Privacy Policy

This Privacy Policy determines how InnMind - Innovare Digital S.A.R.L. (hereinafter referred to as the "Company") uses and protects information received from Users on the website www.innmind.com (hereinafter referred to as the "Site"). This document is a complete statement of the privacy policy of personal data on the Internet, applicable to the activities of our Company.

The activities of our Company in the use and protection of personal data are regulated in accordance with European Regulation Union 2016/679 of April 27, 2016 (General Data Protection Regulation, hereinafter referred to as "GDPR"), which is a legally binding act. The GDPR protects the fundamental rights and freedoms of individuals, in particular their right to protection of personal data.

InnMind is considered a data controller and defines the purposes and methods of processing personal data.

1. Definitions

Capitalized terms used later in this document have the same meanings as in the Terms of Use, unless such concepts are assigned different meanings in this document.

2. Personal Information

Personal data is any information that relates to an identifiable or identifiable individual. Personal data includes all types of information that directly or indirectly identify a person: name, date of birth, address, email, phone number, etc.

3. Principles

Our Privacy Policy is based on the following data protection principles:

- personal data must be processed in a lawful, conscientious and transparent manner;

- personal data should be collected solely for achieving strictly defined, unambiguous and legitimate purposes and should

not be further processed by incompatible with these purposes;

- the collection of personal data must be carried out in the correct way and be limited to exclusively relevant information necessary to achieve the purpose that the processing of this data is intended for;

- personal data must be accurate and updated if necessary;

- all reasonable measures should be taken to ensure the immediate removal or correction of personal data revealing inaccuracies important for the purpose of processing them;

- personal data must be stored in such a way that it allows us to identify a person solely for the period of time necessary to achieve the goal that is pursued by processing this data;

- all personal data is not subject to disclosure and must be stored in a way that ensures their proper protection;

- personal data is not transferable to third parties, except for cases

when such transfer is necessary for the Company to provide the services provided for by the Terms of Use, this Policy, as well as proceeding from the Company 's activities;

- The User has the right to access personal data, to modify or delete data, to restrict or object to data processing, and the right to transfer data.

4. Collection of personal data

If you want to use our services and work with our Site and pass on information to us, we can ask you to provide personal data so that we can carry out our work, provide our services and improve their level. Personal data can be transmitted through our website, our mobile applications, e-mail or other electronic or software solutions we support, as well as by mail or by phone. The collection of all personal data is conducted in accordance with the GDPR. We process personal data exclusively in the amount necessary to achieve strictly defined, unambiguous and legitimate purposes, or to achieve the goal, the achievement of which is required by the legislation of the country in which we operate.

The personal data we collect first of all includes names, birth dates, addresses, e-mail addresses, phone numbers, passport data / other identification documents, national identification numbers. We collect these personal data for the following purposes: analytics, establishing contact with the User, comments to content materials, payment processing, registration and authentication, social functions, protection from spam and interaction with external social networks and platforms

In addition, we collect personal data for other purposes, for example, for statistics, administrative and communication tasks, IT administration and administration of security systems, physical security, the operation of identification and authorization systems, support systems, joint work on internal projects and activities and the joint work of the organizational units.

Personal Data is collected for the following purposes and using the following services:

Analytics: expand-content expand

Contacting the User: expand-content expand

Content commenting: expand-content expand

Handling payments: expand-content expand

Interaction with external social networks and platforms: expand-content expand

Registration and authentication: expand-content expand

Social features: expand-content expand

SPAM protection: expand-content expand

5. Use of personal data

We use personal data for the purposes for which they meet, and store them only for the time necessary to achieve these goals. We can store information about Users as long as their account remains active, or as long as it is necessary to provide our services, to fulfill our duties or to achieve any of the above goals. Access to personal data is provided exclusively to the Company's employees, as well as the affiliated organizations controlled by it, having the appropriate permission and clear working need for access to the data.

6. Using cookies

Our Site and our partners use cookies or similar technological solutions to provide maximum user convenience and for analyzing trends, managing the Site, tracking the user's behavior on the Site and collecting information in general. Cookies are small text files written in the memory of your device to track patterns of user behavior and take into account the preferences. Our cookies do not contain information that can directly identify a person. We automatically collect certain information using cookies and tracking tools, for example, the Internet Protocol (IP-address) address; type of browser; Internet provider (ISP); pages from which the user entered the site and from which he left the site; viewed on our site files (for example, HTML-pages, images); operating system; date and time stamp; and / or click statistics for analyzing general trends and for managing the site. You can control the use of cookies at the level of your browser, but if you choose to disable cookies, this can limit the availability of certain features and features of our site or service.

7. Transfer of personal data

We transfer personal data to third parties only under the following circumstances:

- if the User has given consent to this;

- if the purpose of this data transfer is directly related to the purpose for which the personal data were collected initially;

- if necessary for the preparation

, clarification and enforcement of the Terms of Use;

- if required by law, administrative or judicial order;

- if this is required to substantiate or defend the statement of claim or to protect the lawsuit;

- if this is required to prevent abuse or other misconduct, such as coordinated attacks,

in order to ensure the preservation of data.

Periodically, we transfer the authority to conduct activities on our behalf to other companies and business partners operating within and outside the European Economic Area, for example, technology companies to process and provide systems and technological solutions that improve the quality of our products and services. In such cases, we share with the partners the necessary information.

Service providers only receive the personal data they require to provide their services. We do not disclose personal data to third parties in order to enable them to advertise their products or services to you. If you do not want your data to be transferred to these companies, please contact the personal data protection specialist at support@innmind.com.

8. Security of data processing

Processing personal data, we care about their security. We implement and maintain appropriate technical and organizational measures to protect personal data from accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, particularly if processing involves the transmission of data over the network, as well as protection against other forms of misuse. Questions about the security of personal data can be sent to: support@innmind.com.

9. Right to protection of personal data

Users have the right at any time to request access to, correct or delete personal data, prohibit processing or object to processing thereof, and the right to transfer data. In particular, Users have the right to perform the following actions:

- withdraw your consent at any time.Users have the right to revoke consent if they have previously given their consent to the processing of their Personal Data;

- object to the processing of their data.Users have the right to object to the processing of their data if processing is performed on any legal basis other than their consent.For more information on this issue, see the relevant section below;

- get access to your data.Users have the right to know whether the data is processed by the Company, to receive information about certain aspects of processing and to obtain a copy of the processed data;

- check the data and request a correction.Users have the right to check the accuracy of their data and ask them to update or fix it;

- restrict the processing of their data.Under certain circumstances, Users have the right to limit the processing of their data.In this case, the Owner will not process their Data for any purpose other than storing them;

- require the erasure of their personal data or delete them otherwise.Under certain circumstances, Users have the right to obtain from the Company the deletion of their data;

- get your data and transfer it to another supervisor.Users have the right to receive their data in a structured, widely used and machine - readable format and,

if technically possible, freely transfer them to another supervisor.This provision is applied provided that the data is processed by automatic means and that their processing is carried out on the basis of the User 's consent or on the basis of an agreement to which the User is a party, or on the basis of obligations preceding the conclusion of the contract;

- file a complaint, Users are entitled to file a claim with the competent data protection authority.

10. Liability

We are responsible for compliance with the requirements of the GDPR and the principles set forth in this Privacy Statement and are ready to demonstrate such compliance at any time. We keep records of data processing activities under our responsibility, including the required GDPR information, and, if necessary, provide these credentials to the supervisory authorities upon request.

If there is an unlikely situation in which you consider that we violated the GDPR during the processing of your personal data, you can file a complaint with the supervisory authority.

11. Company requisites

Innovare Digital S.A.R.L.

The number in the trade register No. CHE-278.229.110

support@innmind.com

Any inquiries regarding the exercise of Users' rights under this document may be sent to the Company at: support@innmind.com. These requests can be made free of charge and will be reviewed by the Company as soon as possible, not exceeding one month.

Periodically, this Privacy Statement may be amended, for example, in case of changes in relevant legislation or the corporate structure of our company. You will be notified by e-mail or through an information message on our website about making significant changes before these changes take effect. We recommend that you regularly review this page in order to keep abreast of the current version of our privacy policy.

Updated: 10/09/2018