Effective September 15, 2020
What Information We Collect
As described in more detail below, we may collect the following categories of information about you or your use of MINDTAPP: (1) identifiers (such as name and email address); (2) commercial information (such as transaction data); (3) financial data (such as payment information); (4) internet or other network or device activity (such as browsing history or app usage); (5) geolocation information (e.g. general location inferred from an IP address); (6) sensory information (such as audio or video recordings during research programs); (7) professional or employment related data; (8) education data; (9) inference data about you; (10) legally protected classifications (such as gender); (11) medical information (such as information you voluntarily provide to us in a survey); (12) physical characteristics or description; (13) curated content (such as photos you upload) and (14) other information that identifies or can be reasonably associated with you.
Information You Provide Directly to Us
- Register for a MINDTAPPaccount (“Account”);
- Request certain features (e.g. newsletters);
- Fill out a survey or provide us with feedback;
- Play mindset training games or engage in other activities that require your information to function (e.g., portions of MINDTAPP that require an Account to participate);
- Apply for a job with us;
- Communicate with us; or
- Post user-generated content to MINDTAPP.
You are not required to create an Account to gain access to some areas of MINDTAPP. If you do create an Account, we ask for certain information to process your registration, including an email address and password. If you subscribe to a paid account, we request additional information, including your full name and payment method details.
We may also collect (1) name, (2) gender, (3) date of birth, (4) education level, (5) other demographic information, and (6) other information you voluntarily provide to us. Providing most of this information is optional. We also allow you to select your preferences for training and receiving email communications.
Information that is Passively or Automatically Collected
In addition to the information you provide directly to us, when you use MINDTAPP, we may automatically collect information about the computer, mobile device, or other devices you use to access MINDTAPP and about how you use MINDTAPP. For example, we receive data about the games you play and your performance in those games. We also receive information such as your browser type, IP address, language, the type of device you use, operating system version, unique device identifier ("UDID"), the date and time of your visit, and files you viewed on our site (e.g., HTML pages, graphics, etc.), Internet service provider, clickstream data, the pages you view and the websites you visited immediately before and after visiting MINDTAPP. In some cases, we link this automatically-collected data to other information we collect about you. We do this to improve the services and marketing we offer you.
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access MINDTAPP. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information (including general location inferred from IP addresses), unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed MINDTAPP; and (b) information related to the ways in which you interact with MINDTAPP, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages, and content viewed and the order of those pages, statistical information about the use of MINDTAPP, the amount of time spent on particular pages, the date and time you used MINDTAPP, the frequency of your use of MINDTAPP, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe's website. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of MINDTAPP.
We may supplement the information you provide to us with additional information gathered from other sources, such as publicly available information, or from third parties, such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other product or service we provide.
If you are a subject in a research project or study conducted by MINDTAPP in partnership with a researcher or educational institution, that project may involve the collection of different information than is described in this Section. Research participants may, for example, provide health-related information, including the existence of certain health conditions. MINDTAPP partners with researchers and educational institutions in conducting such studies. Such research projects are typically done on an anonymous basis, such that MINDTAPP acts only as a processor of anonymized or pseudonymized data. For further information on how we handle data associated with such research, please refer to the materials distributed to you as part of the study, contact the researcher leading your study, or contact us using the contact information below.
How We Use Your Information at MINDTAPP
We use your information to operate and provide you with MINDTAPP and other services. This includes, but is not limited to the following business and commercial purposes:
We also reserve the right to use and disclose non-personal data (e.g., de-identified or aggregate data) for any purpose. For example, we show aggregate performance measures to users to allow them to evaluate their performance against other MINDTAPP users. Also, in regard to research, we may disclose performance statistics to university collaborators to evaluate, study, and improve the effectiveness of our programs or psychological functioning more generally. In these situations, all data is disclosed either in aggregate form or with information that can identify you removed. In addition, when we work with university collaborators, we contractually prohibit them from attempting to re-identify individuals from data that has been de-identified.
Legal Bases For Use Of Your Personal Data
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:
- Providing a safe and enjoyable user experience;
- Customer service;
- Protecting our users, personnel, and property;
- Analyzing and improving our business;
- Processing job applications; and
- Managing legal issues.
- We may also process personal data for the legitimate interests of our research partners, such as to provide cognitive training, research, and analytics for such partners.
No Disclosure to Third Parties for Their Own Marketing Purposes
We believe in protecting your privacy, and therefore do not provide your personal data to third parties for their own marketing purposes.
When We Share Your Personal Information With Third Parties
We may share the categories of personal information identified in Section 1 for business purposes (as defined by applicable law) or as required by applicable law. More specifically, we may share your personal information in the following situations:
Service providers and agents
Compliance with law and law enforcement requests, and protection of our rights.
Online Analytics And Tailored Advertising
We may use third-party web analytics services on MINDTAPP, such as those of Google Analytics, Rollbar, and New Relic. These service providers use the sort of technology previously described in the "Cookies and other electronic technologies" section to help us analyze how users use MINDTAPP, including by noting the third-party website from which you arrive, how often you use our app, the events that occur within our app, where the app was downloaded from, and provide certain features to you. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of MINDTAPP. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.
If you receive an email from us, we may use certain tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications.
We may personalize the content and advertising that you see when using MINDTAPP through the use of third-party advertising technologies that allow for the delivery of relevant content and advertising on our websites, as well as other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, the information you provide such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and may be tailored to your interests.
To opt-out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into MINDTAPP, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Data Subject Rights And Your Choices
Analytics and Advertising
Your Legal Rights
- confirm whether we hold personal data about them,
- provide access to personal data we hold about them (including, in some cases, in portable form),
- update, amend, and/or correct personal data we hold;
- delete certain personal data in appropriate circumstances;
- transfer personal data to a third-party provider of services;
You can opt-out of receiving marketing emails by following the unsubscribe instructions included in each email. Please note you may not opt-out of certain transactional emails, such as when we email you to confirm transactions, address Account issues, or communicate about customer support.
From time to time, we use push notifications in our mobile applications to send you messages about MINDTAPP or your Account. You may opt-out from receiving push notifications through your device settings.
California residents have certain rights, subject to exceptions. California law may permit you to request that we:
You may have the right to receive information about the financial incentives that we offer to you if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our services to you. If you ask us to delete it, you may no longer be able to access or use MINDTAPP.
If would like to exercise any of these rights, please submit a request at firstname.lastname@example.org. We will take reasonable steps to verify your identity.
California residents may opt-out of the “sale” of their personal information. MINDTAPP does not “sell” your personal information as we understand that term to be defined by the California Consumer Privacy Act and its implementing regulations.
Under Nevada law, certain Nevada consumers may opt-out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity.
Retention Of Personal Data And Security
Outside The United States Consent To Processing And Transfer Of Information
If you access MINDTAPP outside of the United States, you fully understand and unambiguously consent to the transfer of your personal data to, and the collection and processing of such personal data in the United States. The recipients of the personal data disclosures described in the "When We Share Your Personal Data with Third Parties" section above may be located in the United States or elsewhere in the world. Privacy laws in these countries may not provide protections equivalent to those of your country of residence, and your government may or may not deem such protections adequate.
- Our website may include links to other sites that may collect personal data, and whose privacy practices may differ from those of MINDTAPP. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to review their privacy policies.
- We may allow you to refer your friends and contacts to MINDTAPP, either by manually entering their email addresses or by importing contacts from email accounts you have with third parties. If you choose to utilize these features, we will use and store the email addresses only for purposes of sending the invitation emails you have requested. If you utilize these features, the friends or contacts that you refer may contact us at the contact information listed below to request that we delete their personal data. Please note that we do not collect the username and password to your email accounts; the import features route you to the third party email provider to log in through their services.
- Our website may include social media features, such as Facebook and Twitter buttons. Such features may collect your IP address and information about the page you are visiting and may set cookies to function properly. Your interactions with these features are governed by the privacy policies of the company providing them.
MINDTAPP is not directed to individuals under 13 years old. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13, children under the age of 14 in Spain or South Korea, or from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as required by law. As appropriate under applicable law, parents or legal guardians with questions or requests regarding their children’s personal data may contact us as described below.
California "Do Not Track" Notice
We do not track our customers’ personal data over time and across third-party websites to provide targeted advertising and therefore do not respond to "Do Not Track" (DNT) signals.
17206 Courtney Lane
Huntington Beach, CA 92649