PRIVACY POLICY

Introduction

Thank you for the Mindfly application for mobile phones, tablets and similar portable devices (�<= i>Application�). The Application is owned and operated by Mindfly Ltd., which is referred to= in this privacy policy as �we�, �us� or �our�, as the context requires. For the purpose of this policy the term �Service� refers to any service provided by= us through the Application. The term �you� (and �your�, as applicable) refers to you, = the individual user of the Service.

The purpose and scope of this privacy policy

The term �personal data� refers to information that r= elates to you as an identified or identifiable individual.

This privacy policy explains what type of personal da= ta we collect from or about you when you access or visit the Service, why and how= we use it and the rights you have over your personal data. In collecting perso= nal data, we are acting as a data controller under law.

We collect and process personal data about you with y= our consent, in order to meet our contractual obligations to others, comply with our obligations under applicable law, protect and exercise our legal rights= , where necessary to operate, maintain optimize and improve the Service, carry out = our business operations, protect the security of our systems and the privacy of= our customers, and otherwise protect or further our legitimate interests. Where= we process your personal data based on our legitimate interest, we will only d= o so where the processing is relevant, adequate and limited to the minimum requi= red in order to achieve the purpose for which the information is collected.

To better protect your privacy, we advise you to care= fully read this privacy policy before accessing or using the Service. Please note that by accessing or using the Service, you represent that you have read th= is privacy policy, understand it and agree to its terms.

What personal data do we collect and why?

Creating and Managing an Acc= ount

You can register to the Service by creating a user ac= count. If you do so, we will ask you for your first and last name and your email address. You can choose not to register but creating an account will entitle you to certain benefits which non-registered users do not enjoy.

You can also register to the Service through your Fac= ebook or Google account. If you do so, the operator of the applicable platform will = share with us certain personal data, such as your email, user name and similar information, in accordance with its practice and policies. We encourage you= to review the third-party service operator�s privacy policy for more infor= mation concerning the types of personal data it shares with us. =

You can also register with your email account, in whi= ch case we will ask you for your email address and password.

Once you create a user account, your contact informat= ion will be stored in your account and you may edit and manage them through your acc= ount settings.

You can close your account at any time by sending us = an email to _________________, in w= hich case we will deactivate your account. However, we may retain in our files s= ome information associated with your account and past transactions for purposes= of backups, fraud prevention, dispute resolution, investigations, and complian= ce with legal requirements.

�Newsletters=

If you subscribe to our newsletters, we will ask you = for your name and your email address. We will use your information to send you = our newsletters, which contain important information about our Service. If you reside in the European Economic Area, we will ask for your consent to do th= is, and we will only send you our newsletters for as long as you continue to consent. You can update your email subscription ch= oices at any time by changing the Service�s privacy settings.

You can unsubscribe from receiving newsletters by fol= lowing the unsubscribe instructions in any email you receive from us. Please note = that even if you unsubscribe from our newsletters, we may still need to contact = you with important administrative, privacy and security information related to = your account and your use of the Service, without offering you the opportunity to opt out of receiving them.

Location

When you use the Application = on a mobile phone or other portable device, we may collect information concerning your location, provided the privacy settings on your portable device allow sharing of such location information with the Application. You can change t= he privacy settings on your device or disable the location services in the Application at any time.

Billing and Payment

The Service may include offerings of products and ser= vices which may be of interest to you. These products and services are provided by third-party suppliers and we do not guarantee and= are not responsible for the quality, safety or legality of these products or servic= es.

The Application enables you to purchase some of those= products or services. If you do so, we will collect from you certain billing and pay= ment information, such as your name, address, telephone number, email address and credit card information. We will then transmit this information to the thir= d-party supplier who will verify your credit card details and process your payment.= We do not retain any billing or payment information and we do not process any payments.

Other than expressly set out in this section, this pr= ivacy policy does not cover the collection or processing of data by such third-pa= rty suppliers and we do not control and are not responsible for the information that you submit or is otherwise collected or processed by them or for their privacy statements. You are encouraged to carefully read the privacy policies and t= he terms of use of those third-party suppliers.

Cookies and Tracking

When you use the Service we automatically collect you= r IP address and information concerning your online activities, such as the devi= ce and browser information, the pages you visit and the content you view.

We also use certain tracking technologies such as coo= kies, web beacons, or third-party analytics tools to obtain such information.

A 'cookie' is text file that stores the IP address of= your computer or portable device and enables tracking your preferences by showing which websites you visit. We use cookies to recognize your access to the Service as a previous visitor, track your browsing history, learn through where you arrived at the Service, understand your usage of the Service and improve, customize and ad= just the content of the Service and your user experience. You can set most brows= ers to notify you if you receive a cookie, or you may choose to block cookies w= ith your browser, but if you do, you may not be able to take advantage of the personalized features enjoyed by other users of the Service or will not be = able to access or use certain parts of the Service.

A �web beacon� is a graphic image that often interact= s with cookies and is generally used to monitor the behaviour of the Service�s use= rs. Similar to cookies, we use web beacons to monitor your use of and interaction with = the Service and to enhance and personalize your user experience.

We may use �Google Analy= tics� and other business analytics service providers to provide us with analytics= concerning the Service and user behaviour. These service providers may collect your us= age information, IP address, browser information, device type, and similar pers= onal data with respect the various browsers and devices you use to access and use the Service.

What do we do with personal data?

We use personal data for the following purposes:=

In general, providing, operating, maintaining, supporting= , hosting, enhancing and improving the Service and your user experience

creating and maintaining your user account

providing customer support

providing you with information, through our newsletters or through other means of electronic communications, in connection with y= our use of the Service including general Service information, transaction confirmations concerning services or products you purchased from third= -party suppliers, notices relating to administrative, security or privacy iss= ues, updates concerning new features and functionalities, special offerings etc.

facilitating transactions you engaged with third-party suppliers through the Application, including transferring your billing= and payment information to such third-party suppliers
tracking, measuring and analysing your use of the Service= for the purpose of improving the service and personalizing and customizing your use experience

targeting and presenting you with content and third-party= products and services that may be of interest to you

complying with legal obligations, court orders or other l= egal process and instructions of competent authorities
exercising or protecting our rights in contract or by law= (including in any dispute resolution process) or the rights of our users or busin= ess partners, including enforcing our terms of use and preventing or protecting against any illegal or authorized activities

We do not use the information you provide to make any aut= omated decisions that might affect you.

With whom do we share personal data?

We share person= al data as set out in this privacy policy. We also share your personal data in= the following circumstances and with the following entities:<= /p>

With your explicit consent.

As may be required by law or to comply with a court order= or other legal process.

As may be required to exercise or protect our rights in contract or by law (including in any dispute resolution process) or the rights of our users or business partners, including enforcement of our terms of use or investigating, preventing or protecting against illega= l or authorized activities.

In connection with a corporate transaction, such as merge= r, acquisition, asset sale or a similar evet.

With third parties (service users and non-users) to the e= xtent that you have elected to share your information through the use of a t= hird party application (such as Facebook or WhatsApp).
With third party suppliers, for the purpose of presenting= you with products and services that may be of interest to you.<= /span>

With our third-party vendors, consultants, advisors and o= ther service providers that are working on our behalf or provide services t= o us and need to collect, access, store and/or process personal data for the sole purpose of providing us with specific services related to the Ser= vice or use of the Service, such as our hosting provider and our marketing services provider.

In an aggregated and anonymized form that will not identi= fy you.

How long do we keep personal data for?

We keep your personal d= ata for no longer than is necessary for fulfilling the processing purposes set out = in this policy.

We have different reten= tion policies for different types of personal data. The retention period is dict= ated by certain factors, such as the type of personal data, the purpose for which the data was collected, the legal basis permitting us to collect and store = it, statutory requirements, industry guidelines, our legitimate interests in providing the Services or protecting our legal rights etc.

We constantly asses the storage periods in order to ensure that we do not keep your personal data m= ore than is absolutely necessary for processing purposes. When we no longer hav= e a legitimate reason or legal requirement to process your personal data, we will delete i= t or store it in an anonymized and aggregated manner that no longer identifies y= ou.

In addition, if you hav= e an account with us, we will keep your personal data for as long as you have an account.

Transferring your personal data outside of the European Economic Area (EEA)

We use third parties� h= osting services to store your personal data. In accordance with such providers� po= licies, your personal data may be transferred to, stored, and processed in countrie= s where data centres are located. We have taken steps to ensure such transfer, processing or storage of will be subject to the implementation of appropria= te safeguards (such as, data protection clauses).

Your personal data may = also be transferred to, stored, and processed in Israel, pursuant to EU Commissi= on decision of 31 January, 2011 (2011/61/EU) (see https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=3DCELEX%3A32011D= 0061).

Your rights over personal data

By law= , you can ask us what personal data we hold about you, and you can also ask us to cor= rect it if it is inaccurate. You can also ask for it to be erased and you can ask for us to give you a copy of the information. Under certain circumstances, = you also have a right to object to the collection or processing of your personal dat= a.

Where = processing of personal data is based on your consent, you have the right to withdraw consent at any time for future processing.

If you= have a complaint about our use of your personal data, you have a right to lodge a complaint with an applicable data protection authority.

If you= wish to access, correct, erase or object to the collection or processing of your personal data held by us, or make other inquiries in this respect, please contact our data protection officer at ______________.

Contact us

You ca= n contact us by email at _______________.

Con= nections and links to other services and applications

The Service may include links and connections to thir= d-party services and applications. We have no control over and are not responsible = for the information that is submitted to, collected or processed by such third-= party services or applications and this privacy policy does not cover any data collection or processing by such third-party services or applications. You = are encouraged to carefully read the privacy policies and the terms of use of t= hose third-party services or applications to understand their procedures for collecting, using, and disclosing personal data.

Sec= urity

We maintain data security procedures and systems that are designed t= o ensure the integrity and confidentiality of your personal data. However, you acknowledge that transmission or sto= rage of data over the Internet is not guaranteed to be 100% secure. Accordingly, we cannot and do not guarantee absolute security of your personal data.

Cha= nges to this policy

We reserve the right to change this privacy policy fr= om time to time. When we do, we will also revise the "last updated" = date at the bottom of this page. If we make significant changes, we will notify = you upon your next access to the Service or by other means. Your continued use = of the Service after we make changes is deemed to be acceptance of those chang= es, so please check the policy periodically for updates.

Eff= ective Date: [� ]

Las= t Updated: [�� ]