MindDrops

# Privacy Policy **Last Updated:** January 23, 2026 **Effective Date:** January 23, 2026 --- ## 1. Introduction APP DEV MASTERS LTD ("we," "us," "our," or the "Company") operates the MindDrops mobile application (the "App" or "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our App. We are committed to protecting your privacy and complying with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), the California Consumer Privacy Act (CCPA), and other relevant privacy legislation. **Company Details:** - **Company Name:** APP DEV MASTERS LTD - **Company Number:** 14989815 - **Registered Address:** 3 Etloe Road, Bristol, England, BS6 7PG - **Contact Email:** info@appdevmasters.com By using the App, you consent to the data practices described in this Privacy Policy. If you do not agree with this policy, please do not use the App. --- ## 2. Data Controller APP DEV MASTERS LTD is the data controller responsible for your personal data. For any questions regarding this Privacy Policy or our data practices, please contact us at: **Email:** info@appdevmasters.com **Address:** 3 Etloe Road, Bristol, England, BS6 7PG --- ## 3. Personal Data We Collect ### 3.1 Information You Provide Directly | Data Category | Data Elements | Purpose | |---------------|---------------|---------| | **Account Information** | Email address, display name (optional, via Sign in with Apple) | Account creation and authentication | | **User Content** | Topics you request for audio lessons | Content generation | | **Preferences** | Voice selection, delivery style, playback speed, language | Personalizing your experience | | **Communication** | Messages you send to our support team | Customer support | ### 3.2 Information Collected Automatically | Data Category | Data Elements | Purpose | |---------------|---------------|---------| | **Device Information** | Device type, operating system version, app version | App functionality and troubleshooting | | **Usage Data** | Features used, playback progress, lesson completion status | Service improvement and analytics | | **Push Notification Tokens** | Firebase Cloud Messaging (FCM) device token | Delivering push notifications | | **Analytics Data** | App interactions, feature usage, error logs | Service improvement | ### 3.3 Information from Third Parties | Source | Data Elements | Purpose | |--------|---------------|---------| | **Apple (Sign in with Apple)** | User ID, email (if shared), name (if shared) | Account authentication | | **Apple App Store** | Transaction IDs, subscription status | Processing purchases | --- ## 4. How We Use Your Personal Data We process your personal data for the following purposes: ### 4.1 Service Provision (Contract Performance) - Creating and managing your account - Generating personalized audio lessons based on your topics - Delivering scheduled lessons according to your preferences - Processing in-app purchases and subscriptions - Syncing your playback progress across sessions ### 4.2 Communication (Contract Performance & Legitimate Interests) - Sending push notifications about completed lessons - Delivering topic suggestions you've opted into - Responding to your support inquiries - Sending service-related announcements ### 4.3 Service Improvement (Legitimate Interests) - Analyzing usage patterns to improve app features - Identifying and fixing technical issues - Developing new features based on user behavior ### 4.4 Legal Compliance (Legal Obligation) - Complying with applicable laws and regulations - Responding to lawful requests from authorities - Protecting our legal rights and interests --- ## 5. Legal Basis for Processing (GDPR) Under the GDPR, we process your personal data based on the following legal grounds: | Legal Basis | Processing Activities | |-------------|----------------------| | **Contract Performance** | Account management, lesson generation, purchase processing, playback syncing | | **Consent** | Push notifications, topic suggestions, marketing communications | | **Legitimate Interests** | Analytics, service improvement, fraud prevention, security | | **Legal Obligation** | Tax records, responding to legal requests | You may withdraw consent at any time by adjusting your notification preferences in the App settings or contacting us directly. --- ## 6. Third-Party Services and Data Sharing We share your data with the following categories of third-party service providers: ### 6.1 Cloud Infrastructure and Backend Services **Firebase (Google LLC)** - **Purpose:** Authentication, database storage, file storage, push notifications, cloud functions - **Data Shared:** Account information, lesson data, FCM tokens, audio files - **Location:** Google Cloud servers (US and EU regions) - **Privacy Policy:** https://firebase.google.com/support/privacy ### 6.2 Artificial Intelligence Services **OpenAI, Inc.** - **Purpose:** Generating lesson content and converting text to speech - **Data Shared:** Topic text you provide, selected voice and delivery style preferences - **Processing:** Data is processed by OpenAI's API to generate educational content and audio - **Location:** United States - **Privacy Policy:** https://openai.com/privacy - **Note:** OpenAI processes data to provide the service but does not use API data to train models as of their current terms ### 6.3 Analytics **Mixpanel, Inc.** - **Purpose:** Understanding app usage and improving the service - **Data Shared:** User interactions, feature usage, app version, your Firebase user ID (for session continuity) - **Automatic Tracking:** When analytics is enabled, Mixpanel automatically tracks app opens, sessions, and basic usage patterns - **Location:** European Union (EU data residency) - **Opt-Out:** You can disable analytics at any time in Settings > Privacy & Legal > Usage Analytics - **Privacy Policy:** https://mixpanel.com/legal/privacy-policy **Note:** When you disable analytics, we immediately stop collecting usage data. Previously collected data is retained according to our retention policy (24 months) and can be deleted upon request. ### 6.4 Payment Processing **Apple Inc.** - **Purpose:** Processing in-app purchases and subscriptions - **Data Shared:** Transaction data is processed directly by Apple - **Privacy Policy:** https://www.apple.com/legal/privacy ### 6.5 Push Notifications **Apple Push Notification Service (APNs)** - **Purpose:** Delivering push notifications to your device - **Data Shared:** Notification content, device tokens We do not sell your personal data to third parties. --- ## 7. International Data Transfers Your personal data may be transferred to and processed in countries outside the United Kingdom and European Economic Area, including the United States, where our service providers operate. When transferring data internationally, we ensure appropriate safeguards are in place: - **Standard Contractual Clauses (SCCs):** We use EU-approved SCCs with service providers - **Data Processing Agreements:** We have agreements with all processors requiring GDPR-equivalent protections - **Privacy Shield Successors:** Where applicable, we rely on approved frameworks You can obtain a copy of the safeguards by contacting us at info@appdevmasters.com. --- ## 8. Data Retention We retain your personal data only as long as necessary for the purposes outlined in this policy: | Data Category | Retention Period | |---------------|------------------| | **Account Information** | Until you delete your account | | **Audio Lessons** | Until you delete them or your account | | **Playback Progress** | Until you delete the lesson or your account | | **Analytics Data** | 24 months from collection | | **Purchase Records** | 7 years (legal requirement) | | **FCM Tokens** | Until you sign out or delete your account | | **Support Communications** | 3 years from resolution | When you delete your account, we delete or anonymize your personal data within 30 days, except where retention is required by law. --- ## 9. Your Data Protection Rights Depending on your location, you may have the following rights regarding your personal data: ### 9.1 Rights Under GDPR (UK and EU) | Right | Description | |-------|-------------| | **Access** | Request a copy of your personal data | | **Rectification** | Request correction of inaccurate data | | **Erasure** | Request deletion of your data ("right to be forgotten") | | **Restriction** | Request limitation of processing | | **Data Portability** | Receive your data in a machine-readable format | | **Object** | Object to processing based on legitimate interests | | **Withdraw Consent** | Withdraw previously given consent at any time | | **Lodge Complaint** | File a complaint with a supervisory authority | ### 9.2 Rights Under CCPA (California Residents) - Right to know what personal information is collected - Right to know if personal information is sold or disclosed - Right to opt-out of the sale of personal information (we do not sell data) - Right to request deletion of personal information - Right to non-discrimination for exercising your rights ### 9.3 How to Exercise Your Rights **In-App:** - Delete your account: Settings > Delete Account - Manage notifications: Settings > Notifications - Delete lessons: Library > Select Lesson > Delete - Disable analytics: Settings > Privacy & Legal > Usage Analytics (toggle off) **Contact Us:** - Email: info@appdevmasters.com - Subject: "Data Protection Request - [Your Request Type]" **Data Export:** To request a copy of your data in a machine-readable format, please contact us at info@appdevmasters.com with the subject "Data Export Request". We will respond to valid requests within 30 days (or 45 days for complex requests, with notice). --- ## 10. Data Security We implement appropriate technical and organizational measures to protect your personal data: ### Technical Measures - **Encryption in Transit:** All data transmitted uses TLS/HTTPS - **Encryption at Rest:** Data stored in Firebase is encrypted at rest - **Access Controls:** Role-based access controls for staff - **Secure Authentication:** Sign in with Apple for secure account access ### Organizational Measures - **Data Processing Agreements:** With all service providers - **Security Training:** For personnel handling personal data - **Incident Response:** Procedures for handling data breaches - **Regular Audits:** Of security practices and access logs While we strive to protect your data, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security. --- ## 11. Children's Privacy The App is not intended for children under 13 years of age (or 16 in certain jurisdictions). We do not knowingly collect personal data from children under these ages. If we discover that we have collected personal data from a child under the applicable age, we will delete it promptly. If you believe a child has provided us with personal data, please contact us at info@appdevmasters.com. --- ## 12. Push Notifications We use push notifications to: - Notify you when your audio lessons are ready - Deliver scheduled lessons - Send topic suggestions (if enabled) You can manage notification preferences: - **In the App:** Settings > Notifications - **On Your Device:** iOS Settings > MindDrops > Notifications --- ## 13. Cookies and Similar Technologies The App itself does not use cookies. However, our third-party service providers may use similar technologies: - **Firebase Analytics:** Uses device identifiers for analytics - **Mixpanel:** Uses anonymized identifiers for event tracking You can reset your device advertising identifier through your iOS Settings. --- ## 14. Third-Party Links The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal data. --- ## 15. Changes to This Privacy Policy We may update this Privacy Policy from time to time. We will notify you of material changes by: - Posting the updated policy in the App - Updating the "Last Updated" date - Sending a push notification for significant changes Your continued use of the App after changes constitutes acceptance of the updated policy. --- ## 16. Supervisory Authority If you are located in the UK or EU and believe we have not adequately addressed your data protection concerns, you have the right to lodge a complaint with your local supervisory authority: **UK:** Information Commissioner's Office (ICO) Website: https://ico.org.uk Phone: 0303 123 1113 **EU:** Contact your local Data Protection Authority --- ## 17. Contact Us For any questions, concerns, or requests regarding this Privacy Policy or our data practices: **APP DEV MASTERS LTD** 3 Etloe Road Bristol, England, BS6 7PG United Kingdom **Email:** info@appdevmasters.com --- ## 18. Summary of Key Points - We collect account information, usage data, and content you create - We use your data to provide and improve the Service - We share data with Firebase (Google), OpenAI, Mixpanel, and Apple - Your data may be transferred to the US with appropriate safeguards - You have rights to access, correct, delete, and port your data - You can delete your account at any time through the App - We do not sell your personal data --- **APP DEV MASTERS LTD** Company Number: 14989815 Registered in England and Wales