide whether and when to take the test, and you can stop taking it at any time. Without microphone permission, the test is unavailable. To delete your breathing results, delete your account, or email us if you want to keep your account (Section 10).

4. How and why we use your data, and our legal bases

We process personal data only where we have a legal basis. The table below shows our purposes and the legal bases under the GDPR / UK GDPR and the Law of Ukraine "On Personal Data Protection".

Where we rely on legitimate interests, we weigh them against your rights, and you may object (Section 10). We do not use your personal data for profiling that produces legal or similarly significant effects on you.

5. Artificial intelligence and how recommendations are made

5.1. Where AI is used.

• Choosing a practice. When you type or say what you need, an AI language model receives the text of your request together with the list of practices in the Mindship library and their descriptions, and chooses a practice. It takes into account what your words say about how you feel. It does not receive your name, email address, account ID, check-ins, ratings or breathing results.
• Voice requests. If you speak instead of typing, your recording is sent to an AI speech-recognition service, which turns it into text; the text is then processed like a typed request. We do not store the recording ourselves.
• Reminder texts. AI writes the text of some reminder notifications. For this, the AI model receives your first name (if we have it), the practice the reminder is about and our instructions for the text, but not your requests, check-ins or breathing data.
• Breathing test. Our own machine-learning models analyse your breathing test, and for some recordings an image of the sound is analysed by a third-party AI model (Section 3.2).
• Narrator voices. The narrator voices in practices are synthetic voices created in advance with AI voice synthesis. No data about you is used to create them.

5.2. What is not AI. The pace of a practice is adapted to your breathing by fixed rules, not by AI. The first short practice in onboarding is chosen by fixed rules from the check-in state you pick. Your ratings after practices are not sent to AI providers and do not change how AI chooses practices for you.

5.3. Transparency. Before you start using the app, the "Before we begin" screen tells you that your requests are sent to an AI provider to choose a practice. Each practice has a "Why this practice?" note, written in advance, which says that the recommendation is made by AI, explains what the practice is for and reminds you that it is not medical advice; it does not show the reasoning behind a particular recommendation. This Privacy Policy and our Terms of Service describe all the AI features.

5.4. Limits and human oversight. AI recommendations may be inaccurate. They are suggestions, not instructions, diagnoses or treatment, and you can always choose another practice yourself. The practices and descriptions that AI chooses from are created by our team together with specialists in breathing techniques and psychotherapy. AI does not recognise crises, and nobody at Mindship monitors your requests (see Section 2 of the Health Disclaimer).

5.5. AI providers. Today, Google processes these requests with its Gemini models: through the Gemini API for practice selection, speech recognition and reminder texts, and through Vertex AI for the breathing test. We may also use the following providers, instead of or in addition to Google, for the same purposes: OpenAI (language models and speech recognition), Anthropic (language models) and ElevenLabs (speech recognition). The synthetic narrator voices were created with ElevenLabs. These providers act on our behalf as processors and may process data in the United States (Section 7).

5.6. What providers receive and keep. We send AI providers only what a task needs: the text of your request or the recording of a voice request, the image described in Section 3.2, or, for reminder texts, the data listed in Section 5.1. We do not send them your email address or account ID. Under the terms of the paid Gemini API and Vertex AI that we use, Google does not use this data to train its models; Google keeps requests and responses to the Gemini API, including voice recordings sent for speech recognition, for up to 55 days to detect abuse and misuse. If we use another provider from Section 5.5, we will do so only under terms that do not allow it to use your data to train its models.

5.7. Where your requests are kept. The app keeps the history of your requests on your device. On our side, requests are not saved to your profile, but the text of each request — or the transcript of a voice request — is recorded together with your account ID in our server logs, which are deleted after 30 days, and the first 200 characters of a typed request are recorded in our product analytics. A small number of authorised team members can see these records when they investigate errors, security issues or the quality of the Services (Section 6.3).

5.8. No automated decisions with legal effect. No decision that produces legal effects or similarly significantly affects you is made solely by automated means (Art. 22 GDPR).

6. Who we share data with

6.1. We do not sell your personal data. We share limited data with advertising platforms, through AppsFlyer, only to measure our advertising campaigns (Section 11.3), and never your requests, check-ins, ratings or breathing data.

6.2. Service providers (processors). We use providers who process data on our behalf, under data processing terms and only on our instructions:

We will send you an up-to-date list of our providers on request at support@mindship.me.

6.3. Our team. A small number of authorised team members can access personal data, including the text of requests in our logs and analytics, when this is needed to provide support, fix errors, keep the Services secure or check their quality. They are bound by confidentiality obligations. We do not have a process for reading or reviewing users' requests.

6.4. Sign-in providers. If you sign in with Apple or Google, we receive only the basic profile information they share (name, email or private relay email) and use it only as described in this Privacy Policy. We do not control, and are not responsible for, how those companies use your data; their own privacy policies apply.

6.5. App stores. Apple and Google process your payments and purchase records as independent controllers under their own terms and privacy policies.

6.6. Corporate programmes. If you take part in a corporate programme, the organisation that provides it receives the information described in Section 13.

6.7. Legal requirements and protection of rights. We may disclose data where required by law, by a court order or a lawful request of a public authority, or where necessary to establish, exercise or defend legal claims, or to protect the life or safety of a person.

6.8. Business transfers. In the event of a merger, acquisition, financing or sale of all or part of our business, personal data may be transferred to the acquirer subject to confidentiality obligations and this Privacy Policy. We will inform you of any change of controller.

6.9. Third-party services. Apple, Google, sign-in and payment providers and other third-party services that you use together with the Services act under their own terms and privacy policies. To the extent permitted by law, Mindship is not responsible for their processing of personal data beyond our instructions.

7. International transfers

7.1. Where your data is stored. Our database, file storage and servers are hosted by Google Cloud in Belgium (the europe-west1 region) for all users, wherever they live. Some providers process data elsewhere, as shown in the table below. Mindship is established in Ukraine, and our team accesses data from Ukraine.

7.2. Safeguards. Where personal data is transferred from the EEA, the United Kingdom or Switzerland to a country without an adequacy decision, the transfer relies on the EU–US Data Privacy Framework (and its UK Extension and Swiss framework) where the recipient is certified, or on the European Commission's Standard Contractual Clauses, together with the UK International Data Transfer Addendum or Agreement where UK data is concerned. We also limit what we transfer: data is encrypted in transit and at rest, and AI providers do not receive your email address or account ID.

7.3. Ukraine is not currently subject to an EU or UK adequacy decision. Access by our team in Ukraine to the data of users in the EEA and the UK is limited to what is necessary and protected by the measures described in Section 9. You can request a copy of the relevant safeguards at support@mindship.me.

8. How long we keep your data

We keep personal data only as long as necessary for the purposes described in this Privacy Policy.

Data may be kept longer where required by law or for the establishment, exercise or defence of legal claims (Section 10.4). When data is no longer needed, we delete it or irreversibly anonymise it.

9. How we protect your data

9.1. We apply technical and organisational security measures, including: encryption of data in transit (TLS) and at rest, with breathing results additionally encrypted (AES-256-GCM); random account IDs instead of names and email addresses in most of our systems and in what we send to AI providers; storage of corporate programme data in a database separate from consumer data; access to production systems limited to a small number of authorised team members; and confidentiality obligations for all team members and contractors.

9.2. No method of transmission over the Internet or of electronic storage is 100% secure, and we cannot guarantee that unauthorised third parties will never be able to defeat our safeguards. You are responsible for keeping your device and login credentials secure and should use the Services only in a secure environment. If a personal data breach is likely to result in a risk to your rights, we will notify the competent supervisory authority and, where required, you, in accordance with applicable law.

10. Your rights and how to exercise them

10.1. Depending on where you live, you have the right to:

• access your personal data and receive a copy;
• rectify inaccurate or incomplete data;
• erase your data ("right to be forgotten");
• restrict processing;
• data portability (receive your data in a structured, machine-readable format, for example JSON);
• object to processing based on legitimate interests and to direct marketing at any time;
• withdraw consent at any time, without affecting the lawfulness of processing before withdrawal;
• not be subject to decisions based solely on automated processing that produce legal or similarly significant effects;
• lodge a complaint with a supervisory authority (Section 15).

10.2. How to exercise your rights. You can delete your account in the app (Profile → Settings → Delete Account) and manage notifications in the app and in your device settings (Section 14). For everything else — a copy of your data, corrections, objections, withdrawing consent — email support@mindship.me from the address you sign in with. The app does not yet have a button to export your data: on request, we will send you a copy in a structured, machine-readable format (JSON). We may ask you to verify your identity before acting on a request. We respond within one month (extendable by two further months for complex requests, with notice), or within the shorter period required by local law.

10.3. Deleting your account. You can delete your account in the app or by email (how deletion works). When you delete it in the app, your account and the data in our database are deleted right away, including your sign-in, profile, goals, check-ins, ratings, practice history, breathing results and any recordings still being analysed, and we ask our breath analysis service, RevenueCat and Reteno to delete what they hold about you. If you use Mindship without signing in, or signed in with Apple and hid your email, delete the account in the app: we cannot find it by your email address. Deleting the app from your phone does not delete your account or cancel your subscription — cancel subscriptions through the App Store or Google Play.

10.4. Data we may keep after deletion. The following is not deleted when you delete your account: server logs, which are deleted after 30 days; product analytics, install attribution data and crash reports held by PostHog, AppsFlyer and Firebase Crashlytics, which are linked to your random account ID rather than your name or email address (Section 8); breathing recordings kept without any link to you (Section 3.4); store purchase records held by Apple and Google; records kept separately from your account, such as invitations to corporate programmes, quiz answers and contact details left on our web pages, and your contact entry at our email provider, which we delete when you ask us to; a record of the deletion; and copies in backups until they are replaced. We may also keep limited information where necessary to prevent fraud and abuse, enforce our Terms of Service, establish or defend legal claims, or comply with legal obligations. Such data is kept only for the period required for that purpose and is protected under this Privacy Policy.

10.5. Limits. Your rights are not absolute. We may refuse or limit a request where permitted by law — for example, where we cannot verify your identity, where the request is manifestly unfounded or excessive, or where it would adversely affect the rights of others. Where required by law, we will inform you of the reasons for a refusal.

11. Cookies and similar technologies

11.1. Website. Until you make a choice in the cookie banner, the website loads no analytics or advertising tools and sets only the cookies it needs to work: mindship-consent, which remembers your choice for 182 days, and NEXT_LOCALE, which remembers the language you choose. Your light or dark theme choice is stored in your browser's local storage. If you accept analytics cookies, we load Google Analytics, Amplitude and PostHog to see which pages are visited, which buttons are pressed and how the site performs; PostHog also records sessions on the site, with the text you type hidden. If you accept marketing cookies, Google may use its cookies to measure our ads and show you more relevant ones. You can change your choice at any time through "Cookie settings" at the bottom of every page; when you withdraw consent, the analytics cookies and the PostHog identifiers stored in your browser are removed, and PostHog stops collecting data, keeping only a note in your browser that you said no.

11.2. App. The app does not use cookies, but it includes software development kits (SDKs) from the providers listed in Section 6.2. When you open the app, these start without asking: Firebase (Authentication, Cloud Messaging, Remote Config and Crashlytics), PostHog, Reteno, RevenueCat and Expo. AppsFlyer starts on Android when you open the app, and on iPhone after you answer Apple's request to allow tracking, or after a minute if you have not answered it. The app does not currently ask for separate consent to these tools and has no setting to turn them off; you can limit advertising measurement as described in Section 11.3.

11.3. Advertising and campaign measurement. We use AppsFlyer to learn which of our ads or links led to an install and how many installs lead to sign-ups and subscriptions. AppsFlyer receives: your account ID; your device's advertising identifier (on iPhone only if you allow tracking; on Android unless you have deleted it in your device settings), other device identifiers and technical data about your device and the install; on Android, the install referrer from Google Play; and these events: onboarding completed, sign-up or account linked, sign-in, first practice completed and paywall viewed. RevenueCat reports your trials, subscription purchases and renewals, including price and currency, to AppsFlyer from its servers. AppsFlyer passes information about installs and these events to the advertising platforms on which we advertise the app, so that they can measure and optimise our campaigns. We do not send AppsFlyer your requests, check-ins, ratings or breathing data. To limit this, on iPhone do not allow tracking (Settings → Privacy & Security → Tracking); on Android, delete your advertising ID in your device's ads settings.

11.4. Do Not Track. Some browsers offer a "Do Not Track" (DNT) setting. Because there is no uniform industry or legal standard for recognising DNT signals, we do not currently respond to them. We do honour your cookie choices on the website and the "Ask App Not to Track" setting on iPhone. If a binding standard is adopted, we will describe our approach in an updated version of this Privacy Policy.

12. Age restriction

The Services are intended only for adults aged 18 or over. Breathing practices and wellbeing content are designed for the adult body and psyche. We do not knowingly collect personal data from anyone under 18. If you believe that a minor has provided us with personal data, contact us and we will delete it.

13. Corporate (B2B) programmes

13.1. If you access Mindship through your employer or another organisation (a "Client"), the following additional rules apply.

13.2. Who is responsible. Mindship processes your account, requests, check-ins, practice history and breathing data as an independent controller under this Privacy Policy. The Client is responsible for how it uses the information it receives from us.

13.3. How you join. You can join through an invitation sent to your email address, through the Client's join link, or automatically when you sign up or sign in with an email address on a domain that the Client has asked us to include. The Client's administrators can also add you, one by one or from a list. To invite you, the Client gives us your work email address and may give us your name.

13.4. What the Client sees. The Client's administrators see your email address, whether you have joined, when you joined and whether your premium access is active. They also see statistics on how the programme is used: aggregated figures (for example, how many practices were completed and when, which categories were used, and how participants rated how they felt before and after practices) and, for each participant, the number of completed practices, the time of the last practice, the most used practice category and the time of the last sign-in. Aggregated figures are shown for any group size and period, so in a small programme they may reveal information about individual participants. If this is turned on for the Client, its contact person may also receive a periodic email summary with aggregated figures, which is sent only for programmes with at least five participants.

13.5. What the Client does not see. The Client does not see your requests, your breathing recordings or results, or your individual check-ins, answers and ratings.

13.6. Your earlier data and separate storage. When you join, the data of your earlier use of Mindship (your profile, practice history and breathing results) moves to the part of our systems that serves corporate programmes: a database separate from consumer data, and for some Clients a database of their own. We do not keep breathing recordings made in corporate programmes to improve our analysis (Section 3.4). In a corporate programme, we do not send you news, tips or offers by email.

13.7. Purpose limitation. Our contracts with Clients prohibit any attempt to re-identify users from aggregated statistics and prohibit using Mindship data for employment, disciplinary, remuneration, promotion or dismissal decisions, for insurance underwriting or pricing, for scoring, or for any discrimination.

13.8. Your choice. Participation in a corporate programme is voluntary. You can stop using the Services or delete your account at any time; this does not affect your employment or any other relationship with the Client.

13.9. Administrators. If you administer a programme for a Client, we process your name, email address and sign-in data to give you access to the admin panel.

14. Marketing communications

14.1. Push notifications. If you allow notifications, the app sends practice reminders and reminders to come back to the app; they are on by default. We send news and offers by push notification only if you turn them on in the app. You can change these settings in the app (Profile → Settings → Notifications), where you can also hide the text of notifications on the lock screen, and turn notifications off in your device settings.

14.2. Email. If we have your email address, we may send you emails about your account and subscription, tips on using Mindship, and news and offers. Every email except service messages has an unsubscribe link. In a corporate programme, we do not send you news, tips or offers by email.

14.3. In-app messages. We may show you messages in the app, for example about new practices or offers.

14.4. Service messages (for example, about security, your account or changes to our terms) are not marketing and may still be sent.

15. Region-specific information

15.1. EU/EEA and United Kingdom

The legal bases, rights and transfer safeguards described above apply under the GDPR and UK GDPR. You can lodge a complaint with the supervisory authority of your country of residence, place of work or place of the alleged infringement (in the UK — the Information Commission, formerly the Information Commissioner's Office; in Switzerland — the Federal Data Protection and Information Commissioner).

Corporate clients can request our Data Processing Agreement (including the Standard Contractual Clauses, where applicable) at support@mindship.me.

15.2. Ukraine

Your rights are set out in Article 8 of the Law of Ukraine "On Personal Data Protection". The app records the date and time when you tap "I agree" on the "Before we begin" screen. You may complain to the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua) or apply to a court.

15.3. United States

Sale and sharing. We do not sell personal information for money. The information that AppsFlyer passes to advertising platforms to measure our campaigns (Section 11.3) may count as "sharing" for cross-context behavioural advertising, or as a "sale", under the California Consumer Privacy Act (CCPA/CPRA) and other US state privacy laws. To opt out on your device, do not allow tracking on iPhone, or delete your advertising ID on Android (Section 11.3). We do not share your requests, check-ins, ratings or breathing data with advertising platforms. Disclosures to our service providers under written contracts (Section 6.2), and our use of personal information for internal research for technological development and demonstration, are not a sale.

Categories of personal information collected in the last 12 months. The table below reflects the position as of the "Last updated" date and may change as the Services develop; the full description is in Section 2.

Retention periods are set out in Section 8. Sources of personal information are described in Section 2, and the purposes of use in Section 4.

Your rights. Depending on your state of residence (including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia), you may have the right to: know whether we process your personal information; access it and obtain a copy; correct inaccuracies; request deletion; opt out of targeted advertising, sale or profiling with legal or similarly significant effects; limit the use of sensitive personal information; obtain a list of the categories of third parties (and, where state law requires, specific third parties) to which we have disclosed personal information; and not be discriminated against for exercising these rights. These rights are not absolute, and we may decline a request as permitted by law.

How to exercise them. Email support@mindship.me or use the in-app settings. We will verify your identity using information we already hold and may ask for additional information for verification and fraud prevention. You may use an authorised agent; we may deny a request from an agent that does not provide proof of written, signed authorisation, and may still ask you to verify your identity directly.

Appeals. If we decline to act on your request, you may appeal by emailing support@mindship.me with the subject "Privacy appeal". We will respond in writing within the period required by law, explaining the reasons for our decision. If your appeal is denied, you may contact your state Attorney General.

California "Shine the Light". California residents may request, once a year and free of charge, information about personal information disclosed to third parties for their direct marketing purposes. We do not make such disclosures.

16. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in the Services, the law or our practices. We will post the updated version with a new "Last updated" date and, where required by law, inform you of material changes in the app, by email or by other appropriate means. Where a change requires your consent, we will ask for it. Your continued use of the Services after the updated version takes effect means that you acknowledge it.

17. Contact us

LIMITED LIABILITY COMPANY "MINDSHIP" (TOV "MAINDSHYP"), identification code 45964647

17 Hlybochytska St., building 1-A, non-residential premises 417, Kyiv, 04052, Ukraine

Email: support@mindship.me

We ask you to contact us first with any question or concern about your personal data — most issues can be resolved directly. You also have the right to contact the supervisory authority in your country of residence (Section 15).

This Privacy Policy is available in English and Ukrainian. In case of any discrepancy, the version in the language of the country of your residence prevails where required by mandatory law; otherwise the English version prevails.