Last updated: May 21, 2020
Your privacy is important to us. Everything we do at mymind, Inc. is driven by the values you can find below.
In this policy, we lay out what data we collect and why, how your data is handled, and your rights to your data. We're not in the business of selling your data. We never have been and never will.
Our guiding principle is to collect only what we need. Here’s what that means in practice:
When you sign up for mymind.com, we typically ask for identifying information such as your name and email address. If you sign up via Google or Apple, we only access your NAME and EMAIL address, nothing more. If you use Apple SignIn, you can even hide your email address.
We access your name and email so we can personalize your new account and send you invoices, updates or other essential information. We’ll never sell your personal info to third parties, and we won’t use your name in marketing statements without your permission either.
When you pay for mymind.com, we ask for your credit card and billing address. That's so we can charge you for our service, calculate taxes due and send you invoices. Your credit card is passed directly to our payment processor and doesn't ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and your as-of billing address, for account history, invoicing and billing support. We store your billing address to calculate any sales tax due in the United States, to detect fraudulent credit card transactions and to print on your invoices.
We log all access to all accounts by full IP address so that we can ensure no unauthorized access happens. We keep this login data for as long as your product account is active.
We also log full IP addresses used to sign up for an account. We keep this record forever because we need them to prevent spammy sign-ups.
Web analytics data — described further below — is also tied temporarily to IP addresses to assist with troubleshooting cases. We blind all web analytics data after 30 days.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you, for statistical purposes like conversion rates, and to test new designs.
We do use persistent first-party cookies to store certain preferences, making it easier for you to use our applications, and to support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to see which cookies have been set and how to manage and delete them, please visit allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write to us at mymind.com with a question, we keep that correspondence, including your email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer to give, like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity or gender expression. You may provide these data voluntarily, for example, if you include a pronoun preference in your email signature when writing into our support team.
We do not collect any biometric data.
Our default practice is to not access your information. We promise to never access the content of your mind. The only times we’ll ever access or share your info are:
→ When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.
At mymind, Inc., we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) in the United States. mymind Inc. recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
→ Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
→ Right to Correction. You have the right to request correction of your personal information.
→ Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using mymind Inc. services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
→ Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
→ Right to Restrict Processing. This is your right to request the restriction of how and why your personal information is used or processed, including opting out of the sale of personal information. (Again: We never have and never will sell your personal data.)
→ Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
→ Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
→ Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
→ Right to Non-Discrimination. This right stems from the CCPA. We do and will not charge you a different amount to use our products, offer you different discounts or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at firstname.lastname@example.org
To identify your specific authority to file a complaint or find out more about GDPR, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.
In many of our applications, we give you the option to trash data. Anything you trash on your product accounts while they are active will be kept in an accessible trash can for up to 30 days. After that, the trashed data are no longer accessible via the application and are deleted from our active servers within the next 30 days. We also have some backups of our application databases, which are kept for up to another 30 days. In total, when you trash things in our applications, they are purged within 90 days from all of our systems and logs. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome, so if you change your mind you’ll need to do so before your data are deleted from our active servers.
We also delete your data after an account is canceled. In this case, there is no period of data being kept in an accessible trash can so your data are purged within 60 days. This applies both for cases when an account owner directly cancels and for auto-canceled accounts. Please refer to our cancellation policy for more details.
EU-US and Swiss-US Privacy Shield policy
The GDPR requires that data transfer out of the EU must only happen to countries deemed as having adequate data protection laws. The United States generally doesn’t meet that requirement. Privacy Shield is an agreement between certain European jurisdictions and the United States that allows for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary.
We comply with the frameworks for EU, UK, and Swiss data that are transferred into the United States.
mymind Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regard to the Privacy Shield Frameworks.
The Privacy Shield Frameworks uphold specific principles, many of which are already outlined in the section on Your Rights. For clarity, pursuant to the Privacy Shield Frameworks, the following principles apply to all EU, UK and Swiss data that has been transferred into the United States:
You have the right to access your personal data and to update, correct and/or amend information that is incomplete. You also have the right to request erasure of personal information that has been processed in violation of the principles. If you wish to exercise these rights, you may do so by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at email@example.com
→ We remain liable for the onward transfer of personal data to third parties acting as our agents, unless we can prove we were not a party to the events giving rise to the damages.
→ We do not sell personal data nor do we permit it to be used for reasons other than those for which it was originally provided. If this practice should change in the future, we will update this policy accordingly and provide you with opt-out or opt-in choice as appropriate.
→ We may be required to release personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.
mymind Inc. has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/bbb-privacy-shield/eu-dispute-resolution for more information and to file a complaint. This service is provided at no cost to you. Please do not submit GDPR complaints to BBB EU Privacy Shield.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. To learn more, please see the Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our site, participating in any of our services and/or providing us with your information, you consent to this transfer.
We may update this policy as needed to comply with relevant regulations and reflect any new practices.
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