PRIVACY POLICY

Updated: 13 June, 2021
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JMIND is doing everything in order to protect your personal data. We wrote this Privacy Policy in the most clear and plain language. Likewise, we tried to provide you with our privacy commitments in a transparent and easily accessible way. That said, we hope you will get all needed details to be assured your personal data is safe with us.

Before you give us your consent on the processing of your personal data or provide us with your personal data, we kindly ask you to read carefully this Privacy Policy, so we can be sure that you completely understand the conditions under which we would cooperate.

This Privacy Policy applies to your use of the Services of JMIND, as defined in our Terms of Service. JMIND offers you options concerning data we process, use and share as described in this Privacy Policy and Cookies Policy.

This Privacy Policy explains when, where, and why we process personal data about people, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.
1. What is personal data and what is processing of personal data. Main definitions
Personal data is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to a person that collects and processes such information to identify you as an individual.

Processing of the personal data means any operation with your personal data, whether or not by automated means, as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; means you as a user of JMIND.

Consent of the data subject/user is any freely given, specific, informed and unambiguous indication of the data subject/user's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. JMIND’s lawful bases for processing
JMIND processes your personal data only when we have lawful bases. Specifically, JMIND processes your personal data if:

• processing is based on the consent you have given.
• processing is necessary to provide our services which constitute a contract between you and us as;
• processing is necessary for the purposes of our legitimate interests.
• where necessary, compliance with applicable legislation (e.g., data subject request processing);
• in exceptional cases, to protect your vital interests or vital interests of another natural person; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

In all cases, we will notify you about the applied legal basis for processing and other relevant details, before we start processing of your personal data on the specific legal basis, unless we are not able to do so in accordance with our obligations under any applicable legislation.
3. What data, for what purposes, based on what grounds, and how long we process the data?
4. Payment Services
We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. We do not store your payment information on our servers.
5. Analytics and Development
In order to find the points of interest in our Services and for the purposes of analytics, we monitor and analyze web traffic and keep track of your behavior within our Services. This enables us to provide services that are relevant to you and boost the quality of our Services. The data concerned within this activity are Cookies and Usage data, such as the parts of our Services you visit, the date and duration of your visit, and type of the device you used during your visit. All your data stated in this paragraph is collected and further processed in a manner that does not allow your identification. For these purposes, we use Google Analytics for Firebase, Crashlytics.
The resource serves as an additional measurement solution to carry out essential analytical work within our Services.
6. Changes
If we decide to change the purposes of processing specified above, we will inform you about such changes prior to the use of your personal data within the newly set purposes. The notification on such changes will be sent to your email and you will have to provide your consent for the amended purposes unless the additional purpose of processing is compatible with those listed above.
In case you do not want to provide us the requested personal data for the purposes specified above, you may not have access to certain functions of the Services.
7. Your rights as data subject regarding your personal data JMIND processes:
a) right of confirmation - to obtain from JMIND the confirmation as to whether or not personal data concerning you is being processed;

b) right of access to your personal data processed by JMIND;

c)right to rectification – ask JMIND to have incomplete personal data requiring corrections completed;

d) right to erasure (right to be forgotten) – request JMIND to erase personal data. In most cases JMIND will erase it unless otherwise required by legislation;

e) right of restriction of processing. For example, you could contest the accuracy of your personal data or in case JMIND is not interested in processing of your personal data any longer, but you want JMIND to do this for different reasons, for example, to bring some claim for somebody and, instead of the erasure of information, its processing will be just restricted.

f) right to data portability - to have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others;

g) right to object to processing of your personal data by JMIND when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with objection to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing;

h) Right to withdraw consent at any time by contacting us. After we at JMIND receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law.
8. Time for reply and reaction
JMIND will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if JMIND is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. JMIND will inform you of any such extension within one month of receipt of the request, together with the reasons of such delay.
9. Security
JMIND takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.
10. Children’s privacy
The privacy of children is one of our concerns. JMIND Services are not intended for use by children under the age of 18 without the express permission of their parent or legal guardian. If you are under the age of 18 you will need to get your parent’s/legal guardian’s permission before submitting any personal data to JMIND. We may process the personal data of children under the age of 18, provided that data has been consensually provided by parents/legal guardians for the express purpose of using JMIND Services.
11. Breach notifications
If any personal data of yours would be under the breach, we would inform you and the respective data protection agencies as to the accidents without undue delay, if there are high risks of violation of your rights as data subject. We would also do our best to minimize any such risk.
12. Governing law
Directive 95/46/EC (“GDPR”), effective as of 25 May 2018.
If one of the aforementioned reasons applies, please contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately. These requests are free of charge.
If you believe that our use of your data violates your rights, you can lodge a complaint with the competent data protection authority.
Please, note that when the processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification and we will no longer process your data with such direct marketing purposes.
Data Controller:
JMIND SYSTEMS LTD,
a legal entity under the laws of Cyprus,
organization number 559961
Address:
Vasili Michailidi, 9, 3026, Limassol, Cyprus

To contact email:
privacy@jmind.systems
Your JMIND Team
Your JMIND Team
Your JMIND Team