MindLi AI Inc. (“MindLi”, the “Company”, “we”, “our” or “us”) respects the privacy of the users (“User(s)” or “you”) of our website at www.mindli.com (and its subdomains (collectively, the “Site”), the “MindLi” mobile and web applications (collectively, the “App”), and other Services. This Privacy Policy (“Privacy Policy”) details how your Personal Information collected via the Site, the App and/or the Services is used and processed by MindLi. Capitalized terms which are not defined herein shall have the meaning ascribed to them in our Terms of Use, into which this Privacy Policy is incorporated by reference (the “Terms”).

In this Privacy Policy, references to “MindLi”, or to “we”, “our”, or “us”, are to MindLi AI Inc., a company incorporated in the United States, with its principal office at Cambridge, MA 02138, US. MindLi AI Inc. is the controller/owner of the database with respect to the personal information detailed herein. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at: support@mindli.com.

1. Important Notes and your acknowledgment of this policy

BY ENTERING, CONNECTING TO, ACCESSING, OR USING THE SITE, SERVICES, OR APP, OR OTHERWISE PROVIDING US WITH YOUR PERSONAL INFORMATION, YOU ACKNOWLEDGE THAT YOU HAVE HAD THE OPPORTUNITY TO REVIEW THIS PRIVACY POLICY AND AGREE TO THE TERMS SET FORTH HEREIN. WHERE REQUIRED BY LAW, INCLUDING FOR OUR USERS IN ISRAEL, YOU ALSO CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN, AND YOU ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT LEGALLY OBLIGATED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US. THE LEGAL BASES FOR COLLECTING PERSONAL INFORMATION FROM USERS IN THE EU OR THE UK ARE FURTHER DETAILED BELOW. IF YOU DISAGREE WITH ANY TERM OF THIS PRIVACY POLICY, YOU MAY NOT ACCESS, USE, OR ENTER THE SITE, APP, OR SERVICES, AND WE ASK THAT YOU REFRAIN FROM PROVIDING US WITH YOUR PERSONAL
INFORMATION.

NOTE TO USERS IN JURISDICTIONS WHERE THE PROCESSING OF THEIR PERSONAL INFORMATION IS BASED ON CONSENT: IF YOU DECLINE TO PROVIDE YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY, OR FAIL TO PROVIDE INFORMATION SPECIFICALLY DESIGNATED AS MANDATORY OR REQUIRED TO PROVIDE THE SITE, APP OR SERVICES, YOU MAY NOT BE ABLE TO ACCESS, USE, OR BENEFIT FROM THE SITE, APP, SERVICES, OR THEIR FEATURES. IN ADDITION, WE MAY BE UNABLE TO CONTACT YOU, PROVIDE PERSONALIZED OFFERS AND RECOMMENDATIONS, PROCESS TRANSACTIONS OR PROVIDE SUBSCRIPTIONS TO OUR APP AND SERVICES, DELIVER CUSTOMER SUPPORT AND ASSISTANCE, SEND IMPORTANT SERVICE-RELATED COMMUNICATIONS AND UPDATES, OR OTHERWISE COMMUNICATE WITH YOU FOR BUSINESS, PROMOTIONAL, OR SERVICE-RELATED PURPOSES ESSENTIAL TO OUR RELATIONSHIP AND THE DELIVERY OF OUR APP AND SERVICES.

COMMUNICATIONS: YOU ACKNOWLEDGE THAT WE MAY SEND YOU SERVICE- RELATED COMMUNICATIONS, MESSAGES AND/OR NOTIFICATIONS FROM US (INCLUDING EMAILS AND TEXTS (INCLUDING WHATSAPP AND SMS)), VIA THE CONTACT INFORMATION YOU HAVE PROVIDED, INCLUDING MESSAGES RELATED TO THE APP AND SERVICES (SUCH AS PAYMENT CONFIRMATION AND GENERAL UPDATES), WHERE NECESSARY FOR THE PERFORMANCE OF OUR CONTRACT WITH YOU OR FOR OUR LEGITIMATE INTERESTS, SUBJECT TO APPLICABLE LAW.

MARKETING COMMUNICATIONS: SUBJECT TO APPLICABLE LAW, WE HEREBY INFORM YOU THAT BY PROVIDING US WITH YOUR CONTACT DETAILS, YOU CONSENT TO RECEIVE COMMERCIAL AND MARKETING MATERIALS FROM THE COMPANY REGARDING OUR PRODUCTS AND SERVICES, AS WELL AS FROM OUR THIRD-PARTY BUSINESS PARTNERS. WHERE PERMITTED BY APPLICABLE LAW, WE MAY SEND YOU SUCH MATERIALS ON AN OPT-OUT BASIS, IN WHICH CASE YOU MAY OBJECT IN ADVANCE BY NOTIFYING US, OR OPT OUT AT ANY TIME BY FOLLOWING THE UNSUBSCRIBE INSTRUCTIONS INCLUDED IN EACH MESSAGE OR BY EMAILING US AT SUPPORT@MINDLI.COM. WHERE APPLICABLE LAW REQUIRES YOUR PRIOR CONSENT, WE WILL SEEK SUCH CONSENT SEPARATELY BEFORE SENDING YOU MARKETING MATERIALS, AND YOU MAY WITHDRAW YOUR CONSENT AT ANY TIME USING THE SAME METHODS DESCRIBED ABOVE. CONTENT: WHEN USING THE APP TO CREATE YOUR ENVIRONMENT AND CONTENT, YOU MAY UPLOAD USER CONTENT (AS DESCRIBED IN THE TERMS).

BY INSTALLING THE APP AND/OR USING THE SERVICES, YOU ACKNOWLEDGE THAT MINDLI MAY ACCESS, PROCESS, COLLECT, AND STORE SUCH USER DATA FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY, INCLUDING TO OPERATE AND IMPROVE THE SERVICES, PROVIDE USERS WITH EFFECTIVE INFORMATION, AND, WHERE APPLICABLE, SUPPORT THE OPERATION OF ARTIFICIAL INTELLIGENCE TOOLS. MINDLI IS NOT RESPONSIBLE FOR MAINTAINING USER DATA OR GUARANTEEING ITS RESTORATION, SO YOU SHOULD KEEP BACKUP COPIES. THE APP MAY ALSO ALLOW YOU TO EXPORT DATA, INCLUDING PERSONAL INFORMATION, TO THIRD PARTIES AT YOUR OWN DISCRETION AND RISK. YOU SHOULD TAKE ALL NECESSARY PRECAUTIONS WHEN EXPORTING DATA. WE ARE NOT RESPONSIBLE FOR ANY THIRD PARTY’S USE OF DATA OR RECORDS YOU PROVIDE, AND IF YOU USE A THIRD-PARTY APPLICATION TO SEND DATA, YOU SHOULD REVIEW THAT APPLICATION’S PRIVACY POLICY.

2. Information we may collect from our Users

We may collect two types of data and information from our Users:

(a) Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”). We are not aware of the identity of the User from whom we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information that does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the App and/or the Site and/or the Services. You may access and browse certain parts of the App and/or the Site without disclosing personal information, although, like most websites and online services, we passively collect certain Non-Personal Information from your devices when you access and browse our App and/or the Site and/or the Services, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the App and/or the Site, the activities of the User on the App and/or the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We also use third-party service providers such as Google Analytics to obtain detailed analytics on the User’s behavior on the App and/or the Site.

(b) Personal Information. The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature. Personal Information which is provided voluntarily:

• Communications: Personal Information is collected from the details that Users may provide as part of any communications with MindLi, by any means, including by e-mail, telephone or otherwise. Such Personal Information may include your name, contact details and any other information which you may voluntarily provide to us.
• Registration to the Services: Users may Register to the Services by providing us with certain personal information such as full name and email address, or by using their existing third-party social network account such as Google or Facebook (“Social Network Account“), by using its single sign-on mechanism. Upon Registration through the User’s existing Social Network Account, the applicable social network provides us with access to certain information about such User as stored in his/her Social Network Account, namely, any information which is detailed and displayed to the User in the notice which appears during the integration process with the Social Network Account, including the User’s full name, email address and profile picture. Please read such notice carefully in order to understand what information is available to MindLi via the Social Network Account. MindLi may store the above-mentioned information (or any part of it), in order to achieve the purposes set forth herein. Please remember that the manner in which the Social Network Account uses, stores, and discloses your information is governed solely by its policies, and MindLi shall have no liability or responsibility for the privacy practices or other actions of the applicable social network. You hereby agree that such information will be stored even after the linkage to your Social Network Account expires, for any reason. Important note: Users’ names and nicknames may be made publicly available via the App, including to other Users. Please act with caution when selecting your nickname.
• MindLi Paid Subscription: Personal Information is collected from the details the Users provide in the App Registration form and/or other Services’ purchase process, including full name, phone number, email address and other relevant information. Please note that certain information may be provided for the purpose of producing invoices.
• Mailing list: You may voluntarily provide us with your contact details in order to subscribe to our newsletter and to receive commercial materials from MindLi and our partners.
• User Content: Personal Information includes any data and/or content, including User Generated Content, that you may upload or generate through use of the App and/or the Services, including without limitation comments, Boxes and Sparks (as defined under the Terms of Use), photos that Users may upload to the App, subject of interest and items collected in each subject, information derived from your interactions with other Users, etc. Users bear sole responsibility for such User Content and for any consequences of the use of such content by MindLi and by third parties.
• Contact Us: when using our “Contact Us” form available via the App and/or the Site, we may collect certain information, such as your full name and email
  address. You may also provide information to us in a free text message which includes personal information.
• Payments: payments for our Services use certain Online Payment Processors, including application marketplaces such as Google Play and Apple’s App Store, which will require you to fill out a billing form wherein you will be required to provide such Online Payment Processors with certain Personal Information (such as a credit card number and other related billing information). We will not store such information on our servers. Where necessary, we only keep token information that such Online Payment Processors provide us with, and we will keep such information strictly secured.
• Usage Data: We may collect certain information in connection with your use of the App and/or the Site and/or the Services, including information about your activity, interactions with features and functionalities, content viewed, pages or screens visited, searches, clicks, session activity, preferences, purchases made, subscription-related activity, transaction history, and other actions taken within the App and/or the Site and/or the Services, and such information may be available to the User via the App and/or the Site. Personal Information is also collected via technology:
• IP/MAC Address: Users of the App and/or the Site may automatically provide their IP address (or MAC address, as applicable) and/or advertiser identifier (when available on a device) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.
• Geolocation data: while using the Site and/or the App, we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes.
• Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 2(a) is linked to or associated with a specific individual, then such information will be considered as Personal Information.
• Identifiers: we process certain online identifiers, such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or other unique identifiers, for geolocation, targeted advertising and security purposes. In addition, when using the Site and/or the App, our authorized third-party service providers may collect your advertising identifiers, as further detailed below.
• Emails: we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
  
  

Personal Information that we may generate about you:

• When you are using the App and/or the Services, certain User Content (as defined under the Terms) may be processed using artificial intelligence in order to provide you with Insights (as defined under the Terms). Thus, the processing of information by us as part of the provision of the Services may generate personal information about you, including inferred information and AI-generated outputs associated with your use of the relevant feature. Where such processing constitutes profiling or other automated processing under applicable law, it is used only to support the relevant feature and is not used by MindLi to make solely automated decisions that produce legal effects concerning you or similarly significantly affect you.

Please note:

(1) We use third-party tracking services and usage logs to track and analyze data from Users of the Site and/or the App for purposes of security and fraud prevention. We may also use cookies to gather information regarding your use of the Site and/or the App and the information for which you searched and accessed.

(2) We may cross-reference Personal Information with other Personal Information we have about you, and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.

(3) If the Personal Information you provide to us includes information about others, you are fully and solely responsible for providing all necessary information notices to affected data subjects and obtaining any required consent under applicable privacy laws from data subjects for the use, processing, sub-processing and storing of their information in accordance with this Privacy Policy.

3. How Do We Collect Information on our Users?

There are a few methods that we use:
(a) We collect information through your entry and use of the Site and/or the App and/or the Services. In other words, when you are using the App and/or the Site and/or the Services, we are aware of it and may gather, collect, and store the information relating to such usage. For example, when you use the App and/or the Site and/or the Services, we gather your Technical and Behavioral Information.

(b) We collect information which you decide to provide us voluntarily. For
example, we collect Personal Information when you register for a user account and when you contact us via our e-mail address. We may gather, collect and store such
information either independently or through the help of our authorized third-party service providers, as detailed below.

4. What are the Purposes of the Collection of Information?

(a) Non-personal Information is collected and processed by us in order to:

• For the purpose of research and statistical analysis intended for our internal use, among other things, so that we can make informed strategic decisions while having a better understanding of our target audiences.
• For information security needs and in order to secure our App and/or the Site and/or the Services;
• To understand how our App and/or the Site and/or the Services are used and to adapt, develop and improve our services and products;
• To provide you with content recommendations, inter alia, based on your use of the Services;
• To partner with advertising networks and advertising intermediaries to display advertising on your devices about the App and/or the Site and/or the Services and to help us and our partners make better decisions, based on your interests, about the ads shown to you;
• To adapt the App and/or the Site and/or the Services to your needs and to improve your user experience when you use the App/Site and Services; and
• Keep the Site and/or the App safe and secure and for the prevention of fraud.
  
  

(b) Personal Information is collected and processed by us in order to:

• Enable the provision, operation, administration, maintenance and improvement of our App and/or the Site and/or the Services, including to provide support services, enable registration, create and manage user accounts, provide account access and functionality, and operate, process and administer transactions, purchases, subscriptions and payments, where relevant.
• Communicate with you, including to provide customer service, support and technical assistance, respond to your inquiries, requests, comments, complaints and suggestions, requests for information, and send you service-related notices and updates regarding the App and/or the Site and/or the Services, including changes to this Privacy Policy or the Terms.
• Provide you with Insights (as defined under the Terms).
• Monitor, personalize, develop, maintain and improve the App and/or the Site and/or the Services, and the content, features, recommendations and offers made available through them, including by analyzing your preferences, interests and usage patterns, and to ensure that such content is presented in an optimal way for you and for your device (e.g., tablet, mobile phone).
• Send you, subject to applicable law, advertisements, marketing and promotional content, newsletters, updates regarding the Company and its activities, new offers, benefits, promotions, and updates regarding the App and/or the Site and/or the Services, by mail, telephone, WhatsApp, email, SMS, push notifications, in-App messages, web-browser notifications or other online means, and to maintain records of your marketing preferences and opt-out requests. You may opt out of such communications at any time in accordance with the instructions provided in the relevant communication or as otherwise described in this Privacy Policy.
• Create, manage, run, measure and optimize relevant, targeted and personalized advertising and marketing campaigns relating to the App and/or the Site and/or the Services, our products and our brand, including, subject to applicable law and, where required, your consent, by using limited Personal Information such as online identifiers, device identifiers, advertising identifiers, cookie-related data, hashed contact details and related usage data. Note that we may share such limited Personal Information with advertising platforms, advertising networks, intermediaries, and measurement or analytics providers for these purposes and receive reports and metrics regarding your interaction with our advertisements, including impressions, clicks, conversions and similar performance data to perform audience measurement, attribution, statistical analysis and campaign optimization.
• Conduct internal operations, including research, analytics and statistical analysis for our business purposes, and, where appropriate, aggregate, de-identify and/or anonymize Personal Information so that it can no longer reasonably be used to identify you, directly or indirectly, and use such information for lawful business purposes.
• Email tracking – we may use tracking technology within the email we may send to you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
• Keep the App and/or the Site safe and secure, verify your identity where necessary when you log in to your account, prevent unauthorized access, detect, investigate and prevent fraud, misuse, crime or other prohibited activity, and protect the integrity, availability and security of our data, systems, infrastructure and Services.
• Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve our services.
• Store, host, organize, manage and maintain Personal Information in our databases, systems and records for the purposes described in this Privacy Policy, and for general administrative, operational, recordkeeping and business continuity purposes.
  
  

Note to our Users in the EU and UK:

In order for MindLi to process your Personal Information, as detailed herein, such processing must be justified by a lawful basis for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:

• The processing is based on your consent – where you provide us with your consent to process your Personal Information for one or more specific purposes. For instance, where required under applicable law, we rely on this basis to send electronic marketing communications, newsletters, promotions and similar messages; to create, manage, measure and optimize targeted or personalized advertising and marketing campaigns; to use email tracking and similar non-essential technologies in communications; to enable certain optional AI-driven features; and to process special categories of personal data contained in User Content. If you choose not to provide your consent for such processing activities, or if you decide later on to revoke your consent, this may affect our ability to provide you with MindLi’s relevant feature or MindLi’s marketing materials;
• The processing is necessary for the performance of a contract to which you are a party – generally your Personal Information will be provided to us because you are interested in using the Site, App and/or Services in accordance with the Terms or in order to receive certain services from MindLi. As such, we rely on this basis for (a) processing activities that are required in order to provide, operate and administer the App, Site and Services; (b) enable registration and create and manage user accounts; provide account access and functionality; (c) process transactions, purchases, subscriptions and payments; (d) communicate with you for customer service, support and technical assistance; (e) respond to your inquiries, requests, complaints and information requests; (f) send service- related notices and updates, including changes to this Privacy Policy or the Terms; (g) provide Insights and other requested service functionality; and, (h) where necessary to deliver the requested service, present content and functionality in an optimal way for you and your device.
• The processing is necessary to comply with a legal obligation – we may process your Personal Information to comply with legal, regulatory, tax, accounting, reporting and disclosure obligations, including disclosing information to authorities, maintaining required records, retaining or storing information where required by applicable law, and maintaining records of marketing preferences and opt-out requests where required by applicable law;

  and

• The processing is necessary for the purposes of our legitimate interests, subject to your interests and fundamental rights. Processing of Personal Information will take place pursuant to our legitimate interests in offering our Users comfortable, effective and safe access to our App, Site and Services. This includes personalizing, monitoring, developing, maintaining and improving the App, Site and Services and related content, features, recommendations and offers, including based on preferences, interests and usage patterns; managing customer relationships and retention, improving the service experience, and offering tailored services, features, recommendations and support; conducting internal operations, troubleshooting, testing, research, analytics and statistical analysis; aggregating, de-identifying or anonymizing Personal Information for lawful business purposes; storing, hosting, organizing, managing and maintaining Personal Information in our databases, systems and records for administrative, operational, recordkeeping and business continuity purposes; keeping the App, Site and Services safe and secure; verifying identity where necessary; preventing unauthorized access; detecting, investigating and preventing fraud, misuse, crime and other prohibited activity; and protecting our rights, legitimate interests, data, systems, infrastructure and Services. Where we rely on legitimate interests as a lawful basis, we carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.

Note to non-EU, non-UK Users: BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR THE APP AND/OR SERVICES, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.

5. Sharing Information with Third Parties

MindLi respects its Users’ privacy and will not disclose, share, rent, or sell their Personal Information to any third party, other than as permitted under this Privacy Policy. Notwithstanding, the Company may share Personal Information in the following cases:

• MindLi’s Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of MindLi for the sole purpose of enabling the provision of our Services and to contact you. Please note that all of MindLi’s personnel who will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
• Service Providers: Please note that we collect, hold and/or manage Personal Information through MindLi’s authorized third-party vendors of certain products or services (such as cloud services) (including, as applicable, their affiliates) solely for, and limited to, providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction. Where such service providers include AI service providers, they may process limited Personal Information and User Content solely on MindLi’s behalf, under MindLi’s instructions, and only as necessary to provide the requested functionality described in this Privacy Policy. Any third-party service provider with whom we share Personal Information for processing on our behalf is required, under applicable contractual obligations, to provide a level of protection for such information as required under applicable law.
• In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User support requests; (e) to respond to claims that any content available on the Site and/or the App violates the rights of third parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of the Company, its Users, or the general public; (h) when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; and/or (i) pursuant to your explicit approval prior to the disclosure. For the avoidance of doubt, MindLi may use Non-personal Information and transfer and disclose it to third parties at its discretion, including without limitation for statistical, analytical and research purposes and for customization, development, and improvement of the App and/or the Site and/or the Services.
  
  

6. Artificial Intelligence

To power certain features of the App and Services, including our intelligent “Create” features, preset prompts, note-taking and summarization features, MindLi integrates with one or more third-party Artificial Intelligence (AI) service providers, such as OpenAI, L.L.C., Anthropic, PBC and Google LLC. MindLi may also offer optional integrations that allow a User to connect the User's MindLi account with a third-party LLM account independently maintained by the User.

When you interact with AI-driven features in MindLi, or if you choose to connect MindLi with your own third-party LLM account, User Content (such as text, prompts, and notes), and other Personal Information necessary to operate the relevant AI-driven feature or integration may be transmitted to the applicable third-party AI or LLM providers, solely for the limited purpose of providing that feature to you within the App. Such data will not be transferred to third-party AI providers for their own independent use or for any purpose unrelated to providing the requested functionality. Where an AI-driven feature is not essential to the core functionality of the App, and consent is required under applicable law, we will request your explicit consent before your data is first shared with the applicable AI provider, and you may withdraw that consent at any time through the settings made available in the App or by contacting us, which will disable the feature going forward. Certain AI-driven features may be integral to the App's core functionality and cannot be individually disabled. Data shared with an AI provider is retained only for as long as necessary to deliver the relevant feature and is subject to our contractual arrangements with that provider and, where applicable, the provider’s retention and deletion practices. We do not instruct any AI provider to retain your data beyond what is needed to provide the feature. We require each AI provider to process your data only for our authorized purposes, apply appropriate technical and organizational security measures, and delete or return the data in accordance with our contractual arrangements and applicable legal requirements. We do not permit third-party AI providers to use your Personal Information, User Content, or other user data to train, retrain, or otherwise improve generalized or shared artificial intelligence or machine learning models.

Google User Data Compliance: To the extent AI-driven features involve data obtained through Google APIs or Google Sign-In (“Google User Data”), MindLi’s use and transfer of Google User Data will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Such data is used only for the limited and permitted purposes necessary to provide or improve the requested feature, and is not used for advertising, independent analytics, or model training, and is not sold or transferred to data brokers or other third parties.

7. Data Subjects’ Rights

The Company hereby informs you that you have the right (subject to certain conditions) under applicable law to access Personal Information we collect and process about you, and in certain cases to request its amendment or deletion. You may update your Personal Information independently via the App. However, if you find that you are unable to do so or if you wish to access, correct, amend, or delete Personal Information, please send us an email to: support@mindli.com, and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.

Note to our Users in the EU and UK:

You may have the following rights (by virtue of EU and UK law) in respect of your Personal Information:

• Right to access: you may have the right to request access to your Personal
  Information that is held by MindLi.
• Right to rectification: if the Personal Information processed by MindLi is incorrect or incomplete, you may have the right to have your Personal Information rectified.
• Right to erasure: under certain conditions, you may be entitled to require that MindLi delete your Personal Information (e.g. if the continued processing of that data is not justified).
• Right to portability: you may have the right to (i) receive the Personal Information concerning you, or (ii) transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity). The right to data portability only applies where your Personal Information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
• Right to object to or withdraw consent: where the lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. Where you object to processing based on our legitimate interests, we shall no longer process your Personal Information unless (i) we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or (ii) for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
• The right to restrict processing – under certain circumstances, you may have the right to obtain the restriction of the processing of your Personal Information.
• Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction. Contact details of the various EU supervisory authorities can be found at https://edpb.europa.eu/about-edpb/about edpb/members_en#member-fr. The Information Commissioner’s Office is the UK’s supervisory authority and can be contacted at https://ico.org.uk/global/contact-us/.

   

We may refuse to comply with your request if it is manifestly unfounded, excessive or repetitive in nature. To exercise these rights, where applicable, please contact us by sending an email to: support@mindli.com.

8. International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third-party service providers (as provided herein), across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. We make efforts to ensure that your data is processed solely in the EU, the US, and Israel, but in any event, any transfer of data will be carried out in accordance with the safeguards permitted under applicable privacy laws, including, where applicable, the safeguards described below and the requirements applicable to transfers of data outside Israel, in order to ensure that your data is protected at all times.

Note to our Users in the EU and UK:
If you are located in the EU or UK, you have a right to further information regarding the appropriate safeguards used by us when transferring your Personal Information outside of the EU or UK (as applicable), including a copy of the relevant safeguards where applicable. In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EU or UK, which may include the following: transferring your Personal Information to countries approved by the European Commission or UK government (as applicable) as having adequate data protection laws, such as Israel; transferring your Personal Information to entities certified under the EU-U.S. Data Privacy Framework and, where applicable, the UK Extension to the EU-U.S. Data Privacy Framework; and entering into standard contracts that have been approved by the European Commission and UK government (as applicable) and which provide an adequate level of protection for your Personal Information in the recipient country.

Note to all other Users:
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE APP AND/OR THE SITE, YOU ACKNOWLEDGE THAT YOUR PERSONAL INFORMATION MAY BE TRANSFERRED, STORED AND/OR PROCESSED AS DESCRIBED HEREIN.

9. Minors

The App and/or the Site and/or the Services are intended for Users over the age of sixteen (16). Therefore, MindLi does not intend to, and does not knowingly, collect Personal Information from children under this age. We reserve the right to request proof of age at any stage so that we can verify that minors under this age are not using the App and/or the Site and/or the Services. If we learn that we collected Personal Information from minors under the age of sixteen (16), we will delete that information as quickly as possible. Please contact MindLi at support@mindli.com if you have reason to suspect that MindLi collected Personal Information from minors under the age of sixteen (16), and we will delete that information as quickly as possible.

10. Security

We take reasonable measures to maintain the security and integrity of our App and/or the Site and/or the Services and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Your Personal Information is hosted on third parties’ servers, which provide advanced strict security standards (both physical and logical). Please note, however, that there are inherent risks in the transmission of information over the Internet or other methods of electronic storage, and we cannot guarantee that unauthorized access or use will never occur. No method of transmission over the Internet, or method of electronic storage, is completely secure.

11. Cookies and Tracking Technologies

When you access or use our Site and/or App, we and our authorized third-party service providers may employ industry-standard technologies, including cookies, web beacons, pixels, clear GIFs, local storage objects, and other similar tracking technologies (collectively, “Tracking Technologies“). These technologies store certain information locally on your device and may enable us to recognize your device and distinguish it from those of other users, provide targeted and behavior-based advertising (as further described below), remember your preferences and settings to provide a personalized experience, enhance the performance, functionality, and user experience of our Site and/or App, deliver customized content and services based on your individual interests, device type, and browser specifications, and facilitate essential functions such as authentication and security.

Cookies are small text files that are placed on your device when you visit our Site and/or App. They contain information that can be read by our servers when you return to our services, allowing us to recognize your device and remember your preferences across sessions.

Pixels and Web Beacons are tiny, transparent graphic images, typically measuring 1×1 pixel, that are embedded in web pages, emails, or advertisements. These tracking pixels operate by loading from our servers or third-party servers when you view content, thereby registering your interaction and collecting information about your device, browser, and behavior. Unlike cookies, pixels do not store information directly on your device but instead transmit data back to the server that hosts them. We may use pixels to track email opens, measure advertising effectiveness, count unique visitors, monitor conversion rates, and gather analytics about how users interact with our content across different platforms and devices.

Local Storage Objects include HTML5 local storage, session storage, and other browser-based storage mechanisms that can store larger amounts of data than traditional cookies and may persist even after cookies are deleted.

The Tracking Technologies deployed on our Site and/or App may collect and store both personal and non-personal information. Non-personal information includes pages visited, time spent on the Site and/or App, and customization choices. All such information is collected and processed in accordance with the terms and conditions specified in this Privacy Policy. We also collect user persistent identifiers, which are unique identifiers that allow us to recognize returning visitors across sessions, and preference data including language settings, display preferences, and other customization choices. All such information is collected and processed in accordance with the terms and conditions specified in this Privacy Policy.

We utilize two primary categories of cookies and similar technologies. Session cookies expire automatically when you close your web browser and are used primarily for essential site functionality and temporary data storage during your browsing session. Persistent cookies remain stored on your device until manually deleted or until their predetermined expiration date, enabling us to remember your preferences and recognize you as a returning user across multiple visits.

The Company and our authorized third-party service providers may access information collected through these Tracking Technologies. We work only with reputable service providers who are contractually obligated to handle your information in accordance with applicable privacy laws and our privacy standards. These third parties may also deploy their own tracking pixels and similar technologies to collect data for analytics, advertising, and performance measurement purposes.

Your Control and Management Options

Most modern web browsers and devices provide you with comprehensive control over Tracking Technologies through built-in privacy settings. You may configure your browser to reject all or certain types of cookies, set your browser to alert you before cookies or other tracking technologies are deployed on your device, remove previously stored cookies and local storage data at any time, and customize settings for different websites and technology categories.

Important Notice: If you choose to block, restrict, or delete Tracking Technologies, please be aware that certain features and functionality of our Site and/or App may be limited or unavailable. Essential functions, personalization features, and your saved preferences may not work properly. Additionally, blocking pixels and web beacons may prevent us from measuring performance and delivering optimized user experiences.

Default Behavior: Unless you actively modify your browser settings to block these technologies, our Site and/or App will continue to utilize Tracking Technologies in accordance with this policy during your use of our Site and/or App. For detailed step-by-step instructions on managing Tracking Technologies, please consult your browser’s help documentation. In Google Chrome, navigate to Settings, then Privacy and Security, then Cookies and other site data. For Microsoft Edge, go to Settings, then Cookies and site permissions, then Cookies and site data. Mozilla Firefox users should access Settings, then Privacy & Security, then Cookies and Site Data. Safari users can find these options under Preferences, then Privacy, then Manage Website Data. For comprehensive guidance across all major browsers, visit http://www.allaboutcookies.org/manage-cookies/ for detailed instructions and additional resources.

Analytics and Performance Tracking

We partner with reputable analytics service providers, including Google Analytics, to gain insights into user behavior and improve our services. These providers may place persistent cookies, deploy tracking pixels, and employ other tracking technologies to monitor and analyze user activity across our Site and/or App. The pixels used by these services typically track page views, user interactions, conversion events, and other behavioral metrics that help us understand how users engage with our content. You have the option to opt out of having your browsing activity within our Site and/or App recorded by performance and analytics cookies and pixels. Google provides a dedicated browser add-on that allows users to opt out of Google

Analytics tracking across all websites. You can download and install the Google Analytics Opt-out Browser Add-on from https://tools.google.com/dlpage/gaoptout. Please note that opting out may limit our ability to provide you with optimized performance and a personalized experience, as we will have reduced visibility into how our services are performing and what improvements might benefit users. Cross-Device and Cross-Platform Advertising: Our Tracking Technologies, including pixels and web beacons, may enable our advertising partners and us to recognize you across different devices and platforms when you are logged into your account or when devices are linked through other identifiers. This cross-device tracking allows us to provide a more seamless and personalized experience across all your devices, helps us better understand user behavior patterns, and enables more effective targeted advertising.

Opting Out of Targeted Advertising

You have the right to control how your information is used for targeted advertising purposes. We provide multiple methods for you to opt out of targeted advertising based on information collected through our Tracking Technologies. Please note that opting out of targeted advertising does not mean you will stop seeing advertisements entirely. Instead, the advertisements you see may be less personalized and relevant to your interests and may be based on general factors such as your geographic location, the content of the website you are visiting, or broad demographic categories rather than your specific browsing behavior and individual preferences.
Facebook and Instagram (Meta Platforms): You can control advertising preferences by visiting your Facebook Ad Preferences through your account settings, or by navigating directly to https://www.facebook.com/ads/preferences. Here you can view why you’re seeing specific ads, hide ad topics that don’t interest you, and adjust your ad settings. For Instagram, these settings are managed through the same Facebook Ad Preferences interface. You can also opt out of ads based on data from partners by adjusting your “Ads based on data from partners”; setting.
Google Advertising Services: Visit your Google Ad Settings at https://adssettings.google.com to control personalized advertising across Google services, including YouTube, Gmail, and Google Search. You can turn off ad personalization entirely or customize which categories of ads you see. Additionally, you can visit https://adssettings.google.com/anonymous to control ads when you are not signed into your Google account.
TikTok Advertising: You can manage how TikTok uses your information for advertising and adjust your ad personalization preferences through your TikTok account settings (for example, under Settings and privacy – Ads – Ad personalization, as available). You can also learn more about TikTok’s advertising choices and privacy practices in TikTok’s policies and help resources.
LinkedIn Advertising: Access your LinkedIn privacy settings through your account dashboard and navigate to the “Data privacy”; section to control how your data is used for advertising. You can adjust settings for ads both on and off LinkedIn, including whether LinkedIn can use your profile data for advertising purposes.
Digital Advertising Alliance (DAA): Visit http://optout.aboutads.info to opt out of interest-based advertising from participating advertising networks and companies. This tool allows you to see which companies have placed advertising cookies on your browser and opt out of future targeted advertising from these companies.
Network Advertising Initiative (NAI): Use the opt-out tool at http://optout.networkadvertising.org to control behavioral advertising from NAI member companies. This service provides a comprehensive list of participating advertising networks and allows you to opt out of multiple networks simultaneously. European Interactive Digital Advertising Alliance (EDAA): For users in Europe, visit http://www.youronlinechoices.eu to control online behavioral advertising from participating companies operating in European markets.

12. Third-Party Service Providers

While using the App and/or the Site and/or the Services, we use third-party service providers, who process the Personal Information detailed herein on our behalf, as follows:

– Hosting and cloud services;
– Infrastructure, backup and operation services;
– CRM Platforms;
– Third parties’ artificial intelligence-based services.
– Online advertising platforms and services;
– Mailing services; and
– Data analysis services.

Such third parties may be located in a country that does not have the same data protection laws as your jurisdiction.

13. Links to Third-Party Websites

Certain links provided in the Site and/or the App permit Users to leave our Site and/or the App and enter non-MindLi sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of MindLi, and it is not responsible for the availability of such external sites or services. It does not endorse and is not responsible or liable for any content, advertising, products, services or other information on or available from such linked sites and services or any link contained in a linked site or service.

MindLi reserves the right to terminate any link at any time. You further acknowledge and agree that MindLi shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resources. Most of such linked sites and services provide legal documents, including terms of use and privacy policies, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting. If you choose to connect your MindLi account with a third-party LLM account or other external service that you independently maintain, your use of that third-party service and its handling of your data within that third-party environment may also be subject to that third party’s own terms of use, privacy policy, and data handling practices. We encourage you to review those materials carefully before enabling any such integration.

MindLi is not responsible for the availability, content, or privacy practices of such third-party services, except to the extent they process Personal Information on MindLi’s behalf as described in this Privacy Policy.

14. Direct Marketing

To the extent permitted under applicable law and, where required, on the basis of your prior consent, we may use the contact details you provided us with (including, without limitation, your e-mail address and phone number) for the purpose of providing you with commercial and/or non-commercial materials related to our current and/or future activities and/or products. You may object to or opt out of such communications at any time by sending a written notice to our e-mail address support@mindli.com or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.

If you are an Israeli User, you may also request that your details be deleted from any direct mailing database used by us for such marketing communications, subject to applicable law. In addition, we may send push notifications to the User’s device after the User has agreed to accept push notifications from MindLi. Users can deactivate push notifications by changing their browser or device settings.

15. Data Retention

The Company will retain your Personal Information for as long as your Account to use the App is active and for a period of seven (7) years thereafter, for archiving purposes, to defend against potential legal claims and to comply with our legal obligations. Personal Information collected via the Site shall be retained for as long as it is necessary, relevant and accurate. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

16. Payments

We accept certain online payment methods, using our Online Payment Processors, which enable Users to render payments securely online using a credit card number or bank account. We may add or change the Online Payment Processors at our sole discretion. MindLi is not affiliated with such Online Payment Processors (for more information please see our Terms of Use), as each is an independent contractor; neither is an agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of Online Payment Processors is at the User’s discretion and sole liability and risk. It is the User’s responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

17. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Site, the App and any information collected therein and/or provided to us voluntarily. MindLi may, at its sole discretion, change this Privacy Policy from time to time, so please revisit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Site and/or the App and/or will send you an e-mail (to the extent that you provided us with such e-mail address) regarding such change. Such material changes will take effect seven (7) days after such notice was provided on the Site and/or the App or sent via e-mail, whichever is earlier, unless a shorter or longer period is required under applicable law. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised" date. Where required under applicable law, we will provide additional notice and/or obtain your consent in relation to such changes. In the event that this Privacy Policy should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law, and without any prior notice.

18. Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: support@mindli.com.