PRIVACY POLICY

Mindwibe

Effective date: 01.01.2025
1. General Information
This Privacy Policy explains how personal data is processed within the Mindwibe mobile application.
Operated by:
Mdmindfuldating Limited
England and Wales
12 Virginia Way, St. Ives PE27 6SQ, United Kingdom
Email: info@mindwibe.com
The Company acts as a data controller under:

• UK GDPR
• EU GDPR (Regulation (EU) 2016/679)
• UK Data Protection Act 2018

2. Data We Collect
We may collect and process the following categories of personal data:
2.1 Information Provided by Users
When you create an account or use the Application, you may provide:

• phone number
• email address
• first and last name
• profile photographs
• date of birth
• gender
• information obtained from linked social media accounts
• responses to psychological tests
• journal entries and mood tracking data
• personal goals and plans
• messages and chat history
• audio recordings
• video content
• files uploaded by the user
• likes, matches, and interaction history
• reports submitted and blocking actions
• any other content voluntarily submitted within the Application

Providing certain information may be necessary to access specific features of the Application.

2.2 Technical and Device Data
When you use the Application, we may automatically collect:

• IP address
• device type and model
• operating system and version
• device identifiers (including IDFA, GAID or similar identifiers)
• push notification tokens
• cookies and similar tracking technologies
• application usage data
• interaction logs
• crash reports and diagnostics data

Some of this data may be collected through third-party analytics and advertising partners.

2.3 Location Data
We may process location data to enable matching and proximity-based features.
Location data is collected only where permission is granted through your device settings. You may disable location access at any time in your device settings.

2.4 Inferred and Profile Data
We may generate inferred data based on your activity within the Application, including:

• compatibility indicators
• behavioural patterns
• preference profiles
• engagement metrics

This may involve profiling in order to personalise matching, content, and advertising.

3. Special Category Data
Processed based on explicit consent under Article 9 GDPR.
Consent may be withdrawn at any time.

4. Purposes of Processing
Includes matching algorithms, personalisation, fraud prevention, advertising, analytics, compliance.

5. Legal Bases

• consent
• contractual necessity
• legitimate interests (security, fraud prevention, service improvement)
• legal obligations

Users may object to processing based on legitimate interests.

6. Profiling and Automated Decision-Making
We use algorithms for:

• matchmaking
• personalisation
• targeted advertising

Users have the right to object to profiling and request human review where applicable.

7. Data Sharing
We may share personal data with third parties only where necessary for the operation of the Application, legal compliance, or legitimate business purposes.
7.1 Service Providers
We may share personal data with carefully selected service providers who act as data processors on our behalf, including:
Analytics Providers

• AppMetrica (usage analytics and performance measurement)

Authentication Services

• Google (Google Sign-In)

Payment Processors

• Apple (In-App Purchases)
• Google (Google Play Billing)

Advertising Partners

• Google AdMob
• Yandex Advertising Network

Cloud Infrastructure Providers

• Selectel (hosting and server infrastructure)

These providers process personal data solely for the purposes of delivering their services to us and under contractual obligations that include appropriate data protection safeguards.

7.2 Legal and Regulatory Requirements
We may disclose personal data where required to:

• comply with applicable laws or regulations
• respond to lawful requests by public authorities
• enforce our Terms of Service
• protect the rights, safety, and property of the Company, users, or third parties
• prevent fraud or security incidents

7.3 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of assets, personal data may be transferred to the relevant successor entity, subject to applicable data protection laws.

7.4 Advertising and Analytics Technologies
Certain partners (such as Google AdMob or analytics providers) may process device identifiers and usage data for:

• measuring performance
• delivering personalised advertising
• analytics and service optimisation

Where required by law, such processing is based on user consent, and users may manage advertising preferences through device settings or platform tools.

7.5 No Sale of Personal Data
We do not sell personal data to third parties.
8. International Transfers
Data may be stored in the Russian Federation.
Transfers rely on:

• Standard Contractual Clauses
• Supplementary technical safeguards
• Transfer Risk Assessments

9. Data Retention
Data is retained only as long as necessary.
Upon account deletion, data is erased or anonymised, except where retention is required for legal purposes.

10. User Rights
Requests may be submitted to info@mindwibe.com.
We respond within one month.
Users may lodge complaints with the UK ICO or relevant supervisory authority.