Privacy Policy

Last edited November 2021

Mindr Inc. and its affiliates (“Mindr”) are committed to respecting the privacy of your information. This Privacy Policy describes your privacy rights regarding Mindr’s collection, use, storage, sharing, and protection of your personal information and/or data. It applies to Mindr’s website and all related platforms, websites, applications, services, tools, modules, integrated application sites and remote services, servers, and services residing on servers owned and/or operated by third parties (collectively, our “Sites and Services”) where this policy is referenced, regardless of how you access or use them. Before you use or submit any information through or in connection with the Sites and Services, please carefully review this Privacy Policy. By using any part of our Sites and Services, you agree to the terms of this Privacy Policy and consent to the processing of your personal information as described here. IF YOU DO NOT AGREETO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITES OR SERVICES.

Throughout this Privacy Policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person.

Information we collect when you use our Sites and Services.

We collect certain personally identifiable information that you submit through the Sites and Services, as well as other non-personally identifiable information that we collect through cookies and other tracking technology, as more particularly described below. We may collect information about the way you interact with our Sites, Services, content and advertising. This may include, but is not limited to, device ID, device type, machine ID, geo-location information, computer and connection information, present and former actions taken using sites or accounts linked to any of your accounts with Mindr Sites or Services, statistics on page views, traffic to and from our Sites, IP address, ad data, and standard web login formation, and any telephone number you provide us or from which you may call or otherwise contact us.

You are not required to provide personal information that we request, but if you chose not to do so, in many cases we will not be able to provide you with our products and services correspond to any queries you may have.

Information we collect from other sources.

We may also obtain information from or about you in other ways. For example, we may verify user information with a service provider or combine your information with additional information we collect from other third parties or sources, as authorized and permitted by law. Also, we collect the information you send to us such as correspondence, customer satisfaction surveys or customer service communications, testimonials or user content such as photos, blogs and writings.

How We Use Information.

Our primary purpose in collecting personal information is to provide you with a safe, efficient and customized experience. We may use the information we collect to:

Provide and improve the Sites and Services, including to develop new features or services, to take steps to secure the Sites and Services, and for technical and customer support;

Create your account, process transactions and facilitate and/or customize your use of the Sites and Services;

Prevent, detect and investigate potentially prohibited or illegal activities, and enforce any of our user agreements;

Customize, measure and improve our Sites and Services and advertising, including to monitor traffic through our Sites and Services;

Contact you to tell you about our services and those of our corporate family, service updates, targeted marketing and promotional offers based on your communication preferences;

Contact you to resolve disputes, collect fees, and troubleshoot problems with your account or our sites, services, applications or tools, or for other purposes authorized by law;

Contact you at any telephone number using auto-dialed or pre-recorded message calls or SMS or other text messages (if applicable) for the purposes described in this Privacy Policy or our User Agreement;

For analytics, research and reporting, including to analyze and derive insights from your use of the Sites and Services; and

Compile aggregate user data that is stored in our databases, which may be used for marketing and other purposes related to our Sites and Services.

Further, if you attend an event sponsored or hosted by Mindr, you grant Mindr the right to use any photos, videos or audio taken of you or your dependents at the event for Mindr’s promotional and advertising purposes and otherwise on the Sites and Services without any compensation to you, and you waive any rights or privacy, publicity or any similar rights that you may have in connection with such photos, video or audio.

How we share information.

We share information between our systems and that of third parties so as to allow us to test, develop, market or deploy new or existing Sites and Services. We make every attempt to remove user identifiable information from the data that we collect and share with third parties. However, for some services information like names, address and other transaction-related data might be shared for the purposes of completing transactions authorized by you. We may also disclose personal information to respond to legal requirements(for example, in response to requests by federal, state or local authorities, including tax authorities, subpoenas, court orders or other legal process) or in the good-faith belief that disclosure is legally required, enforce our policies, establish or exercise our legal rights or protect anyone’s rights, property or safety. We may also disclose your information with current or future affiliated companies. Aggregate analytics data may be used to improve our Sites and Services, and may also be disclosed to affiliates, partners, subsidiaries, subscribers, or other third-parties for our or their benefit.

We may also share your personal information with:

Service providers under contract who help with our business operations (such as fraud detection, credit card processing, or bill collection).

Co-brand partners for certain sites or events. When we identify a co-brand partner for a site or event, you agree that we may share contact information and transaction data (excluding credit or debit card numbers) with that partner. Information shared with a co-brand partner is subject to their privacy policy. We do not control the privacy policies of co-brand partners and we encourage you to review their privacy policies.

Marketing partners for certain sites or events where you agree during checkout that you would like your information shared for their marketing purposes. We may share your contact information and transaction data (excluding credit or debit card numbers) with the marketing partner identified in checkout. Information shared with a marketing partner is subject to their privacy policy. We do not control the privacy policies of marketing partners and we encourage you to review their privacy policies.

Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).

Other business entities, should we plan to merge with or be acquired by that business entity or sell assets. Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information will be used contrary to this policy, you will receive prior notice.

Legal Basis for Processing Personal Data.

The law in some jurisdictions requires us to tell you about the legal grounds that we rely on to use or disclose your personal information. To the extent those laws apply, our legal grounds for processing such information are:

1. Honoring Contractual Commitments to You. Much of our processing of information is to meet our contractual obligations to provide products and services to customers.

2. Legitimate Interests. In many cases, we handle information on the grounds that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, including without limit: customer service; marketing and advertising; protecting our users, personnel and property; analyzing and improving our business; and managing legal issues.

3. Legal Compliance. We need to use and disclose information in certain ways to comply with our legal obligations.

4. Consent. Where required by law, and in some other cases where legally permissible, we handle information on the basis of consent. In such cases, you have the right to withdraw your consent at any time.

Cookies and web beacons.

When you first use our Site and Services, Mindr may send a cookie to your computer that identifies you as a unique user. We may use session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to store your preferences, identify you and maintain your signed-in status, and provide you with a more personal and interactive experience. You can set your browser to refuse cookies or delete persistent cookies by following your browser’s help instructions. If you choose to disable cookies, some of our services may not work properly. We may also use web beacons which are typically small graphic objects or pixels that are embedded in a web page. These web beacons allow us or our provider(s) to check that a user has viewed a web page.

Accessing and changing personal information.

You can request information regarding and change your account information by contacting Mindr. To the extent any such information is stored in your account profile, we can assist you in changing your address, telephone number, email address, password, credit card information, Social Security Number or Taxpayer ID (if applicable) and privacy and communications preferences.

We may communicate with you at various times, with administrative emails or phone calls, about transactions and service announcements, customer service responses and promotional emails like special offers, newsletters and updates. You can choose to stop receiving promotional emails at any time simply by contacting us or using an email’s unsubscribe function. You may not opt out of receiving administrative messages or customer service responses. If you have agreed to receive marketing communications through check-out with our partners, you must change your communication preferences with them directly.

Security and Retention.

Your information is stored on our servers located in the United States. We treat data as an asset that must be protected and use tools (encryption, passwords, physical security, etc.) to protect your personal information against unauthorized access and disclosure. However, as you probably know, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from the site. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

We retain information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our user agreements and take other actions permitted by law.

Third Parties.

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, whether they are buyers or sellers on our Site or other sites throughout the internet (including the ones we link to), different rules may apply to their use or disclosure of the information you disclose to them. Mindr does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.

Children’s Privacy. The Sites and Services are not intended for children under the age of 18. Moreover, Mindr does not knowingly collect personal information (as defined in the Children’s Online Privacy Protection Act) from children under the age of 13. If Mindr becomes aware that it has collected personal information from children under the age of 13, Mindr will take steps to delete such information in accordance with its legal obligations.

California Privacy Rights.

California law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined by applicable California law) with third parties for their direct marketing purposes. We may share your personal information with third parties.  This use and sharing of your personal information is not intended to permit them to use that information for their own direct marketing purposes, however we encourage you to confirm their privacy policies directly. If you have agreed to receive direct marketing communications with our partners, you must change your communication preferences with them directly.

Privacy Policy Updates.

If we decide to change our privacy policy, we will post those changes on this site and notify you of material changes with an alert on the site or a communication to you. Changes take effect 30 days after they are posted to the Site. This policy was last updated effective September 20th, 2021.

Questions.

Should you have any questions or concerns regarding this policy, please contact us at legal@mindrglobal.com.