MindCotine, Inc. (“MindCo Health”, “Mindcotine”, “MindCo-Relief”,”we”, “our” or “us”) is committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share, and use data that identifies or is associated with you (“personal information”). MindCo Health provides a platform for helping individuals with mental health challenges through digital cognitive behavioral therapy and coaching programs via the MindCo Health mobile applications (MindCotine or MindCo-Relief) that are available for download on your device (the “App”). This Privacy Policy applies to your use of the App and our website (available at www.mindcohealth.com) (our “Site”) (together with the “Service”). Please ensure you have read this Privacy Policy and understand how we collect, store, use, and disclose your personal information before accessing or using the Service.
MindCo is the controller of the personal information we hold about you in connection with your use of the Service. This means that we determine and are responsible for how your personal information is used.
2.1. Information you provide to us directly. We collect personal information that you voluntarily submit directly to us when you use the Service. This can include information you provide to us through the Site, when you download and set up an account on the App, correspond with us by e-mail or otherwise, subscribe to our mailing lists or other forms of marketing communications, when you report a problem with the Service or use some other feature of the Service.
2.2. We also collect information and content you choose to post to the Service, such as photos and other media, each of which you present through technology available through the Service, including but not limited to our in-app community.
2.3. If you choose not to provide such personal information, we may not be able to provide those parts of the Service to you or respond to your other requests.
2.4. The table at Annex 1 sets out in detail the categories of personal information we collect about you and how we use that information when you use the Service, and for users based in the European Economic Area (“EEA”) and UK the legal basis which we rely on to process the personal information.
2.5. Information we collect automatically. We also automatically collect personal information indirectly about how you access and use the Service, and information about the device you use to access the Service. For example, we may collect:(a) information about the features you use and the pages you view;(b) information about your device (such as your IP address, device identifier, device type, model and manufacturer); and(c) information about your usage patterns (such as how often you use the Service and your language settings).
2.6. We use this information to provide you the features and functionality of the Service, to monitor and improve the Service and to develop new products and services.
2.7. The table at Annex 2 sets out in detail the categories of personal information we collect about you automatically and how we use that information. For EEA and UK-based users, the table also lists the legal basis which we rely on to process the personal information.
2.8. We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.
2.9. We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Service and developing new products and features. We may also share such anonymized and aggregated information with others.
3.1. We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in Annexes 1 and 2, in accordance with our legal obligations and legitimate business interests.3.2. We may, however, need to retain your personal information for longer if we are required to do so by law.
4.1. We may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2): (a) Associate professionals: we may share your personal information with third party associate coach professional (a “MindCo Coach”). MindCo Coaches provide advice and support where you have requested to receive that aspect of the Service. (b) Other service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, cloud or web hosting, or providing analytic services. (c) Third parties at your request: For example, you may have the option to share your content with other users of the Service. (d) Affiliates: Other companies owned by or under common ownership as MindCo, including our subsidiaries (i.e., any organization we own or control) ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy. (e) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business. (f) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of MindCo, its users or others.
5.1. From time to time we may contact you (by email or via push notifications) with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
5.2. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
5.3. If you are an EEA or UK-based user, we will only send you marketing emails if you have given us your consent to do so.
5.4. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences via the App settings. You can also disable push notifications via the App settings.
6.1. Keeping Your Information Safe. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
6.2. MindCo does not ask for, nor access, any medical record information nor do we store any protected health information, nor are we a “Covered Entity” as defined under the Health Insurance Portability and Accountability Act (HIPAA).
6.3. International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Service from the EEA or UK, in the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognized as offering an equivalent level of protection; or (ii)the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.
7.1. Profile and Data Sharing Settings. You may update your profile information, such as your username and profile photo, and may change some of your data sharing preferences (e.g., your visibility settings) by accessing the “Settings” in the App.
7.2. Access to your Device Information. You may control the App’s access to your device information through your “Settings” on your device.
7.3. How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
7.4. Modifying or deleting your information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacy@mindcotine.com. We may not be able to modify or delete your information in all circumstances.
8.1. Your rights with regard to your personal information.
8.2. If you are accessing the Service from the EEA or the UK, in accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold: (a) Right of access. The right to obtain: (i) confirmation of whether, and where, we are processing your personal information;(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods; (iii) information about the categories of recipients with whom we may share your personal information; and (iv) a copy of the personal information we hold about you. (b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person. (c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay. (d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified. (e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you. (f) Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
8.3. You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
8.4. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
8.5 You also have the right to lodge a complaint to your local data protection authority. If you are based in the EEA, information about how to contact your local data protection authority is available here.
8.6 Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photo copy of a valid identity document.
9.1. Our Service uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users. This helps us to provide you with a good experience and allows us to monitor and analyze how you use and interact with our Service so that we can continue to improve our Service. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.
9.2. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
9.3. We use the following types of cookies: (a) Strictly necessary cookies. These are cookies that are required for the operation of our Service. They include, for example, cookies that enable you to log into your account. (b) Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Service when they are using it. This helps us to improve the way our Service works, for example, by ensuring that users are finding what they are looking for easily. (c) Functionality cookies. These are used to recognize you when you return to our Service. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org. For more information about tracking technologies, please see Section below.
9.4. Please see Annex 3 for more information about the specific cookies we use on the Service.
9.5. The cookies we use are designed to help you get the most from the Service but if you do not wish to receive cookies, most browsers and devices allow you to change your cookie settings. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our Service. These settings will typically be found in the “options” or “preferences” menu of your browser.
9.6. For mobile users, you have controls in your device Operating System that enables you to choose whether to allow cookies or share your advertising ID with companies like MindCo or our advertising service providers. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt-out of interest-based ads’. Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.
10.1. Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.
10.2. Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display “remote images”, “remote content” or “images” by default.
10.3. Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.
11.1. The Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
12.1. The Service is not directed at persons under 18 and we do not knowingly collect personal information from any persons under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
13.1. We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the “last modified” date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.
14.1. If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by a notification within the App. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.
15.1. Please contact privacy@mindcotine.com if you have any questions, comments and requests regarding this Privacy Policy.15.2. This Privacy Policy was last modified on January 2, 2021.
