This policy describes our policies and procedures for collection, transmission, storage, processing, disclosure and protection of any data, including, but not limited to, personal data provided by you as a user while using the service. User shall mean any person/ persons, who visits, uses, deals with and/ or transacts through My Vital Mind app (“privacy policy”). Please also read our terms of service (“agreement”), which sets out the terms governing the services. The terms and conditions, privacy policy and any other terms and conditions as may be applicable shall hereinafter collectively be referred to as “agreement” or “contract”.
This Privacy Policy is meant to help You understand what data We collect, why We collect it, what We do with it, how You can manage and control the Use of Your data and the rights You have to access and control Your Personal data.
We will always respect and protect Your privacy, and this forms a part of Our guiding principles. We have policies and procedures in place to protect the privacy and security of Your Personal data. Your trust means a lot to Us. My Vital Mind does not request Your Personal Data. Your data is secured with strong encryption during transmission and storage.
Your use of the My Vital Mind App will be governed by this Privacy Policy as applicable to My Vital Mind App together with all policies, notices, guidelines, disclaimers that are published and shared with You from time to time including but not limited to My Vital Mind Terms of Service.
We reserve the right to make changes to this Privacy Policy and to make such changes effective for all data We may already have collected from You. We will notify You via in-app notifications when We make any changes to the Privacy Policy. If the changes to the Privacy Policy include changes to the collection, storing or processing Your Personal information in a way that infringe into Your privacy, we will notify You clearly about the same and seek Your consent for the same where required by the applicable laws and regulations. Please note that by installing My Vital Mind App, providing Your nickname and clicking the proceed arrow within the My Vital Mind App, You acknowledge and consent to this Privacy Policy and Our Terms of Service.
Anonymization is the process of removing personally identifiable data from data sets so that the person can no longer be identified directly or indirectly.
Cookie is a small amount of data generated by a Website and saved by Your Web browser. Cookies are used to store User preferences for a specific site. Use of cookies makes Web- surfing easier. You may refuse to accept Cookies by activating the setting on Your browser which allows You to refuse the setting of Cookies. Data or Information under this Privacy Policy means Both Personal and NonPersonal data or information.
Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Data Processor means a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the data controller.
Encryption is the process of transforming data into unreadable text so that it is only legible to those possessing an encryption key. The process of making encrypted data readable again is referred to as decryption.
Personal data or Personal Information means data relating to an identified or identifiable natural person who can be directly or indirectly identified by reference to an identifier such as full name, identification numbers, location address, online identifier and other identifiers within the definitions of The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or data) Rules 2011, General Data Protection Regulation (GDPR) (EU) 2016/679 regulation and UK-GDPR. Personally identifiable information (PII) and Sensitive or Special Category of Personal data is covered within the definition of Personal Data.
Pseudonymisation means the processing of Personal data in such a manner that the Personal data can no longer be attributed to a specific User without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal data are not attributed to an identified or identifiable natural person. Non-Personal data or Non-Personal Information means any data that does not reveal Your specific identity either directly or indirectly. Sub-Processor/s is a processor who is sub-contracted some of the personal data processing. Web browser is a software program that allows User to access, retrieve and view data on the World Wide Web. Examples of browsers include Internet Explorer, Firefox, Google Chrome and Safari.
What Data do We collect and how do We Use it? a. How do We handle Your Personal Data? No identifiable information is solicited or stored in the My Vital Mind app. As data is not related to an identifier or identifiable natural person, it will no longer be Personal data or Special Category of Personal data. There is no user registration nor are You asked to share Personal data when You install and use My Vital Mind App and Services. We collect, transfer and securely store the unique vendor specific ID provided by the Apple App Store or Android Play store when You install My Vital Mind App on Your device. This is done for the purpose of generating a random pseudonymised user identifier. This pseudonymised identifier generated becomes the user Id that is referred to for all subsequent data transfers and linking Your data within My Vital Mind databases. This processing is based on Our Legitimate Interest. You have the Right to be Forgotten. You can also, at any point of time, clear all Your provided data by writing to us at myvitalmind3@gmail.com. DO NOTE THAT CLEARING DATA DELETES ALL YOUR SUBMITTED DATA INCLUDING YOUR IDENTIFIERS, PAST CONVERSATIONS, REMINDERS, ASSESSMENT RESPONSES AND ENABLED SETTINGS. POST RESET, YOU WILL NOT BE ABLE TO RECOVER YOUR PAST DATA AND YOU WILL BE CONSIDERED AS A NEW USER OF THE APP. HENCE, THIS FEATURE IS TO BE USED BY YOU AT YOUR DISCRETION.
b. How do We handle Your conversation messages? When You use the Interactive videos on our app, and enter any data on My Vital Mind app We collect, transmit and securely store these such data in Our servers. Processing of Your data is based on Our Agreement that You agree at the time of installing and using My Vital Mind App. We do not collect any Personally Identifiable Information from You. At the same time, We do use anonymised data that is required for research and statistical purposes based on Our Legitimate Interest to improve Our Product and Services and contribute to the development of user-centered mental wellbeing best practices globally. Your data is encrypted during transmission and storage. All the interactions You have with My Vital Mind App is private. No one within or outside of our Data Controller has access to Your Data except to process based on Our Legitimate Interest and based on principles of privacy by design and default.
c. How do we handle Your name? When You Use the Service, We will not ask for and will not require Your full name at any point of time during the conversation. After installation, We take You through a one time on-boarding process. Here We ask for only Your nickname. ALWAYS USE NON-IDENTIFIABLE NICKNAME TO MAINTAIN COMPLETE ANONYMITY.
d. Why do We ask about Your thoughts, feelings (emotions), mood, major event or life changes, goals ? When You Use the Service, We may periodically ask You wellness-related information such as Your thoughts, feelings or emotions, mood, major events / changes in life, Your resilience goals and Your energy levels. Processing of Your response is based on Our Agreement and solely to provide You evidence-based tools and techniques to manage emotions and encourage mental well-being in a self-help context. We use Your anonymized and minimal wellness-related information for populationlevel research and statistical purposes as per Our Legitimate Interest.
e. How do We handle Your Device data when You Use Our Service? When You Use the Service, We collect, securely encrypt and transfer and store the following data from Your mobile device: mobile application identifier, mobile operating system, OS version, device make and model. We process this data based on Our Legitimate Interest to detect and deter unauthorized or fraudulent Use of or abuse of the Service, to troubleshoot issues, for debugging app crashes and to optimize Your experience for e.g. to make sure My Vital Mind App is displayed correctly on Your phone, or Your usage settings are applied.
Do We use Cookies? We do not use any Cookies and beacons within My Vital Mind App. We use cookies and Web beacons on Our Website. These collect and process data such as browser type, browser language, Operating System, browser data including type and language settings along with the actions You take on Our Website (such as the Web pages viewed and the links clicked. This data is collected after taking required consent from the Users based on Our Cookie Policy. We do not share or sell Your provided data to any third party.
f. How do We use any Third Party Analytics tools and software? When You use the Service, My Vital Mind App usage and system generated event data gets logged and sent to third-party operations and analytics tools such as Google Analytics, Facebook Analytics and Firebase via their secure API integrated within the My Vital Mind App. No Personal Data is shared. We use random Firebase generated Identifiers of the User to send in-app and push notifications. Processing of events data is based on Our legitimate Interest to view My Vital Mind App engagement and Operational performance to improve Our Service Quality, Safety and Performance No direct advertising or direct marketing is performed both within and outside the app. However, to measure the effectiveness of our social media or other marketing campaigns, We may install third-party modules (Google Analytics, Facebook Analytics, Firebase and branch.io) within the My Vital Mind App to help Us understand Service performance based on User use. This helps us make improvements to Our Service experience for Our Users. Event data from these modules is sent to third-party operations and analytics tools such as Google Analytics,Facebook Analytics and Firebase via their secure API integrated within the My Vital Mind App. No Personal data is shared. These events do not contain any conversational data provided by You during Your use of the Service. Processing of events data is based on Our Legitimate Interest to view My Vital Mind App engagement and Operational performance to improve Our Service Quality, Safety and Performance. Apart from the App-pushed events, the third party tool APIs also may automatically collect some non-personal events. Google Analytics automatically collected events. The use of Google Analytics is governed by Google Data Policy and Data Safeguards . The use of Facebook Analytics is governed by Facebook Data Policy and Terms of Service. The use of Firebase is governed by Firebase Terms of Service, Use Policy and Crashlytics Terms of Service.
g. How do We handle Your App password? For Your privacy and security, You are advised to set Your own My Vital Mind App PIN to protect unauthorized access of Your conversation messages. Your mobile device screen password is Your PIN. You can also change Your PIN Using the “Passwords” option under settings. The PIN that You Use is personal to You, and You are responsible for maintaining the confidentiality and security of Your PIN. PLEASE KEEP YOUR PIN SAFE AND DO NOT SHARE IT WITH ANYONE. The PIN You set remains in Your device and is not collected, transmitted and stored in Our servers.
h. What do We do with Your feedback and ratings? When You Use the Service, You have an option to send Your feedback from within the My Vital Mind App and through Our Website.. Feedback can be given using the Feedback feature provided in the My Vital Mind App setting. If You contact Us from Our Website “Contact Us”, We will collect minimal Personal Information provided by You such as Your name, Your email address, and Your message. This data is securely stored in Our account with access to only authorized users. We will Use this data to address Your requests to provide You support and to improve Our Services. Your Email will be retained within Our system for a maximum of 10 years since last correspondence as per Our Information Retention Policy. We process Your data for our Legitimate Interest. We will not use Your Personal data for any Direct Marketing without Your Consent. We will not share or sell Your personal data to any third party. Processing Your anonymous feedback and rating is based on Our Agreement and used by Us to improve the product and Your Service quality, safety and performance. AS A BEST PRACTICE, IT IS ADVISED THAT YOU TAKE ADEQUATE PRECAUTIONS TO NOT SHARE YOUR SENSITIVE HEALTH OR PERSONAL DATA WHILE GIVING FEEDBACK OVER EMAIL NETWORKS.
i. How do We handle notifications or reminders? When You Use the Service, You have the option to activate or deactivate push notifications or reminders in My Vital Mind App settings. You can cancel or restrict notifications at any time through the Notifications tab in your profile Processing of Your notifications is based on Our Legitimate Interest to send Service information and reminders that help improve My Vital Mind App engagement.
j. How do We handle User Incident support? There may be occasions where You wish to contact Us to seek support or to complain about any of Our Services.If You contact Us directly in Our Email, either via Our Apps or Website, We will collect minimal Personal Information such as Your name, Your email address, Your phone number (if You provide), subscription receipts, as well as, where required, data about Your mobile device or personal computer such as device type, and OS type. This data is securely stored in Our account with access to only authorized users. We will Use this data to address and investigate the issues or requests You have forwarded to Us, to provide You support and to improve Our customer support Service. Your Email will be retained within Our system for a maximum of 10 years since last correspondence as per Our Information Retention Policy. We process Your data for our Legitimate Interest. Your issues or complaints or requests about My Vital Mind App and Services are taken very seriously. You will need to send an email request from Your Google or Apple email ID to myvitalmind3@gmail.com. We try our best to respond to Your complaints within 7 business days. Some of Your complaints may take longer to resolve. We will continuously provide You with an update until Your complaints are satisfactorily resolved.
k. How do We handle data provided during promotions and surveys? From time-to-time, we send out in-app or push notifications to share discounts and new releases in My Vital Mind App. These are shared only with existing users for Existing Services. Processing of Your Non-Personal data such as Nickname, Timezone, App usage to send such notifications is based on Our Legitimate Interest and to provide You with Service discounts and improve Your experience of My Vital Mind App. If You choose to participate in a My Vital Mind promotional event on social media or elsewhere outside of the My Vital Mind App, You may be asked to opt-in to complete a survey questionnaire. Your voluntary submissions including Your personal data such as email address will be processed only for the following purposes - to send You additional data about the programme, to enrol or on-board You to the programme and to correspond with You on programme related matters. Your survey submission will never be linked to Your My Vital Mind app account and hence Your My Vital Mind App conversations and activities will never identify You. Your submissions will reside in a secure and private storage area operated within our account and managed by Google Forms. You can opt out at any time from the programmes by sending Us an email request from Your Google or Apple email ID to myvitalmind3@gmail.com to delete Your personal data or to discontinue receiving any further communication on this matter. On receipt of Your email, We will verify and remove only the specific Personal data as requested by You, on receiving the request. YOUR SUBMISSIONS WILL NEVER BE SHARED WITH A THIRD PARTY.
l. How do We handle Your Payment data when You subscribe to Our Services? If You choose to purchase or Use a fee-based Service and pay for such Service by means of in-app purchases via iTunes or Google Play, We do not collect, retain and store Your personal, financial and credit/debit card data. This is because Your card settlements including card and personal details will be handled by appropriate third-party payment agencies. We do not not collect any personal data from the play stores postpurchase. Only the payment confirmation and subscription details get collected from the play store and processed (collect, transmit and store) by Us. Processing of this data is for Our Legitimate Interest to support You for any payment or subscription related requests, issues or clarifications.
m. What do We process when You follow Us on Instagram You have the option to follow Us in Instagram Using Your Instagram account. You can set up an Instagram account, if You do not own one and follow Us at @myvitalmindapp. WE DO NOT ASSOCIATE YOUR INSTAGRAM ACCOUNT WITH YOUR My Vital Mind APP ACCOUNT.
n. What data do We process for the purposes of Our Legitimate Interest? We Use Legitimate Interest basis to process Your data in a way which might reasonably be expected as part of running Our business and which does not materially impact Your rights, freedom or interest. When providing Our Services, We may process Your data based on Our Legitimate Interest for the following purposes. o To create a pseudonymized random user identifier from Apple App Store or Android Play store identifier; o To monitor, detect and deter unauthorized or fraudulent Use of or abuse of the Service; o For Uses and disclosures required by law; o For disclosures for judicial and administrative proceedings; o For disclosures for law enforcement purposes; o For Uses and disclosures for public health reporting purposes; o For Uses and disclosures to avert a serious threat to health or safety to You, Us, or others; o For improving and/or optimizing Our Service quality, safety and performance; o To enable Us to troubleshoot and provide customer support, and to respond effectively to Your inquiries and claims; o For purposes of research and statistical analysis; o For sending limited in-app and push notifications such as service information, service reminders and service promotions; o For purposes of servicing You towards My Vital Mind Gift Card program; o To allow migration of Your My Vital Mind app data when You change Your mobile device; o To accurately and positively identify Your Personal data at Your request when exercising Your data protection rights;
Changes to this Privacy Policy We may modify Our Privacy Policy from time to time for various reasons including to improve Our privacy practices, to ensure Our Users Right to be Informed, to reflect changes to Our Service, and to comply with relevant laws. If and when this policy is changed, We will post the new notice on our Website and My Vital Mind App and notify You through an in-app notification automatically or as otherwise required by relevant law. It is Your responsibility to check Our Website and My Vital Mind App periodically for updates or changes to Our policy. We encourage You to review changes carefully. If You agree to the changes, then please continue to Use Our Service. If You, however, do not agree to any of the changes and You no longer wish to Use Our Service, You may choose to unsubscribe Service or uninstall Our App. Continuing to Use Our Service after a notice of change has been communicated to You or published on Our Service constitutes Your acceptance of changes and consent to the modified Privacy Policy.
Severability and Exclusion We have taken every effort to ensure that this Privacy Policy adheres with the applicable laws, including Data Protection Laws. The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. This Privacy Policy does not apply to any data other than the data collected by Us while providing the Services.