Last updated: 22 Nov 2024

1. Introduction
LiberatinInMind (“we,” “our,” or “us”) is committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data, and how to exercise your rights, when you use our website (“Site”) and mobile application (“App”). By accessing or using the App and Site, you agree to this Privacy Policy.

2. Data Controller

LiberationInMind is the data controller responsible for the processing of your personal data as described in this Privacy Policy.

3. Information We Collect

3.1 We may collect the following types of personal data:

(a) Personal Identification Information: Includes your name, email address, phone number, postal address, and username and password account information for registered users.

(b) Usage Data: Information about how you interact with the App and Site, including IP address, device type, browser type, operating system, access times, and pages viewed.

(c) Location Data: Information about your location if you have provided consent for location tracking on your device.

(d) Cookies and Tracking Technologies: Information collected through cookies, pixel tags, and other tracking technologies that collect information about your interactions with our Site and App.

(e) Transaction and Payment Information (if applicable): Purchase history and payment details, such as payment method (credit card details are collected and processed through third-party payment processors).

(f) Analytics Information: Data collected through analytics services like Google Analytics and Firebase, which includes anonymized or pseudonymized data related to how users engage with the App and Site.

(g) Communications Data: Any communications you send to us, such as email inquiries, feedback, or customer support requests.

(h) Marketing and Advertising Preferences: Data about your preferences for receiving marketing communications and details about your engagement with promotional materials.

4. How We Use Your Data

4.1 We process your personal data based on the following legal grounds:

(a) Performance of a Contract: To fulfill our contractual obligations, such as providing the App and Site features, services, and customer support.

(b) Legitimate Interests: To improve our services, enhance user experience, and analyze the usage of our App and Site.

(c) Consent: Where required by law, we will obtain your consent before collecting sensitive data (e.g., location or marketing preferences).

(d) Legal Obligations: To comply with legal obligations, regulatory requirements, or to respond to lawful requests from public authorities.

5. Google Analytics

5.1 We use Google Analytics to collect information about your interactions with our App and Site, such as pages viewed, time spent on the Site, referring URLs, and other website performance metrics. Google Analytics helps us understand how visitors use our Site and improve user experience.

5.2 Google Analytics uses cookies and similar tracking technologies to collect and store information. These cookies track how users interact with the Site and provide us with reports about Site activity and website performance.

5.3 How Google Uses Data: Google may collect data about your IP address, browser type, operating system, referring URL, device type, and other metrics related to your interaction with our App and Site. This data is processed in accordance with Google’s own Privacy Policy, which can be found at Google Privacy Policy.

5.4 Opting Out of Google Analytics: You can opt-out of Google Analytics tracking by using the Google Analytics Opt-Out Browser Add-on, available at Google Analytics Opt-Out. This add-on prevents your data from being collected and used by Google Analytics when visiting websites.

5.5 We use Google Analytics in compliance with the GDPR, and any personal data collected by Google Analytics is anonymized to protect your privacy.

6. Firebase

6.1 We use Firebase, a development platform by Google, to enhance the performance and functionality of our App and Site. Firebase helps us with a variety of services including but not limited to:

(a) Firebase Analytics: Provides insights into user engagement, behavior, and other app performance metrics.

(b) Firebase Crashlytics: Helps track and resolve technical issues by collecting real-time crash data, which allows us to identify and fix bugs.

(c) Firebase Cloud Messaging: Enables us to send push notifications to users about important updates, offers, or events.

6.2 Firebase may collect information such as your device ID, app usage data, IP address, and crash reports. Firebase Analytics may also use anonymized information to provide insight into the behavior of users on the App.

6.3 How Firebase Uses Data: The data collected by Firebase may be stored on Google’s servers, which are located in the United States and other countries. You can learn more about Firebase’s privacy practices at Firebase Privacy and Security.

6.4 Opting Out of Firebase Analytics: You can opt-out of Firebase Analytics by adjusting your device settings or by following instructions provided in your device’s operating system.

6.5 We use Firebase in compliance with GDPR, and all data collected via Firebase services is treated with the highest standards of privacy and security.

7. How We Share Your Data

7.1 We may share your personal data in the following ways:

(a) With Service Providers: We may share your data with third-party service providers who assist us in operating the App, Site, and our business (e.g., hosting services, analytics providers, including Google and Firebase

(b) For Legal Reasons: If required by law, we may disclose your data to comply with legal obligations, court orders, or to defend legal claims.

(c) With Consent: We may share your personal data with third parties if you have provided explicit consent.

8. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Once the retention period has expired, we will securely delete or anonymize your data.

9. Your Rights

9.1 General Rights:

(a) Access, correct, or delete your personal data.

(b) Opt out of marketing communications.

(c) Restrict or object to data processing.

9.2 Your Rights Under GDPR:

If you are a resident of the European Economic Area (EEA), you have the following rights under the GDPR:

(a) Right to Access: You have the right to request access to the personal data we hold about you.

(b) Right to Rectification: You can request that we correct or update any inaccurate or incomplete personal data.

(c) Right to Erasure: You can request that we delete your personal data, subject to certain legal obligations.

(d) Right to Data Portability: You have the right to request that we provide your personal data in a structured, commonly used, and machine-readable format.

(e) Right to Restrict Processing: You can ask us to restrict the processing of your personal data in certain circumstances.

(f) Right to Object: You have the right to object to the processing of your personal data where processing is based on legitimate interests or for direct marketing purposes.

(g) Right to Withdraw Consent: If we process your data based on your consent, you can withdraw this consent at any time.

9.3 Your Rights Under California Consumer Privacy Act (CCPA):

If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

(a) Categories of Personal Information We Collect. We may collect the following categories of personal information, as defined under the CCPA:

(i) Identifiers: Name, email address, phone number, IP address, device ID, or similar identifiers.

(ii) Commercial Information: Records of products or services purchased or considered.

(iii) Internet or Network Activity: Browsing history, interaction with our Site or App.

(iv) Geolocation Data: Approximate physical location.

(v) Professional Information: Job title, employer details (if provided during registration or inquiries).

(vi) Inferences: Derived preferences or characteristics based on your usage of our Services.

(b) You have the following rights under the CCPA:

(i) Right to Know. You can request that we disclose the following: the categories of personal information we collect about you, the specific pieces of personal information we hold about you, the purposes for which we use your personal information, the categories of third parties with whom we share your personal information, any sale of personal information, if applicable.

(ii) Right to Delete. You have the right to request that we delete any personal information we have collected about you, subject to certain exceptions, such as: completing transactions or providing services you requested, detecting security incidents, protecting against fraud, or ensuring legal compliance.

(iii) Right to Opt-Out of Sale or Sharing. You have the right to opt-out of the sale or sharing of your personal information. “Sale” Definition: The exchange of personal information for monetary or other valuable consideration.

(iv) Right to Correct. You can request that we correct inaccurate personal information about you.

(v) Right to Limit Use of Sensitive Personal Information. You may restrict how sensitive personal information is used, such as for targeted advertising or profiling.

(vi) Right to Non-Discrimination. We will not discriminate against you for exercising your CCPA rights. For example, we will not: deny you goods or services, charge you different prices or rates, provide a different level or quality of services unless permitted by law.

(c) Sale of Personal Information. We do not sell your personal information as defined under the CCPA. If this practice changes, we will update this Privacy Policy and provide a mechanism to opt-out.

(d) Sensitive Personal Information. Under the CCPA/CPRA, we do not collect or process sensitive personal information for purposes beyond those allowed under the law, such as performing Services or complying with legal requirements.

(e) Authorized Agents. If you wish to designate an authorized agent to make requests under the CCPA on your behalf, please provide the agent with written permission, and ensure they can verify their identity and your authorization.

9.4 To exercise your rights, you can contact us using the contact information provided below:

Mailing Address: LiberationInMind, 124 City Road, London EC1V 2NX, United Kingdom

Email: support@liberationinmind.com

Response Time and Process: We will acknowledge your request within 10 business days. We will respond to your request within 45 calendar days of receipt. If additional time is needed (up to 90 days), we will notify you with the reason for the delay.

9.5 You also have the right to lodge a complaint with your local data protection authority.

10. International Data Transfers

We may transfer your personal data to countries outside of the EEA. If we do so, we will ensure that appropriate safeguards are in place to protect your data, such as using the European Commission’s Standard Contractual Clauses or transferring data to companies certified under the EU-US Privacy Shield.

11. Security of Your Data

We take appropriate technical and organizational measures to ensure that your personal data is treated securely and protected against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure.

12. Cookies and Tracking Technologies

We use cookies and similar technologies on our App and Site to enhance user experience, analyze traffic, and personalize content. You can manage your cookie preferences through your browser settings or through our cookie consent banner. For more information on the types of cookies we use and your choices regarding them, please review our Cookie Policy.

13. Third-Party Links

Our App and Site may contain links to third-party websites. We are not responsible for the privacy practices or content of these websites. We encourage you to review the privacy policies of third-party sites before providing any personal information.

14. Children’s Privacy

Our App and Site are not intended for children under the age of 18 years, and we do not knowingly collect personal data from children under 18 years. If we discover that we have inadvertently collected such data, we will delete it promptly.

15. Changes to this Privacy Policy

We reserve the right to modify Privacy Policy at any time, in response to legal, technical, or business developments. Changes will be effective upon posting. It is your responsibility to review this Privacy Policy periodically for any updates. Your continued use of this Site or App after the changes have been made will constitute your acceptance of the revised Privacy Policy.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, you can contact us at:

Mailing Address: LiberationInMind, 124 City Road, London EC1V 2NX, United Kingdom

Email: support@liberationinmind.com