Summary of Key Points

This summary provides key points from our Privacy Notice. You can find full details in the sections below.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the choices you make.
• Do we process sensitive personal information? We may process certain wellness-related information you voluntarily provide, such as mood logs and journal entries. This data is used solely to deliver personalised support within the app and is never sold or shared for advertising purposes.
• Do we collect information from third parties? We do not collect any information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
• How do we keep your information safe? We have organisational and technical processes in place to protect your personal information. However, no electronic transmission over the internet can be guaranteed 100% secure.
• What are your rights? Depending on where you are located, you may have certain rights regarding your personal information.
• How do you exercise your rights? Contact us at hello@mindcoreai.eu. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On?
4. When and With Whom Do We Share Your Information?
5. Do We Use Cookies and Tracking Technologies?
6. Do We Offer AI-Based Products?
7. How Do We Handle Social Logins?
8. How Long Do We Keep Your Information?
9. How Do We Keep Your Information Safe?
10. Do We Collect Information From Minors?
11. What Are Your Privacy Rights?
12. Controls for Do-Not-Track Features
13. Do We Make Updates to This Notice?
14. How Can You Contact Us About This Notice?
15. How Can You Review, Update, or Delete Your Data?

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You may include: email addresses, usernames.

Wellness & Wellbeing Data. When you use the app, you may voluntarily provide wellness-related information including mood logs, journal entries, and messages shared with our AI companion. This information is processed solely to deliver and personalise the Services to you. It is never sold or shared with third parties for marketing or advertising purposes.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details (such as Google). If you choose to register in this way, we will collect certain profile information about you from the social media provider.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out, you may turn them off in your device’s settings.

Information automatically collected

Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use our Services.

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services.
• Device Data. Information about your computer, phone, tablet, or other device you use to access the Services.
• Location Data. Information about your device’s location, which can be either precise or imprecise.

2. How Do We Process Your Information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver AI-powered support. Your messages to the AI companion are processed to generate personalised responses. Messages are sent to our AI service provider (OpenAI) for this purpose.
• To process payments. We use Google Play Billing to handle in-app purchases and subscriptions. We do not store or have access to your payment card details.
• To send you notifications. We may send push notifications such as check-in reminders and new article alerts. You can opt out in your device settings.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. You can opt out of our marketing emails at any time.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends so we can improve our Services to better engage and retain users.
• To save or protect an individual’s vital interest. We may process your information when necessary to prevent harm.

3. What Legal Bases Do We Rely On to Process Your Information?

We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK: The GDPR and UK GDPR require us to explain the valid legal bases we rely on:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada: We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

4. When and With Whom Do We Share Your Personal Information?

We may share information in specific situations and with the following categories of third parties.

We may share your data with the following third-party service providers who perform services for us:

• OpenAI — Your messages to the AI companion are sent to OpenAI to generate responses. OpenAI processes this data in accordance with their own privacy policy. We do not share your name, email, or account details with OpenAI.
• Google Firebase (Authentication & Firestore) — We use Firebase to manage user accounts, authentication, and to securely store app data such as usage records and subscription status.
• Google Play Billing — In-app purchases and subscriptions are handled by Google Play. We do not store or process payment card details.
• Data Analytics Services — We may use analytics services to understand how users interact with our Services in order to improve them.

We have contracts in place with our third-party providers to help safeguard your personal information. We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. Do We Offer Artificial Intelligence-Based Products?

We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to enhance your experience and provide you with innovative solutions.

We provide the AI Products through third-party service providers (“AI Service Providers”), including OpenAI. Your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process.

7. How Do We Handle Your Social Logins?

If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (such as Google). Where you choose to do this, we will receive certain profile information about you from your social media provider, which may include your name, email address, and profile picture.

We will use the information we receive only for the purposes described in this Privacy Notice. We recommend that you review the privacy notice of any social media provider to understand how they collect, use, and share your personal information.

8. How Long Do We Keep Your Information?

We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information.

9. How Do We Keep Your Information Safe?

We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. You should only access the Services within a secure environment.

10. Do We Collect Information From Minors?

We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@mindcoreai.eu.

11. What Are Your Privacy Rights?

In some regions, such as the EEA, UK, Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions you have certain rights under applicable data protection laws. These may include the right to: (i) request access and obtain a copy of your personal information, (ii) request rectification or erasure, (iii) restrict the processing of your personal information, (iv) data portability, and (v) not be subject to automated decision-making.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us at hello@mindcoreai.eu.

Opting out of marketing communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, or by contacting us directly.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can contact us at hello@mindcoreai.eu. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.

If you have questions or comments about your privacy rights, you may email us at hello@mindcoreai.eu.

12. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

13. Do We Make Updates to This Notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at hello@mindcoreai.eu or contact us by post at:

MindCore AI
Serenity Court 4
Antonio Galea Street
Birkirkara, MT BKR2763
Malta

15. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.

To request to review, update, or delete your personal information, please contact us at hello@mindcoreai.eu.