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This policy describes our privacy practices – what Personal Information we collect about our Users, what we do with it, how we share it, and your rights regarding that Personal Information.

By accessing or using any of our Services, you acknowledge that you have read this Privacy Policy.

Privacy Policy

The scope

MINDer provides you with tools to assess how your lifestyle and health background may influence your cognitive abilities through our website and the tools provided on there (collectively referred to as our “Services”).

We collect your personal data to enable you to benefit from these Services effectively.

This Privacy Policy explains the types of personal data we collect, the purposes and methods of collection and use, the circumstances under which we may share your data, and the rights and choices available to you to manage your personal data in compliance with applicable laws.

The data controller is MINDer (hereinafter referred to as “we,” “our,” or “us”). This Privacy Policy applies whenever you access our website (referred to as the “Site”), communicate with us via online or social media channels, or interact with our Services.

US

MINDer is a digital wellness platform that helps you evaluate how your lifestyle and wellness factors may influence your cognitive abilities. This evaluation is based on specific user inputs, informed by publicly available academic research and medical guidelines. These inputs are compared against outcomes and statistics derived from the same research and guidance.

"Data"

We can collect “Personal Data” (or “Data”) that identifies you:

either directly, such as your first name and your email address
or indirectly, such as an online identifier (e.g. your account ID, your IP address, a cookie identifier) or one or more factors specific to your physical, physiological, genetic, mental identity.

Data Collection

We may collect your Data and combine this Data with data providing by our partners:

a) You  use our Services.
We can collect some Data to provide you with our Services, to improve and personalize your online experience, to analyze trends and demographics, to prevent fraud and to improve the security of our Services.

We may collect the following types of information:

  • Contact Details: this includes information such as your name, gender, your date of birth, your email address or your login and password (together your “Contact Details”).

  • Health Data: this includes information about diabetes,  blood pressure, cholesterol levels, hearing and visual problems, Body Mass Index (BMI),  anxiety, mood disorders, and your cognitive abilities (together your “Health Data”).

  • Lifestyle Information: this includes information about your smoking, sleep, exercise habits and work habits.

  • Technical information: this includes your browsing data and technical Information, to access to our Services and security of our Services, such as: visited pages, identifier of your device and the connection (IP address, MAC address), login dates and times, information concerning the browser and the operating system you use.
     

We use various types of technologies such as cookies (”Cookies”) to collect such Data when you use our Services or visit a third party site where we and our partners provide personalized content or carry out content use analysis. There's a further section below on these.

We allow some of our partners to set and access their Cookies on your device. These partners’ use of Cookies is subject to their own privacy policies and not this Privacy policy.


b) You sign into our Services or our partners platform with a social login or your credentials.‍
We collect the Data that you have agreed to share via the social media site or third party such as comments, social media handle/username, number of followers, email address.

c) You subscribe to updates or ask to be contacted by us or our partners.‍
We collect your email address and other contact details when you sign up to our newsletters or ask to be contacted by us or our partners. You can unsubscribe at any time by clicking on the unsubscribe link available at the end of each email.

d) You make a purchase in our online services.‍
We collect the Data needed to process your purchase (in particular to handle your order, process invoices and payments, deliver your purchase, prevent fraud) such as your “Contact Details”, your bank details (your “Payment Details”) and purchase history.

e) You are exposed to personalised advertisements or content on our Services or those of our partners.‍
We collect Data such as the advertisement, and the number of times it was watched, its location and the identifier of your device. We also collect information about your actions in relation to the advertisement, such as the sites visited as well as the dates and times of the visits.

We may also use your Data collected to offer you personalised advertisements, products, services, or content (“Personalised Content”) via our Services or those of our partners.
If you wish to withdraw your consent or object to the personalisation of advertisements, please visit the "What are your rights" and "How do you exercise your rights?" sections below.

f) You take part in a survey or poll organised by us.‍
We may collect Data such as your last name, your first name, your date of birth and your email addresses and survey responses.
We use this Data to administer the survey, to send you promotional offers and/or for internal statistical purposes.

g) You contact us via our customer support or social media.‍
If you contact us via our customer support, we collect Data such as your last name, your first name, your username, your email address, your date of birth, your postal address, depending on your questions or requests.

We will record the content of our correspondence with you. This data could be used to monitor service quality and compliance, prevent fraud, or provide training for our staff and customer service teams.If you contact us via social media, we collect some of the Data included on your profile.


h) You do not comply with our terms and conditions.‍
When you use our Services, we ask that you comply with our terms and conditions which are intended to protect our users, employees and our rights.If you do not abide by these rules, you may be sanctioned including in the event of inappropriate conduct. We will keep your Data for the time needed to apply these exclusions. This Data may include for example your username, your IP address, and the identifier of your device.


How long is my data kept?

Unless the law specifies a different retention period (e.g. for complying with legal, accounting, tax requirements and for managing your rights and/or our rights), we will only keep your Data for the time strictly necessary to carry out the operations for which said Data has been collected.
 

For example, if you purchased a product or a service from us, we retain some transactional data attached to your contact details to comply with legal, tax or accounting obligations, as well as to allow us to manage our rights (for example to assert our claims in Courts) during applicable laws and regulations.
 

At the end of this data retention period, your personal data will be erased or anonymized.


i) You interact with other users (via our social media pages).‍
We collect Data such as your username, IP address, the date, time, and we save the content of your messages to allow you to interact with other users in a secure environment.

How do you store, use, share and disclose site visitors' personal information?

Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.  

 

All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service.

Where you use a password for registering with our Services, you are responsible for keeping this password confidential. We ask you not to share your username and/or password with anyone.

We cannot guarantee the security of Data that you transfer over the internet or a telecommunication network to us; however, we do take appropriate technical and organisational measures to safeguard your personal data.

GDPR

Access and Data Portability (Right of Access and Data Portability)
You have the right to access the personal data we hold about you. You can request a copy of your data in an interoperable format (data portability). This allows you to transfer your data to another service provider or use it yourself.

However, if you have been excluded from using our Services, we may not be able to provide access to data related to your exclusion to protect our ability to detect and prevent violations of our terms.


Correcting Your Data (Right to Rectification)
If you believe the information we hold is inaccurate or incomplete, you can request that we update or correct it.


Objecting to Our Use of Your Data (Right to Object)
You may object to our use of your personal data. If your rights outweigh our legitimate interests in using your data, we will either restrict its use or delete it at your request.

 


Providing and Withdrawing Consent (Right to Consent)
You can provide or withdraw your consent for specific uses of your data at any time, including:

  • Research Participation: Contact us to withdraw from participation in research. Upon withdrawal, your personal data will be securely destroyed or anonymized.

  • Newsletters and Emails: Opt out of receiving marketing emails or newsletters by using the unsubscribe link in our messages or contacting us directly.

  • Personalized Content and Advertisements: Manage consent for personalized ads, sharing of your data, or use of specific cookies by visiting our Cookies page. On mobile devices, adjust your privacy settings (e.g., “Limit Ad Tracking” on Apple or “Opt-out of Ads Personalisation” on Android).

Deleting Your Data (Right to Erasure or Right to Be Forgotten)
You can request the deletion of your personal data in the following cases:

  • You wish to delete your account.

  • We no longer need your data.

  • You have successfully objected to our use of your data.

  • You have withdrawn your consent for specific uses.

  • Your data was processed unlawfully.

If you have been excluded from our Services, we may retain data related to your exclusion to ensure continued enforcement of our terms.


Restricting the Use of Your Data (Right to Restriction of Processing)
You can request restrictions on the use of your data if:

  • You do not want us to delete it but prefer to limit its processing.

  • You are challenging the accuracy of the data we hold.

  • You believe we have used your data unlawfully.

If you are a user of our Services and you want to exercise any of your rights set out above, please contact us via the “contact us” button available in our application, or email founder@mind-er.com

General Conditions for Data Deletion or Processing Restriction
If you object to processing, withdraw your consent, or request data deletion, we will stop processing your data or delete it unless we have overriding legitimate grounds or need the data for legal purposes, in accordance with applicable laws and regulations.

Updates

Please note that we may update or change this privacy policy.

If we update our privacy policy, we will post those changes to other places we deem appropriate. You are deemed to have accepted the new terms of the privacy policy when you first use the Services.

Processing

  • Contractual Obligation: We process your data to fulfill a contract between us, which includes providing Services such as completing purchases, granting access to assessment results associated with your purchase, managing payments, inviting you to leave a review, or participate in surveys.

  • Legitimate Interest: We rely on legitimate interests to enhance your user experience. This includes understanding our product's performance (identifying strengths, weaknesses, opportunities, and threats), testing and developing new or improved products and services, staying updated on industry trends, maintaining the integrity and security of our IT systems and networks, troubleshooting, system maintenance, support, reporting, hosting data, processing payments, addressing your questions or requests, and sending newsletters. Additionally, we use your inputs in alignment with publicly available academic research and medical guidelines to generate cognitive health assessments and build a database of common risk factors and their links to lifestyle for further research into cognitive health.

  • Your Consent: We process your data with your consent for activities such as research participation, handling your health data, and providing personalized advertisements based on Cookies. You have the right to withdraw your consent for data processing, including health data, at any time.

  • Legal Obligation: We process data to comply with legal requirements, such as addressing complaints or inquiries from competent administrative or judicial authorities, or any other authorized entities, in accordance with applicable laws.

Cookies

Cookies are small pieces of data stored on a site visitor's browser. They are typically used to keep track of the settings users have selected and actions they have taken on a site.

 

You would have been presented with a Cookie consent bar when you visited the website. This gives site-visitors the opportunity to accept or decline non-essential cookies on your site. 

Wix uses cookies for important reasons, such as:

  • To provide a great experience for your visitors and customers.

  • To identify your registered members (users who registered to your site).

  • To monitor and analyze the performance, operation and effectiveness of Wix's platform.

  • To ensure our platform is secure and safe to use. 

Cookie Name
Purpose
Duration
Cookie Type
XSRF-TOKEN
Cookie for fraud detection of calls
Session
Essential
hs
Security Cookie for Hive (legacy)
Session
Essential
svSession
Session cookie for identification
6 months
Essential
SSR-caching
Performance cookie for rendering
24 hours
Essential
TS*
Cookies for attack detection
Session
Essential
bSession
Used for system effectiveness measurement
24 hours
Essential
fedops.logger.sessionId
Tracking session errors and issues (resilience)
12 months
Essential
_wixAB3|*
Cookie for site experiments
6 months
Essential
server-session-bind
Cookie for API protection
Session
Essential
client-session-bind
Cookie for API protection
Session
Essential

As well as Wix cookies, we use GA4 (Google Analytics) to monitor site traffic, and Google Ads for marketing. You can check which cookies are used by each business solution, third-party app or third-party integration using Chrome's built-in cookie view. While in incognito mode, click the Secure icon  next to the URL bar and then select Cookies.  

To learn more about cookies go to https://allaboutcookies.org/

Within our Services, we may contain links to Third party websites. These third-party organisations will have their own privacy policies and Cookies which you should read carefully before providing any of your personal data as we do not accept any responsibility or liability for the websites of other organisations.

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