Mindset Technologies Ltd (Mindstep)
Mobile Application Privacy Policy

Mindset Technologies Ltd, trading as “Mindstep”, is on a mission to create a one-stop brain care platform, via the Mindstep App mobile application software (the “App”). Mindstep is committed to respecting your privacy and protecting your personal data.

Introduction

This policy (together with our end-user licence agreement (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Mindset Technologies Ltd trading as “Mindstep” is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Mindset Technologies Ltd
Name of DPO: Aaron Lin 
Email address: compliance@letsmindstep.com
Postal address: 5 Chancery Lane, WC2A 1LG

If you have any concerns about our use of your personal information you can raise your concerns to us directly using the contact details above.

You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated in September 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you via push notifications. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. 

Third party links

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

The data we collect about you depends on how you choose to engage with the App. We designed the App as follows to provide you with a choice whether to continue your user journey by signing up to the care platform:

Part 1 – the screening mechanism. This section of the App provides a screening mechanism whereby your data will be processed by using clinically validated cognitive screening tools, questionnaires and algorithms to assess you for signs of cognitive impairment and/or risk factors for cognitive impairment. We do not make a diagnosis; we simply show where you score relative to the expected level for your age group.

Part 2 - the care platform. If you decide to continue your user journey with the App you can choose to sign up to the care platform available on the App. 

The App provides a personalised care approach directly to the general adult population to reduce risk factors for cognitive decline and mental health disorders. To do this, the App provides you with information, advice, and a personalised action plan to support your mental and physical health and to lower your risk of cognitive impairment based on the information you provide to us via the screening mechanism within the App and your interaction with the care platform available on the App.

If you interact with the screening mechanism in Part 1 of the App we may collect, use, store and transfer different kinds of personal data about you such as: Identity Data; Device data; Content data; Health data; Usage data;

If you interact with the care platform in Part 2 we may collect, use, store and transfer different kinds of personal data about you such as: Identity Data; Device data; Content data; Health data; Usage data; transaction data, profile data; marketing and communications Data; Contact data; 

We explain these categories of data here.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may come from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may process special category data about you whilst using the App. Special category data means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

Automated decision making or profiling 

The App provides a screening mechanism whereby the data will be processed by automated algorithms in the App. The algorithm does not make a diagnosis, we simply show where you score relative to the expected level for your age group. 

How is your personal data collected

We collect the following data about you:

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our website and also allows us to improve the App and website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data in accordance with data protection laws

We will use your personal data for the following purposes: 

Providing your personal data to others 

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in this policy. 

International transfers

Many of our external third parties are based inside the UK. Some of our external third parties are based outside of the UK and so their processing of your personal data will involve a transfer of data outside the UK. 

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers. In App purchase transactions carried out by Apple will be encrypted. 

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. 

We do not provide hardware for users, and therefore you must download the App software onto your personal device. Once downloaded, the App is stored locally on your device. Users require network connectivity for the App to function properly and for data to be collected and accessible by us. Where you do not have network connectivity, data will continue to be collected through the App, but will not be received or accessible by us, as it will be stored entirely locally.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We will retain your Personal Data only for the period necessary to fulfil the purposes outlined in this Policy.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 

Please click on the links below to find out more about these rights: 

You also have the right to ask us not to continue to process your personal data for marketing purposes. 

You can exercise any of these applicable rights at any time by contacting us at compliance@letsmindstep.com.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties 

External third parties such as service providers who support our services. Other third parties may have access to your aggregated data, but will be unable to use the data to identify you. 

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances

As already detailed above within this Policy, under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

You can exercise any of these rights as applicable at any time by contacting us at compliance@letsmindstep.com.

Description of categories of personal data

Identity Data: such as first name, last name, username or similar identifier, date of birth, gender.

Contact Data: such as email address.

Transaction Data: may include details about payments to and from you and details of in-App purchases.

Health Data: Special category data means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

Device Data:  a security token; a unique device identifier; identifier for vendor. 

Content Data: includes information stored on your Device.

Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.

Usage Data: includes details of your use of any of our Apps or your visits to any of our App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.