MindLi Ltd. (“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) (the “Site”), and the “MindLi” mobile application (the “App”). We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site and/or our App and our Services (as such term is defined in our Terms of Use). MindLi is committed to protecting the personal information that you share with us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at: Terms of Use, into which this Privacy Policy is incorporated by reference (the “Terms”).

1. Your acknowledgment of this policy

This Privacy Policy (“Privacy Policy”) details how your Personal Information collected via the Site and/or the App is used and processed by MindLi.

YOU HEREBY AGREE AND CONSENT TO RECEIVE 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 SERVICES (SUCH AS PAYMENT CONFIRMATIONS AND GENERAL UPDATES), AND COMMERCIAL MATERIALS, FROM THE COMPANY OR ITS THIRD-PARTY BUSINESS PARTNERS, SUBJECT TO APPLICABLE LAW.

WHILE USING THE APP IN ORDER TO CREATE YOUR OWN ENVIRONMENT AND YOUR OWN CONTENT VIA THE APP, YOU SHALL UPLOAD TO THE APP CERTAIN USER CONTENT (AS DETAILED UNDER THE TERM OF USE). AS SUCH, MINDLI HAS ACCESS AND/OR CONTROL OVER SUCH USER’S DATA, AND SHALL BE CONSIDERED AS PROCESSING, COLLECTING AND/OR STORING SUCH DATA ON ITS SERVERS OR OTHERWISE. BY INSTALLING THE APP AND/OR USING THE SERVICES, YOU AUTHORIZE MINDLI TO STORE SUCH USER DATA, FOR THE SOLE PURPOSE OF OPERATING THE SERVICES, INTER ALIA, FOR IMPROVING THE SERVICES TO ANALYZE SUCH DATA IN ORDER TO PROVIDE USERS WITH EFFECTIVE INFORMATION AND TO USE IT AS PART OF THE OPERATION OF ARTIFICIAL INTELLIGENCE TOOLS. HOWEVER, MINDLI WOULD NOT BE RESPONSIBLE FOR MAINTAIN ANY USER’S DATA AND CANNOT GUARANTY RESTORE USER’S DATA UPON YOUR REQUEST. HENCE, WE HIGHLY RECOMMEND YOU MAINTAINING BACKUP COPIES THEREOF.

PLEASE NOTE THAT THE APP MAY ALLOW YOU TO EXPORT CERTAIN DATA, INCLUDING PERSONAL INFORMATION, FROM THE APP AND TO SEND IT TO THIRD PARTIES. SUCH EXPORTING OF DATA IS AT YOUR OWN DISCRETION AND AT YOUR OWN RISK. PLEASE MAKE SURE THAT YOU TAKE ALL NECESSARY PRECAUTIONS WHEN EXPORTING DATA FROM THE APP. WE ARE NOT RESPONSIBLE FOR ANY THIRD PARTY’S USE OF ANY DATA AND RECORDS THAT YOU MAY PROVIDE TO SUCH THIRD PARTY. IF YOU USE A THIRD PARTY APPLICATION TO SEND DATA FROM THE APP TO THIRD PARTIES, THE COMPANY RECOMMENDS THAT YOU EXAMINE THE PRIVACY POLICIES OF EACH SUCH THIRD PARTY APPLICATION.

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 alternatively 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 carefully such notice 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 Registration form and/or other Services’ purchase process, which includes, inter alia, full name, phone number, email address,. Please note that certain information may be provided for the purpose of producing invoices. Additional information may be requested in the future.
• 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 the 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.

Please note: 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 consents under applicable privacy laws from data subjects for the use, processing, sub-processing and storing of their information in accordance with these Terms.

• 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 to us free text 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 to 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 and do not receive any direct payment from Users. Where necessary, we only keep token information that such Online Payment Processors provide us with and we will keep such information strictly secured.
• The Services: we may collect certain information as part of the User’s use of the Services, including the User’s activity on the App and/or the Site and/or the Services, and such information may be available for the User via the App and/or the Site.

Personal Information is collected also 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 3.(a) will be 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 another unique identifiers, for geo-location, 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 of Use) will be processed using artificial intelligence that will allow us to provide you with Insights (as defined under the Terms of Use). Thus the processing of information by us as part of the provision of the Services may generate personal information about you.

Please note:

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.

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. 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; and
• 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.
• Keep the Site and/or the App safe and secured and for prevention of fraud.

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

• Enable the provision of our Services.
• Respond to your inquiries, requests, comments and suggestions.
• To provide you with Insights (as defined under the Terms of Use).
• Provide support and technical assistance.
• Ensure that the content on the App and/or the Site and/or the Services is presented in an optimal way for you and for your device (e.g., tablet, mobile phone).
• Send you by email, SMS, phone, through the App and/or web-browser notification or through the post updates, commercial content, newsletters, notices, announcements, and additional information related to the App and/or the Site and/or the Services.
• Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical 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 secured and for prevention of fraud and crime.
• 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.
• Maintain our data processing records and general administrative purposes.

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 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 that 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 parties vendors of certain products or services (such as, cloud services) (including, as applicable, their affiliates) solely 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. For more information regarding our Service Providers, please refer to the minors Section below.
• 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’s 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; (i) to cooperate with third parties for legitimate business purposes, including without limitation, enhancing the User’s experience; and/or (l) pursuant to your explicit approval prior to the disclosure.

For 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. Data subjects’ rights

We acknowledge that you have the right to access and change the Personal Information we collect and process about you. You may update your Personal Information independently via the App and/or the Site. However, if you find that you are unable to do so or if you wish to access or to 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..

7. 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 and 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 in accordance with the safeguards permitted under applicable privacy laws, to ensure that your data is secured at all times.

Note to non EU or UK based Users

BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE APP AND/OR THE SITE, YOU ACKNOWLEDGE, AND CONSENT, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

8. 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 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 reasons 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.

9. 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 ever occur. MINDLI SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.

10. Cookies

When you access or use the App and/or the Site and/or the Services, we and/or our third-party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies), which store certain local information on your device (“Local Storage“) which may enable us, inter alia, to recognize your device from those of other Users of the App and/or the Site and/or the Services, to improve the App’s and/or the Site’s and/or the Services’ performance, to deliver a better and more personalized service according to the User’s individual interests and the device or browser used, to track Users’ use of the App and/or the Site and/or the Services, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern, and to perform other analytics and to develop our App and/or the Site and/or the Services. Such information is locally stored in the User’s device. MindLi and/or our authorized third party service providers may access such information. MindLi and/or our authorized third-party service providers may use both session cookies (which expire once you close the web-browser) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the App and/or the Site may store non-personal information (such as the different pages viewed by a User within the App and/or the Site and/or the Services) as well as User persistent identifier, which will be collected in accordance with the terms specified herein. Most devices and browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your experience of the App and/or the Site and/or the Services may be limited. Please note that unless you block the acceptance of cookies, the App and/or the Site will utilize cookies upon your use of the App and/or the Site. If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the App and/or the Site from placing further cookies on your device unless and until you adjust your settings as described above. For detailed instructions regarding the blocking of cookies, please refer to your browser ‘help’, ‘tool’ or ‘edit’ section or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web browsers:

Chrome
Internet Explorer and Microsoft Edge

Mozilla Firefox

Safari

It is possible to opt-out of having your browsing activity within the App and/or the Site and/or the Services recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users’ activities on the App and/or the Site and/or the Services, including by use such services’ persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout

11. Third-Party Service Providers

While using the App and/or the Site and/or the Services we may be using third-party service providers, who may collect, store and/or process the Personal Information detailed herein. Such third parties may be located in a country that does not have the same data protection laws as your jurisdiction. MindLi uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such third parties’ software or services may include without limitation the following categories of service providers:

–Hosting and cloud services;

–Infrastructure and operation services;

– Third parties’ artificial intelligence based services.

– Mailing services; and

– Data analysis services.

12. 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, and 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 resource. 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.

13. Direct Marketing

To the extent permitted under applicable law, you hereby agree that 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 withdraw your consent 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 is available in the message transmitted to you. 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 settings.

14. Data Retention

The Company will retain your Personal Information for as long as your Account to use App is active and for a period of 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.

15. 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 the 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.

16. 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 re-visit 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 the earlier. Otherwise, all other Changes to these Terms are effective as of the stated “Last Revised” and your continued use of the Site and/or the App on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

17. 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.