How Do We Collect Information?

We collect, store, and use information you share on our App, including the resulting personality analysis, shadow work profiles, archetypal patterns, and dream analysis determined by Mindberg — including through the use of AI-powered tools — on that basis. This includes your name, email address, date of birth, answers to our assessments and tools, the description of your dreams, and any other information you choose to enter on the App, as well as personalized insights and guidance generated by the App.

If you provide personal data of another person on our App, you must ensure you have that person’s consent to both the disclosure and the processing of their data in accordance with this Privacy Policy.

Depending on your method of payment, we may collect purchase information such as payment details, billing address, and related payment data. Payment processing is handled by third-party providers — we do not store your full payment card details.

We also record certain technical information when you use our App, including information about your device and your visits to and use of our App, such as your IP address, browser type, and page views.

Whether Information Has to Be Provided by You and Why

Providing contact and relevant information enables us to communicate with you and deliver our services. We’ll inform you at the point of collection whether the information is required.

If you don’t provide certain requested information, we may not be able to provide the services which require it (e.g., certain features or assessments).

How Do We Use the Information We Collect?

We use the information we collect to provide you with our services and content that is relevant and personal to you. Specifically, it’s necessary for us to use your information to:

• Send you account-related messages, such as password recovery emails
• Identify you and ensure the security of your account
• Provide you with personalized content and services relevant to your psychological profile
• Process your assessment responses using AI-powered tools to generate shadow work profiles, archetypal analysis, dream interpretations, and other personalized psychological insights
• Respond to your questions or complaints

We have a legitimate interest in using your information in these ways. It’s necessary for us to make our services and content as relevant to you as possible.

In addition, we have a legitimate interest in maintaining our relationship with you, improving our App and services, and protecting both you and other users. We use your information to:

• Conduct analytics on how you use our App in order to better understand your needs and optimize our service. We use third-party analytics providers to collect standard usage data and behavior patterns. This information is processed in a way that does not identify individuals.
• Improve our App and develop new functionality
• Conduct internal analysis and research to improve our services and understanding of personality patterns
• Keep the App secure and prevent fraud
• Keep users safe, including working with law enforcement where necessary
• Verify compliance with the terms and conditions governing use of the App

Other legal grounds that apply to our processing of your personal data include:

• Where we provide services to you as a member — covered by our contract with you (see our Terms and Conditions)
• Where we expressly require consent from you for the processing in question
• Where another legal ground applies — e.g., to protect vital interests, or where required by law

We will only use your personal data with your consent to send email newsletters (you can unsubscribe at any time), and where assessments involve “special category” personal data (e.g., data concerning health), which we process to provide results and subsequently for anonymized research purposes. You may withdraw consent at any time.

Where you supply us with special category personal data, we may further process this data for research purposes in anonymized form, relying on Article 17, Section 2, Item 10 of the Serbian Personal Data Protection Law (“DP Law”) and Article 9.2(j) of the GDPR.

We will not provide your personal data to any third parties for the purpose of direct marketing by those parties.

Do We Transfer Your Information Elsewhere?

As a worldwide digital service, we work with providers located both within and outside Serbia and the European Economic Area (EEA) in order to operate our App. Some of your personal data may be transferred outside Serbia and the EEA. Some of the countries in question may not have data protection laws equivalent to those in Serbia or the EEA.

We ensure that any transfer of your personal information outside Serbia and the EEA is subject to appropriate safeguards as permitted under the DP Law and the GDPR. We generally use standard contractual clauses for such transfers, unless the destination country has been deemed adequate. We also limit access to your personal information to staff members who have a business need for it.

Here are the categories of third-party providers we work with:

All third-party providers act as data processors in accordance with our instructions. We transfer as little data as possible and encrypt it where feasible.

How Can You Manage Your Information?

If you have an account on our App, you can use the Settings section to manage your personal details. This allows you to:

• Update your email address
• Edit your profile name or make it private
• Manage notifications
• Delete your profile

If you delete your profile, we will anonymize your user record, removing your email address, name, age, and other identifying information.

We will not, however, delete your responses to assessments, log records, and similar data. We retain this data to preserve the integrity of our research and ensure the security of our App.

If you decide to delete your profile, please save any information you’d like to keep beforehand. Once the profile is deleted, it cannot be recovered.

You can also ask us to correct personal data you have provided, or to remove specific personally identifying information from our App. We will need to verify the authenticity of any such request — please ensure your account is linked to an active email address.

How and When Do We Share Your Information?

Our staff, agents, suppliers, and subcontractors may need access to your information where necessary for the provision of our services.

There are also certain circumstances where we may disclose your personal information:

• Where required by law or in connection with legal proceedings
• Where we need to establish, exercise, or defend our legal rights
• If we are involved in a merger, reorganization, or similar proceeding requiring transfer of information
• If we have strong reason to believe that you or someone else is in immediate physical danger, we may contact local authorities and provide relevant information

We don’t serve ads in our App, and we don’t share your data with online advertisers. As a general rule, except as described above, we don’t share your personal information with third parties.

How Long Do We Keep Your Information?

We keep your information only for as long as needed to provide services to you and fulfill the purposes described in this policy. Retention periods include:

• Payment and order data, including relevant access logs — 10 years
• Activity logs — 1 year
• Transient activity records (e.g., email invitations, password resets) — 3 months
• Account details — unlimited (while the account is active)
• Content submitted to our App — unlimited

We regularly delete accounts that are not linked to meaningful activity and have been inactive for more than two years.

We will depersonalize your information or remove it from our systems once it is no longer needed for compliance, legal, regulatory, or other purposes described in this policy.

How Do We Handle Children’s Information?

Our App is not intended for individuals under the age of 18, and we do not knowingly collect personal data from anyone under 18. If you are below this age, you are not permitted to use our App, products, or services, and should not provide us with personal data.

What Can You Ask Us to Do with Your Information?

Under the DP Law and the GDPR, you have a number of important rights free of charge. These include the rights to:

• Access your personal data and certain supplementary information
• Require correction of any mistakes in data we hold about you
• Require erasure of your personal data in certain situations
• Receive your personal data in a structured, commonly used, machine-readable format and transmit it to a third party in certain situations
• Object at any time to processing of your data for direct marketing
• Object to decisions made by automated means which produce legal or similarly significant effects
• Object to continued processing of your data in certain other situations
• Restrict our processing of your data in certain circumstances
• Withdraw consent where we rely on it as the lawful basis for processing
• Lodge a complaint with a supervisory authority (in Serbia: the Commissioner for Information of Public Importance and Personal Data Protection, Bulevar kralja Aleksandra 15, Belgrade, Serbia)

To exercise any of these rights, please contact us (see Section 10). You will need to send the request from the email address associated with your account.

To unsubscribe from our newsletter, you can click the unsubscribe link at the bottom of any email.

How Do We Secure Your Information?

We take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal data. This includes storing information on secure, password- and firewall-protected servers, encrypting traffic to and from the App, and anonymizing or pseudonymizing personal data where possible.

We cannot guarantee complete security of data sent over the internet. Please take care when sharing sensitive data.

How Can You Get in Touch with Us?

You can reach us via email at [email protected].

We, Mindberg doo, are the data controller responsible for the information collected on our App.

If you reside in the EU/EEA, please contact our designated data protection representative: Attorney at law Mr. Marko Ketler, Dunajska cesta 136, Ljubljana, Slovenia. Email: [email protected].

Your Data Protection Rights under the CCPA

If you are a California resident, you are entitled to learn what data we collect about you, request deletion of your data, and request that we do not sell or share it. To exercise your rights, you may request:

• Disclosure: The categories of personal data collected, the sources, the business purpose for collection, the categories of third parties with whom we share it, and the specific pieces of data we hold about you.
• Deletion: We will delete the personal data we hold about you as of the date of your request and direct service providers to do the same. Some deletion may be accomplished through de-identification.
• No sale of data: We do not sell or rent your personal information to any third party for any purpose. You are the sole owner of your personal data and can request disclosure or deletion at any time.

Exercising these rights will not result in discrimination against you. To make a request, email us at the address in Section 10.

These rights are covered by the California Consumer Privacy Act (CCPA). For more information, visit the official California Legislative Information website.

Miscellaneous

You are responsible for keeping your password and login details confidential. Do not share this information with anyone.

Some sections of our App may contain links to other websites. We are not responsible for the privacy policies or practices of those websites.

We may update this Privacy Policy from time to time and will inform you of any changes so you can review them.