Privacy Policy

Last Updated: August 26, 2025

MindCircle Pty Ltd (“we,” “us,” “our,” or “the Company”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (“the App”) and related services. The App provides mindfulness, meditation, breathing exercises, and sleep support programs, along with features for tracking social impact contributions.

By using the App, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the App. This Policy should be read in conjunction with our Terms and Conditions, available at [https://mindcircle.io/terms-and-conditions/].

We comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) and, where applicable, other data protection laws such as the General Data Protection Regulation (GDPR) for users in the European Union (EU) or European Economic Area (EEA).

1. Information We Collect

We collect the following types of information:

1.1. Personal Information

• Information you provide directly, such as:
  • Name
  • Email address
  • Age (to verify eligibility, as the App is restricted to users at or above the age of legal majority in their jurisdiction)
• We collect this during account registration or when you contact us for support.

1.2. Usage and Device Information

• Automatically collected data, including:
  • Device identifiers (e.g., IP address, device type, operating system)
  • App usage data (e.g., session duration, features accessed, milestones achieved for social impact programs)
  • Log data (e.g., access times, errors)
• This helps us improve the App and track contributions to social causes.

1.3. Other Information

• If you interact with third-party integrations, we may collect related data as necessary.
• We do not collect sensitive information (e.g., health data) unless you voluntarily provide it, but note that App usage may imply wellness interests.

We do not collect information from children, as the App is not intended for users under the age of legal majority.

2. How We Collect Information

• Directly from You: When you create an account, subscribe, or contact us.
• Automatically: Through cookies, analytics tools, or device sensors (e.g., for usage tracking). We use technologies like Google Analytics or similar for anonymized insights.
• From Third Parties: Such as app stores (e.g., Apple App Store, Google Play) for payment details, or partners for social impact verification. We do not receive your payment information directly.

3. How We Use Your Information

We use your information for the following purposes:

• To provide and maintain the App, including account management, feature access, and subscription billing.
• To track and fulfill social impact contributions based on your milestones (e.g., sharing aggregated data with partners).
• To improve the App, such as analyzing usage patterns or fixing bugs.
• To communicate with you, including sending service updates, promotional offers (with your consent where required), or responding to inquiries.
• To comply with legal obligations, prevent fraud, or enforce our Terms.
• For research and analytics, in anonymized or aggregated form.

Under GDPR (for EU users), our legal bases include: consent (e.g., for marketing), contract performance (e.g., providing services), and legitimate interests (e.g., security).

4. Sharing Your Information

We do not sell your personal information. We may share it as follows:

• Service Providers: With trusted third parties who assist us (e.g., cloud hosting like AWS, analytics providers, payment processors via app stores). They are bound by confidentiality and data protection obligations.
• Legal Requirements: If required by law, subpoena, or to protect rights/safety (e.g., in response to government requests).
• Business Transfers: In the event of a merger, acquisition, or sale of assets.
• With Your Consent: For any other purpose you approve.

5. Data Storage and Security

• Storage: Your data is stored on secure servers in Australia or with international providers (e.g., AWS regions). We retain personal information only as long as necessary for the purposes outlined (e.g., active accounts) or as required by law (e.g., 7 years for tax records).
• Security: We implement reasonable measures, such as encryption, access controls, and regular audits, to protect against unauthorized access, loss, or misuse. However, no system is 100% secure; you use the App at your own risk.
• Breach Notification: In case of a data breach, we will notify affected users and authorities as required (e.g., within 72 hours under GDPR).

6. International Data Transfers

As an Australian company with global users, your data may be transferred outside your jurisdiction (e.g., to EU-compliant servers). For EU users, we ensure adequate safeguards, such as Standard Contractual Clauses, to protect your data under GDPR.

7. Your Rights and Choices

You have rights regarding your information:

• Access and Correction: Request a copy of your data or correct inaccuracies.
• Deletion: Request erasure (e.g., “right to be forgotten” under GDPR), subject to legal exceptions.
• Objection/Restriction: Object to processing or restrict it (e.g., for marketing).
• Portability: Receive your data in a portable format (GDPR).
• Withdraw Consent: Where processing relies on consent.
• Opt-Out: From marketing emails via unsubscribe links.
• Cookies: Manage via device settings; note that disabling may affect functionality.

To exercise rights, contact us at support@mindcircle.io. We respond within 30 days (extendable under GDPR). EU users may complain to their data protection authority (e.g., OAIC in Australia for all users).

8. Children’s Privacy

The App is not directed to children under the age of legal majority in their jurisdiction. We do not knowingly collect data from minors. If we discover such data, we will delete it promptly.

9. Changes to This Privacy Policy

We may update this Policy to reflect changes in practices or laws. We will notify you via in-app notice, email, or by posting the updated version on our website with the new “Last Updated” date. Continued use constitutes acceptance.

10. Contact Us

For questions or complaints:

Email: support@mindcircle.io