Introduction

This Privacy Policy explains what information Mindo(“Mindup,” “we” or “us”) collect and receive from Account Holders and End Users (“you”) through Mindup’s websites and applications, which we refer to collectively as “the Service.” The Service includes the Mindo Software.

Please note, if you use Mindo, or with In-App Purchase functions, you are both the Account Holder and End User of a Mindo service account.

Although significant changes are rare, this policy may be amended as new features, technology, or legal requirements arise, so please check back from time to time. We’ll notify you if we make a significant change and, where required, seek your consent.

What information does Mindo collect and receive?

We built Mindo to help you remember and organize your ideas, thoughts, and memories. That means you can input, upload, or store in Mindo any text, images, and other data that you choose (collectively, “Content”). We also collect and receive the following types of information:

• Basic subscriber information. To open your account and process payments, we collect and receive basic information like your email address and, depending on how you purchase a subscription to Mindo In-App Purchase, your billing address and other payment information.

• Log data. When you use Mindo, we collect data to understand how you and others access and use the Service, as well as information about actions you take when using the Service (such as the act of creating a note or sharing a note). This information helps us provide the Service to you, learn how the Service is used, and identify and suggest ways we can make the Service more useful to you.

• Location information. We collect the IP address you use to connect to the Service, and — if you choose to share it — your location information from a mobile device. This helps us localize the Service for you and, depending on your location settings, allows us to show you relevant content accessible from your account.

• Device information. We collect information about the number and type of devices you use to connect to the Service, as well as information about the operating systems on those devices (e.g., iOS, Android, Windows) to ensure the Service works as expected for you.

We also may link your subscriber information with data we receive from our partners and other third parties to help understand your needs and provide you with a better experience. For example, if you create or log into an Mindo account using your Google Apps credentials via single sign-on, we will have access to certain information such as your name and email address as authorized in your Google Apps profile settings.

How does Mindo use my information?

We have specific rules for how and when we use the information we collect and receive. We describe these below.

What does Mindo do with my information?

We are committed to protecting the privacy of your information. Below, we describe the ways in which we use the information we collect and receive to provide, maintain, and improve the Service; to provide troubleshooting and customer support; to protect the Service for all our users; to contact you; and to administer Mindo accounts.

◦ Making sure you find what you’re looking for when you search your account.

◦ Showing you information most relevant to how you are or could be using the Service at a specific time or location.

◦ Suggesting actions for you to take based on information you’ve stored.

◦ Suggesting Mindo service features or products to you that we think will help you get the most out of our Service.

◦ Recommending people for you to collaborate with.

• To provide troubleshooting and customer support, our Customer Support team may need to access your information, such as your account email address and information about the Mindup application you are using, subject to the protections described above.

• As part of our efforts to protect your account and the functionality of the Service, our systems may analyze the emails you send to and from your Mindo account and the notes you share to detect spam, malware, or other potential security concerns.

• We use a number of technologies to help you get the most out of the Service. Our systems automatically analyze your data to power Mindo features and to continually improve the Service for you in a way that does not require anyone to look at your Content. This may include, for example: Making sure you find what you’re looking for when you search your account. Showing you information most relevant to how you are or could be using the Service at a specific time or location. Suggesting actions for you to take based on information you’ve stored. Suggesting Mindo service features or products to you that we think will help you get the most out of our Service. Recommending people for you to collaborate with. To provide troubleshooting and customer support, our Customer Support team may need to access your information, such as your account email address and information about the Mindup application you are using, subject to the protections described above. As part of our efforts to protect your account and the functionality of the Service, our systems may analyze the emails you send to and from your Mindo account and the notes you share to detect spam, malware, or other potential security concerns. In accordance with your communication preferences, we’ll occasionally contact you to announce new products and features we build for you, share tips for using Mindo to get more done, make special offers, and provide information about how Mindo works with products and services from our business partners.

Would someone at Mindo ever view my Content?

You have control over who sees your Content. We limit the use of your Content to make sure that no one at Mindo can view it unless you expressly give us permission or it’s necessary to comply with our legal obligations. Specifically:

• To help refine or improve the technology, we may ask you for permission to review portions of your Content. For example, if a new feature suggests related notes that are relevant to your Content, we may give you an opportunity to provide us feedback on how well the feature is performing along with a sample of the Content in question, so we can make sure this feature provides appropriately tailored suggestions. Such access to your Content is done only with your express permission and is subject to strict confidentiality rules and data access controls. Choosing to give us such permission is completely voluntary. If you contact our Customer Support team for help with specific pieces of Content in your account (for example, if you can’t find a note you believe should be in your account), we may ask for your temporary permission to look at your Content. This permission terminates when the issue is resolved.

To test and improve our product offerings for our users, we use aggregated data that does not contain any personal information, does not identify any person, and cannot be connected to any specific user. This policy is not intended to apply to such anonymized/de-identified data.

How does Mindo share or disclose my information?

Mindo is not in the business of selling or renting your information. Here are instances when we may disclose your information — and then only the minimum information necessary:

• We share your information with Service Providers who process data on our behalf, such as credit card processors and customer management systems. For example, these Service Providers help us:

◦ Operate, develop, and improve the features and functionality of the Service

◦ Complete your payment transactions

◦ Fulfill your sales and support requests

◦ Communicate with you as described elsewhere in this policy

We require these providers to agree to strict data protection requirements in keeping with our privacy policy standards and our commitments under our EU-US Privacy Shield and Swiss-US Privacy Shield certifications as discussed below.

We do not share your information with any third parties for their own advertising purposes.

• Your Content is private unless you decide you want to share it. You may choose to share using public links or through any of the Service’s features that allow you to share or collaborate on Content (“Collaboration Features”). If you choose to share, we may need to take steps to facilitate your collaboration.

• In the event of a merger, sale, or reorganization of all or part of our business, information covered by this policy may be transferred in connection with that deal.

How does Mindo respond to legal requests for my information?

We vigilantly protect the privacy of your account. We will not disclose your information to law enforcement or other governmental authorities unless we believe it is required to comply with warrants, court orders, subpoenas, or other lawful government requests. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards of due process.

We narrowly interpret all information requests, and we only disclose Content in your account that is specifically responsive to a government warrant or where you have provided your explicit consent.

In addition, in rare cases, we may share your information as necessary to investigate or take action regarding illegal activities, suspected fraud, or potential threats against persons, property or the systems on which we operate the Service, or as otherwise necessary to comply with our legal obligations.

How can I manage my information stored in Mindo?

Consistent with our first law of data protection—your data is yours—in most cases, you can manage your information simply by logging into your account and editing your information directly within the Mindo service.

However, if you prefer, you can contact us at nuix74@icloud.com to ask us to provide access to, correct, update, or delete your personal information. Please note that we may ask you for proof of account ownership and/or identity before fulfilling your request. We will comply with such requests to the extent required by applicable law or the US-Swiss Privacy Shield and US-EU Privacy Shield.

What happens if I want to stop using Mindo?

You can delete your Content at any time, and you can stop using the Mindo service at any time.

If you delete your Content and then sync, it will no longer be accessible to you or others who may access the Service.

Mindo provides you with features that allow you to communicate and collaborate with other users. Please note that deleting your copy of these communications (such as messages) won't delete copies existing in the accounts of people you were interacting with.

What happens if Mindo closes my account?

If Mindo deactivates your account due to a TOS violation, then you may contact us to request deletion of your Content, and we will evaluate such requests on a case by case basis, pursuant to our legal obligations.

Where does Mindo store my information?

When you use Mindo Software on your computing device, such as by using one of our downloadable applications, some of your data will be stored locally on that device.

When you sync your computing device with the Service, that data will be replicated on servers maintained in the China. This means that if you store information in or submit data to the Mindo website or Mindo Software and sync such Mindo Software with the Mindo service, you acknowledge your personal information will be transmitted to, hosted, and accessed in the China.

Data privacy laws or regulations in your home country may differ from those in the China. We will collect, store, and use your personal information in accordance with this Privacy Policy and applicable laws, wherever it is processed.

Which Mindo company is my data controller?

Your data controller is China-based Mindo.

How does Mindo comply with data transfer rules?

If you are a resident of the European Economic Area (“EEA”) or Switzerland, please note that we use standard contractual clauses approved by the European Commission to transfer your personal Information from the EEA or Switzerland to the China and other countries.

How can I contact Mindo?

Mindo welcomes your feedback regarding this Privacy Policy. If you have questions, comments or concerns about this Policy, please contact us by email at nuix74@icloud.com

GLOSSARY

• Account Holder means the person or entity who has contracted with Mindo as either an individual Basic or In-App Purchase user.

• Collaboration Features means any of the Service’s features that allow you to share or collaborate on Content.

• Content means the text, images, and other data you choose to input, upload, and store in Mindo.

• End User means the individual who uses an account on the Mindo service.

• Mindo (or sometimes “we” or “us”) means Mindo developers.

• Mindo Service means the Mindo Software (as defined below) and other products, services and websites hosted or made available by Mindo, including our downloadable applications, App Center, User Forum, and Help & Learning pages.

• Mindo Software means the software hosted on Mindo’s servers and the software we make available to be deployed by you.

• Paid Service means Mindo In-App Purchase offering for which we collect payment (in the form of currency, Mindo points, coupon codes).