PRIVACY POLICY FOR MOBILE APPLICATION "MINDWAY"
Effective date: 23/02/2024
We take your privacy seriously and are committed to protecting your personal data. This privacy policy explains how we collect, use, and protect your personal data when you use our Mindway app (the "App").
1. DEFINITION OF CONCEPTS

• Mobile application: Software designed for smartphones, tablets, watches, and other mobile devices, developed for specific platforms (iOS, Android, Windows Phone, etc.). For this Policy, the Mobile Application is "MINDWAY."
• Personal data: A set of personal and/or non-personalized information about the User provided or collected.
• Policy: This Mobile Application Privacy Policy.
• User: A person who downloaded and/or activated the Mobile Application.
• User Agreement: An agreement between the Copyright Holder and the User regarding Mobile Application use.
• Copyright Holder: Individual owning exclusive rights to the Mobile Application: "Ryder Mckenzie," Australia, Victoria.
• Cookies: Small files placed on User devices to enhance application or site functionality.

2. RELATIONS TO WHICH THE POLICY APPLIES
General Provisions
This Policy applies exclusively to Personal Data received from the User in connection with their use of the Mobile Application. It does not apply to third-party processing of voluntarily provided User data.
By installing or activating the Mobile Application, the User agrees to the terms of this Policy.
3. LIST OF COLLECTED PERSONAL DATA
Information about users
The Copyright Holder may collect and process:

1. Information about traffic, clicks, logs, and other data.
2. Information about the device (identification number, mobile operator's network, etc.).
3. Information voluntarily provided by the User when using the App, such as notes or journal entries - information is kept securely confidential & not disclosed.
4. User nickname on app & email used to signup

Information about transactions
For in-app purchases, the User's payment information is collected for transaction purposes, fraud prevention, and legal compliance.
Use of cookies
The Mobile Application uses Cookies for traffic control, data transfer, identifying Users, and improving content.
4. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
Processing Purposes
Personal Data is processed for:

1. Analyzing behavior and mediation preferences.
2. Ensuring proper App operation, improving functionality, and content.
3. Anonymous User identification.
4. User orders/purchases.
5. Technical support.
6. Communication with the User.
7. Fulfilling Copyright Holder obligations.
8. Backing up notes and journal entries.
9. Handling of First-Time Client Form: When users submit the first-time client form, their data is handled securely and only provided to the assigned counsellor for the purpose of facilitating counseling sessions. This data is treated with utmost confidentiality and is not disclosed to any third parties except as required by law or with the user's explicit consent.

5. ACCESS OF THIRD PARTIES TO PERSONAL DATA
Using analytical platforms
The Rightholder uses the Amplitude analytical platform to track User behavior, preferences, and content popularity. User consent is implied upon App installation.
Disclosure of personal data to third parties
Personal Data may be disclosed to affiliates, legal successors, payment service providers, third parties with User consent, or as required by law.
6. DATA SECURITY
Reasonable technical and organizational measures are taken to protect personal data from loss and unauthorized access.
7. DATA RETENTION
Personal data is retained as long as necessary for outlined purposes or as required by law. Users can delete data by emailing ryder@mindwayapp.com.
8. EAP SERVICES:
We will not share or disclose any information to (workplace) regarding:

• Your usage on Mindway
• Any emotion tracking data
• Any personal information regarding the counselling sessions

Unless subpoenaed, poses risk or with your consent:

We may share:

• Name & email when signed up
• Date of session conducted for billing purposes only (never personal information)

9. SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER
Request to terminate processing
Users can object to data processing by emailing ryder@mindwayapp.com.
Request for information
Questions about data processing can be sent to ryder@mindwayapp.com.
Change or deletion of personal data
Users can change or delete personal data by deleting their account. The Copyright Holder can delete User accounts for policy violations.
10. TERMS AND PROCEDURE FOR STORING PERSONAL DATA
Storage is carried out by the Copyright Holder throughout the User's App usage period.
11. MINORS ACCESS TO THE MOBILE APPLICATION
The App is intended for users over 18. Minors must stop using the App.
12. FINAL PROVISIONS
Availability of Policy Text for Review
This version is valid from Febuary 23, 2024.
Changes and additions to the policy
The Policy may change. Users are responsible for regularly checking for updates.
Disclosure risk
The User acknowledges that online data transfer is not guaranteed to be safe. Any transfer of Personal Data is done at the User's risk.