Privacy Policy
Data Controller and Owner:
CM MENTALGROWTH LTD Incorporated and registered in the Republic
of Cyprus, Registration No. HE
372828 34, RIGA FERAIOU STR., OFFICE 33, 1087, NICOSIA CYPRUS
Owner contact email: support@mentalgrowth.app.
Types of Data collected
Among the types of Data that Aspectica (hereinafter the «Application») collects, by itself
or through third parties, there are: Cookies and Usage Data, Contact data, Physical data,
Account data, Correspondence data, Session data, Preference data.
Other Personal Data collected may be described in other sections of this privacy policy or
by dedicated explanation text contextually with the Data collection.
The Personal Data may be freely provided by the User, or collected automatically when
using this Application.
Any use of Cookies- or of other tracking tools - by this Application or by the owners of third
party services used by this Application, unless stated otherwise,serves to identify Users and
remember their preferences, for the sole purpose of providing the service required by the
User. Failure to provide certain Personal Data may make it impossible for this Application to
provide its services.
Users are responsible for any Personal Data of third parties obtained, published or shared
through this Application and confirm that they have the third party's consent to provide the
Data to the Owner.
Mode and place of processing the Data Methods
of processing
The Data Controller processes the Data of Users in a proper manner and shall take
appropriate security measures to prevent unauthorized access, disclosure, modification, or
unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following
organizational procedures and modes strictly related to the purposes indicated. In addition
to the Data Controller, in some cases, the Data may be accessible to certain types of
persons in charge,
involved with the operation of the site (administration, sales, marketing, legal, system
administration) or external parties (such as third party technical service providers, mail
carriers, hosting providers, IT companies, communications agencies) appointed, if
necessary, as Data Processors by the Owner.
Place
The Data is processed at the Data Controller's operating offices and in any other places
where the parties involved with the processing are located. For further information, please
contact the Data Controller.
Retention time
The Data is kept for the time necessary to provide the service requested by the User, or
stated by the purposes outlined in this document, and the User can always request that the
Data Controller suspend or remove the data.
The use of the collected Data
The Data concerning the User is collected to allow the Owner to provide its services, as well
as for the Analytics. You will find below explanations regarding the reasons why we may
collect data and the legal bases we rely on in each case:
We may use your Contact Data to:
- respond to communications that you send to us. The legal basis for such processing is
your and our legitimate interests; and
- market products and services to you only where you have requested that we do so, or
otherwise provided your explicit consent. The legal basis for such processing is that you
have consented to us doing so; and
- for customer relationship management (“CRM”) purposes;
- additionally, we may request access to your device’s contacts for the purposes of enabling
social functionality.
We may use your Account Data to:
- enable you to personalize your use of our services;
- enable you to save and maintain your profile and administer your account with us; and -
enable us to identify you.
The legal basis for such processing is for the performance of the contract between you and
us.
The legal basis for such processing is for the performance of the contract between you and
us.
We may use your Correspondence Data to:
- help address issues you raise with us and to improve the Application and our services. The
legal basis for such processing is your and our legitimate interests.
We may use your Session Data to:
- administer, maintain and improve the Application and our services, including identifying you
or your device. Additionally, Session Data is used to identify and respond to potential risks to
the security of the Application. The legal basis for such processing is our legitimate interest.
This Data is provided ONLY by the Platforms our App is published on, such as AppStore
and Google Play. We do not store this Data in any way.
We may use your Preference Data to
- infer your interests, including serving and suggesting content that you might like, and
tailoring advertising to you based on such preferences.
Detailed information on the processing of Personal
Data
Personal Data is collected for the Analytics purposes and using the following services: The
services contained in this section enable the Owner to monitor and analyze web traffic and
can be used to keep track of User behavior.
1. Appsflyer
Appsflyer is an analytics service.
Personal Data collected: Cookies and Usage Data. Place of processing: US
2. MixPanel
MixPanel is an analytics service.
Personal Data collected: Cookies and Usage Data. Place of processing: US
3. Facebook Analytics
Facebook Analytics is an analytics service.
Personal Data collected: Cookies and Usage Data. Place of processing: US
4. Google Analytics
Google Analytics is an analytics service.
Personal Data collected: Cookies and Usage Data. Place of processing: US
5. TestFlight
TestFlight is an analytics service.
Personal Data collected: Cookies, email address and Usage Data. Place of processing: US
6. Amplitude
Amplitude is an analytics service.
Personal Data collected: Cookies and Usage Data. Place of processing: US
7. Adapty
Adapty is an analytics service.
Personal Data collected: Cookies and Usage Data. Place of processing: US
8. Firebase
Firebase is an analytics service.
Personal Data collected: Cookies and Usage Data. Place of processing: US
Additional information about Data collection and
processing Legal action
The User's Personal Data may be used for legal purposes by the Data Controller, in
Court or in the stages leading to possible legal action arising from improper use of this
Application or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal
data upon request of public authorities.
Additional information about User's
Personal Data
In addition to the information contained in this privacy policy, this Application may provide
the User with additional and contextual information concerning particular services or the
collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may
collect files that record interaction with this Application (System logs) or use for this purpose
other Personal Data (such as IP Address).
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested
from the Data Controller at any time. Please see the contact information at the beginning of
this document.
The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and
can consult the Data Controller to learn about their contents and origin, to verify their
accuracy or to ask for them to be supplemented, canceled, updated or corrected, or for their
transformation into anonymous format or to block any data held in violation of the law, as
well as to oppose their treatment for any and all legitimate reasons. Requests should be
sent to the Data Controller at the contact information set out above. This Application does
not support “DoNot Track” requests. To determine whether any of the third party services it
uses honor the “Do Not Track” requests, please read their privacy policies.
Users also have the right to lodge a complaint with their local data protection authority
about any of activities that are deemed not to be in compliance with GDPR.
POLICIES CONCERNING
CHILDREN
We recognize we have a special obligation to protect personal data obtained from children.
Legally you must be at least 13 years old to use this application. We do not and will not
knowingly collect personal data from any child under the age of 13 without consent from
their parent or guardian.
EU residents
Individuals residing in the countries of the European Union have certain statutory rights in
relation to their Data introduced by the General Data Protection Regulation (the “GDPR”).
Subject to any exemptions provided by law, you may have the right to request access to
Data (including in a structured and portable form), as well as to seek to update, delete or
correct Data:
a. Rectification of Data and Restriction of Processing
You are responsible for ensuring the accuracy of your Data that you submit to the
Application. Inaccurate information will affect your experience when using the Application
and our ability to contact you. If you believe that your Data is inaccurate, you have right to
contact us and ask us to correct such Data by contacting us at support@mentalgrowth.app.
You shall also have the right to request restriction of processing of your Data, if you contest
the accuracy of the Data, and we need some time to verify its accuracy.
b. Access to your Data and Data Portability
You shall have the right to request information about whether we have any Data about you,
to access your Data (including in a structured and portable form) by writing us at
support@mentalgrowth.app.
c. Erasure of your Data
If you believe that your Data is no longer necessary in relation to the purposes for which it
was collected or otherwise processed, or in cases where you have withdrawn your consent
or object to the processing of your Data, or in cases where the processing of your Data
does not otherwise comply with the GDPR, you have right to contact us and ask us to erase
such Data as described above. You can simply write to us at support@mentalgrowth.app.
Please be aware that erasing some Data inserted by you may affect your possibility to use
the Application. Erasure of some Data may also take some time due to technical reasons.
Or you may use the ‘Delete my account' function from the Settings Tab, thereby deleting all
your Data.
d. Right to object processing of your Data
You can object processing your Data and stop us from processing your Data simply by
writing to us at support@mentalgrowth.app. Please be aware that erasing some Data
inserted by you may affect your possibility to utilize the Application.
e. Notification requirements
We commit to notify you within a reasonable period of time and your data protection
authority within the timeframe specified in applicable law about any personal data breaches
in the Application.
f. Data Protection Authorities
Subject to GDPR, you also have the right to (i) restrict our use of Data and (ii) lodge a
complaint with your local data protection authority about any of our activities that you deem
are not compliant with GDPR.
Please keep in mind that in case of a vague access, erasure, objection request or any other
request in exercise of the mentioned rights we may engage the individual in a dialogue so
as to better understand the motivation for the request and to locate responsive information.
Following the provisions of GDPR we might also require you to prove your identity (for
example, by requesting an ID or any other proof of identity) in order for you to invoke the
mentioned rights. This is made to ensure that no rights of third parties are violated by your
request, and the rights described in this section are exercised by an actual Data subject or
an authorized person.
California residents
Individuals residing in California have certain
statutory rights in relation to their Data introduced by
California Consumer Privacy Act of 2018 (the
“CCPA”). Subject to any exemptions provided by law,
you may have the following rights:
a. Transparency Rights
A right to receive certain information about how a business collects and uses your
information. Such information must be provided within a privacy policy and upon request.
b. Right of Access
A right to request access to certain information which includes categories of personal
information collected or sold, specific personal information, sources, purpose of collection
and use and categories of third parties that the Business sold personal information to.
c. Portability Rights
The right to receive the information in a readily usable format that allows you to easily
transmit the information to another entity.
d. Right of Deletion
A right to request deletion of data collected from you. Upon such a request, a business
must delete such data (subject to certain exceptions) and flow down the request to its
service providers who must comply.
e. Right to Opt Out
The right to require any business that sells information to third parties to opt out from selling
your information. In the case of personal information of children between 13-16, a the child
must opt in to permit such sale and under 13 must obtain parental consent.
f. Non-Discrimination Rights
Subject to certain exceptions businesses are prohibited from discriminating against any
Consumer who exercises a right granted under the CCPA and must continue to provide
equal service or goods and price even if one exercises his rights.
Please keep in mind that in case of a vague access, erasure, objection request or any other
request in exercise of the mentioned rights we may engage the individual in a dialogue so
as to better understand the motivation for the request and to locate responsive information.
Following the provisions of CCPA we might also require you to prove your identity (for
example, by requesting an ID or any other proof of identity) in order for you to invoke the
mentioned rights. This is made to ensure that no rights of third parties are violated by your
request, and the rights described in this section are exercised by an actual Data subject or
an authorized person.
Definitions and legal references
Personal Data (or Data)
Any information regarding a natural person, a legal person, an institution or an association,
which is, or can be, identified, even indirectly, by reference to any other information,
including a personal identification number. Data may include:
-Contact Data: This may include your name and your email address. This information will
be collected by us if you communicate with us, for example if you use the links on the
Application to communicate with us via email.
-Account Data: If you create an account in the Application to benefit from our Platforms,
you
may need to provide your name, email address.
-Physical Data: This may include your gender identity, age, date and place of birth.
-Correspondence Data: This includes the information you provide when you request
support through the Application, contact us via the email address provided in this Privacy
Policy and elsewhere on our website and your views, opinions and feedback which you
choose to provide in relation to the App and our services, including any comment facilities
and message boards.
-Session Data: This includes your IP address, your device’s unique identifier details,
browser details including version, device operating system, geo-location, time zone setting
and time/date of access requests, the amount of data transmitted and the requesting
provider. We may also capture other information about visits to the Application such as
traffic patterns.
-Cookie Data: Cookies are small files which are downloaded to your device when
accessing our platform. Most web browsers automatically accept cookies.
-Preference data: This includes any information you choose to provide us.
Usage Data
Information collected automatically from this Application (or third party services employed
in this Application), which can include: the IP addresses or domain names of the computers
utilized by the Users who use this Application, the URI addresses (Uniform Resource
Identifier), the time of the request, the method utilized to submit the request to the server,
the size of the file received in response, the numerical code indicating the status of the
server's answer (successful outcome, error, etc.), the country of origin, the features of the
browser and the operating system utilized by the User, the various time details per visit
(e.g., the time spent on each page within the Application) and the details about the path
followed within the Application with special reference to the sequence of pages visited, and
other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application, which must coincide with or be authorized by the Data
Subject, to whom the Personal Data refers.
Data Subject
The legal or natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural person, legal person, public administration or any other body, association or
organization authorized by the Data Controller to process the Personal Data in compliance
with this privacy policy.
Data Controller (or Owner)
The natural person, legal person, public administration or any other body, association or
organization with the right, also jointly with another Data Controller, to make decisions
regarding the purposes, and the methods of processing of Personal Data and the means
used, including the security measures concerning the operation and use of this Application.
The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The hardware or software tool by which the Personal Data of the User is collected
(Aspectica). Cookies
Small piece of data stored on the User's device.
How long we store data
Your data will be stored on our system as long as you are registered. Beyond that, we are
only storing data if it is legally necessary or otherwise required by law.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by
giving notice to its Users on this page. It is strongly recommended to check this page often,
referring to the date of the last modification listed at the bottom. If a User objects to any of
the changes to the Policy, the User must cease using this Application and can request that
the Data Controller remove the Personal Data. Unless stated otherwise, the then-current
privacy policy applies to all Personal Data the Data Controller has about Users.
Latest update: December 29, 2023
BY USING THIS APPLICATION, YOU PROMISE THAT YOU HAVE READ, UNDERSTAND
AND AGREE TO THIS PRIVACY POLICY.
