Mindset Technologies Ltd (Mindstep)
Mobile Application Privacy Policy
Mindset Technologies Ltd, trading as “Mindstep”, is on a mission to create a one-stop brain care platform, via the Mindstep App mobile application software (the “App”). Mindstep is committed to respecting your privacy and protecting your personal data.
Consent to installation of the App
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this privacy policy and it is important that you read that information. Before installation of this App, please indicate your consent to our processing of your personal data as described in the policy.
By clicking the purple “Agree” button I consent to the installation of the App for the purposes of Mindstep providing a screening mechanism and personalised care approach if I choose to sign up to the care platform to reduce risk factors for cognitive decline and mental health disorders as set out in the privacy policy. To do this, the App provides information, advice, and a personalised action plan to support my mental and physical health and to lower risk of cognitive impairment based on the information I provide and if I choose to interact with the care platform available on the App.
I do not consent to the installation of the App.
If you change your mind and want to withdraw your consent you can do this at any time by contacting us at compliance@letsmindstep.com. Withdrawing your consent will not affect the lawfulness of any processing carried out before you withdraw your consent.
Mindset Technologies Ltd (we) are committed to protecting your personal data and respecting your privacy.
Introduction
This policy (together with our end-user licence agreement (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:
Mindstep mobile application software (the “App”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
Any of the services accessible through the App (Services) that are available on the App Site.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
Mindset Technologies Ltd trading as “Mindstep” is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).
We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Mindset Technologies Ltd
Name of DPO: Aaron Lin
Email address: compliance@letsmindstep.com
Postal address: C/O Cc Young & Co, 3rd Floor, The Bloomsbury Building, 10 Bloomsbury Way, Holborn, London, England, WC1A 2SL
If you have any concerns about our use of your personal information you can raise your concerns to us directly using the contact details above.
You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated in June 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you via push notifications. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
The data we collect about you
The data we collect about you depends on how you choose to engage with the App. We designed the App as follows to provide you with a choice whether to continue your user journey by signing up to the care platform:
Part 1 – the screening mechanism. This section of the App provides a screening mechanism whereby your data will be processed by using clinically validated cognitive screening tools, questionnaires and algorithms to assess you for signs of cognitive impairment and/or risk factors for cognitive impairment. We do not make a diagnosis; we simply show where you score relative to the expected level for your age group.
Part 2 - the care platform. If you decide to continue your user journey with the App you can choose to sign up to the care platform available on the App.
The App provides a personalised care approach directly to the general adult population to reduce risk factors for cognitive decline and mental health disorders. To do this, the App provides you with information, advice, and a personalised action plan to support your mental and physical health and to lower your risk of cognitive impairment based on the information you provide to us via the screening mechanism within the App and your interaction with the care platform available on the App.
If you interact with the screening mechanism in Part 1 of the App we collect, use, store and transfer different kinds of personal data about you such as: Identity Data; Device data; Content data; Health data; Usage data;
If you interact with the care platform in Part 2 we collect, use, store and transfer different kinds of personal data about you such as: Identity Data; Device data; Content data; Health data; Usage data; transaction data, profile data; marketing and communications Data; Contact data;
We explain these categories of data here.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may come from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We will process special category data about you whilst using the App. Special category data means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
How is your personal data collected
We collect the following data about you:
Information you communicate to us. This is information you consent to giving us about you by filling in forms on the App Site, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, enter a competition, register to an event promotion or survey and when you report a problem with an App or our Services. If you contact us, we will keep a record of that correspondence.
Information we collect automatically. Each time you use our App we may automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
We may also receive personal information indirectly, from the following sources in the following scenarios: Device Data from analytics providers; advertising networks and search information providers
Cookies
We use cookies and/or other tracking technologies to distinguish you from other users of the App, and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our website and also allows us to improve the App and website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
How we use your personal data
We will only use your personal data if we have a legal basis for the processing activity. We process your personal data in the following circumstances:
Where you have consented before the processing takes place.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests of significant potential for contribution to medical research and the significant potential benefit for the wider scientific community, the public and healthcare systems, and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data in accordance with data protection laws
We will use your personal data for the following purposes:
To install the App and register you as a new App user.
To provide you with access to the App and care platform in order to provide our services including general health screening, cognitive screening, cognitive assessment and if applicable a personalised action plan.
To improve and develop our products and services.
To allow us to communicate with you.
To contribute to medical research and development and the wider scientific community.
To manage our relationship with you including notifying you of changes to the App or any Services.
Administer the operation of the App including app malfunction monitoring.
To enable you to participate in a prize draw, competition or complete a survey.
To deliver content and advertisements to you, make recommendations to you about goods or services which may interest you, to measure and analyse the effectiveness of the advertising we service you.
To track user behaviour in relation to your usage of the Mindstep to help us better understand the effectives of various marketing & advertising strategies.
To monitor trends so we can improve the App
Providing your personal data to others
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in this policy.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
International transfers
Many of our external third parties are based inside the UK. Some of our external third parties are based outside of the UK and so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we will use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
All information you provide to us is stored on our secure servers. In App purchase transactions carried out by Apple will be encrypted.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We do not provide hardware for users, and therefore you must download the App software onto your personal device. Once downloaded, the App is stored locally on your device. Users require network connectivity for the App to function properly and for data to be collected and accessible by us. Where you do not have network connectivity, data will continue to be collected through the App, but will not be received or accessible by us, as it will be stored entirely locally.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Data retention
We will retain your Personal Data only for the period necessary to fulfil the purposes outlined in this Policy.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these applicable rights at any time by contacting us at compliance@letsmindstep.com.
Glossary
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
External third parties such as service providers who support our services. Other third parties may have access to your aggregated data, but will be unable to use the data to identify you.
External third parties proving third–party tracking technology if you opted into the Apple ATT.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances
Your legal rights
As already detailed above within this Policy, under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
if you want us to establish the data's accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can exercise any of these rights as applicable at any time by contacting us at compliance@letsmindstep.com.
Description of categories of personal data
Identity Data: such as first name, last name, username or similar identifier, date of birth, gender.
Contact Data: such as email address.
Transaction Data: may include details about payments to and from you and details of in-App purchases.
Health Data: information about your health is special category data
Device Data: such as IP address and device model, a security token; a unique device identifier; identifier for vendor.
Third party tracking technology data: once a user downloads the Mindstep app from Apple, the Apple’s in built ATT consent button gives you the choice whether you wish to opt in to tracking technology.
Content Data: includes information stored on your Device.
Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
Usage Data: includes details of your use of any of our Apps or your visits to any of our App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.