Privacy Policy

§1Operator and Data Controller

Write to the address above about anything concerning your personal data. It is also the address where you exercise all the rights described in this policy.

§2Types of Data collected

mindshiftlife.space collects, by itself or through third parties, the following types of Personal Data:

Details on each type of data are provided in §5 or in the explanations shown before the data is collected. You provide Personal Data voluntarily or, in the case of Usage Data, it is collected automatically when you use the website.

Unless stated otherwise, all data requested by the website is mandatory, and failing to provide it may make it impossible to provide the services. Where the website clearly states that some data is optional, you may choose not to provide it without any effect on the availability or functioning of the website. If you are not sure which data is mandatory, contact the Operator.

You are responsible for any third-party Personal Data you obtain, publish or share through the website.

§3How and where Data is processed

Methods of processing

The Operator takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of the Data. Data is processed using computers and IT tools, following organizational procedures strictly related to the stated purposes.

In addition to the Operator, in some cases the Data may be accessible to people involved in running the website (administration, sales, marketing, legal, system administration) or to external parties appointed by the Operator as Data Processors, such as technical service providers, mail carriers, hosting providers, IT companies and communications agencies. You can request an up-to-date list of these parties from the Operator at any time.

Place of processing

Data is processed at the Operator's offices and in any other places where the parties involved in the processing are located. Depending on your location, Data may be transferred to a country other than your own. You will find the place of processing for each service in §5.

Retention period

Unless stated otherwise, Personal Data is processed and stored for as long as required by the purpose for which it was collected. It may be kept longer if required by a legal obligation or if you consent to it.

§4Purposes of processing

Data is collected so that the Operator can provide the Service, comply with its legal obligations, respond to requests from authorities, protect its rights and interests (as well as those of Users or third parties) and detect malicious activity and abuse. Other purposes are:

• building and running the website;
• platform services and hosting;
• analytics;
• contacting the User;
• access to third-party accounts;
• displaying content from external platforms;
• handling payments;
• location-based interactions;
• tag management;
• newsletter and waitlist;
• booking online consultations;
• free quizzes;
• the MENTOR app and responses generated by artificial intelligence.

§5Services we use

Below you will find details of Personal Data processing by purpose and by specific service.

Building and running the website

Key parts of the website are built and run directly by the Operator using the software below.

Platform services and hosting

These services host and run key components of the website so that it works on a single platform. They provide tools such as analytics, account management, comments, databases, e-commerce and payments, which involve processing Personal Data. Some of them run on geographically distributed servers, which makes it difficult to determine the exact storage location of the data.

Analytics

Analytics services allow the Operator to monitor and analyze traffic on the website and may be used to track User behavior.

Tag management

These services help manage the tags and scripts the website needs in one place. User Data passes through them, which may result in it being stored.

Contacting the User

Booking consultations

When you book a consultation, the website saves your first name, email address, chosen time and an optional description of the topic. Based on this, an event with a separate Google Meet link is created in the Operator's calendar, and you receive a confirmation and reminders by email. We process this data to perform the consultation agreement.

Handling payments

Unless stated otherwise, the website handles payments by card, bank transfer or other means through external payment service providers. You give your payment and personal details directly to these providers. mindshiftlife.space does not collect or process such information and only receives confirmation from the provider of whether the payment was successful.

Access to third-party accounts

These services allow the website to use data from your account on a third-party service and perform actions with it. They are not enabled automatically and require your explicit authorization.

Displaying content from external platforms

These services, often called widgets, let you view content from external platforms directly on the website's pages and interact with it. They may collect traffic data from the pages where they are installed, even if you don't use them.

Free quizzes

We save your answers to the free quizzes on the website, including written answers, to prepare your result and a deeper analysis if you order one, and to improve the quizzes. If you leave your first name and email address, we process them on the basis of your consent. If you skip this step, we save your answers without your name and address. Your answers may concern your relationships, finances and childhood experiences, so only the Operator has access to them.

The Mentor app

Mentor is the MindShift Life web app, available to people with an active subscription. Below you will find what data we process in it, why and for how long.

What data we collect

• Account data: first name and email address, needed to log in and manage your subscription.
• Content you write or record yourself: your goal, the card of your end version, answers in rituals, conversations with Mentor, sentences, evidence, photos and voice recordings.
• App settings: reminder times, chosen backgrounds, display mode.
• Technical data: device and browser type and a description of the error when the app runs into a problem. It is used only to fix bugs.

Why we process it

• To guide you through the program and tailor the content to your goal. This is necessary to provide the service you ask for (Article 6(1)(b) GDPR).
• To send reminders about your rituals, if you turn them on. Here the basis is your consent, which you can withdraw at any time in the app's or your phone's settings (Article 6(1)(a) GDPR).
• To detect and fix app errors. This is our legitimate interest (Article 6(1)(f) GDPR).

Artificial intelligence

Some of Mentor's responses are created by the Claude language model from Anthropic PBC (USA). The model receives only what is needed for a given response: your goal, your card and the content of the current conversation or ritual. Mentor does not make decisions about you that have legal effects. Its responses are support in working with an assumption, not medical, psychological or financial advice.

Voice in recordings

Affirmations read in Mentor's voice are created by Google Cloud Text-to-Speech. It receives only the text of the affirmation, without your name or email address.

Sensitive data

In rituals and conversations you may choose to describe information about your health, relationships or emotions. We don't ask for it, and by entering it you consent to its processing in the app (Article 9(2)(a) GDPR). You can delete any such entry in the “What Mentor knows about me” tab.

Data on your phone

So that Mentor works without internet, some data is saved in your device's memory: the app state, recordings for playback and changes waiting to be sent. You can delete them by clearing the site data in your browser or removing the app from your home screen.

Who we share data with

Data is transferred to the USA on the basis of standard contractual clauses approved by the European Commission or the EU-U.S. Data Privacy Framework.

How long we keep data

• Ritual conversations: 90 days.
• Technical statistics: 30 days.
• Your goal, card, sentences, evidence and recordings: until you delete them or delete your account.
• When you delete your account, we delete all Mentor app data.

Your rights

You have the right to access your data, correct it, delete it, restrict its processing, transfer it and object to its processing. You can download all your data in one file: Settings, “Download my data”. For anything else, write to hello@mindshiftlife.space. You also have the right to lodge a complaint with a data protection authority, in Poland the President of the Personal Data Protection Office (UODO).

Data controller

MSLife LLC, 1111B S Governors Ave STE 21058, Dover, Delaware, United States of America, hello@mindshiftlife.space

Location-based interactions

§6Cookies

mindshiftlife.space uses Trackers, including cookies. You will find details in the cookie policy.

§7Information for Users in the European Union

This section applies to all Users in the European Union under the General Data Protection Regulation (GDPR). For them it takes precedence over any other, possibly conflicting, information in this policy. You will find the categories of data, purposes of processing and recipients in §5.

Legal bases for processing

The Operator may process your Personal Data if one of the following applies:

• consent has been given for processing for one or more specific purposes;
• processing is necessary to perform an agreement with you or to take steps before concluding it;
• processing is necessary to comply with a legal obligation of the Operator;
• processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Operator;
• processing is necessary for the purposes of the legitimate interests of the Operator or a third party.

The Operator will gladly explain which legal basis applies in a given case and, in particular, whether providing data is a statutory or contractual requirement or a condition for concluding an agreement.

Retention period

• Data collected in connection with an agreement between the Operator and you is kept until the agreement has been fully performed, and order and invoice data for the period required by tax and accounting regulations.
• Data processed on the basis of consent, including in the newsletter and on the waitlist, is kept until consent is withdrawn.
• Data collected on the basis of the Operator's legitimate interests is kept for as long as needed to fulfill those purposes. You will find details of these interests in the relevant parts of this policy or can obtain them from the Operator.

The Operator may keep data longer if consent to this has been given and not withdrawn, and when required by a legal obligation or an order from an authority. After the retention period ends, the data is deleted, and the rights of access, erasure, rectification and data portability can no longer be exercised.

Your rights under the GDPR

To the extent permitted by law, you have the right to:

• withdraw consent at any time, if you gave it earlier;
• object to processing if it is based on a legal basis other than consent;
• access your data, meaning information on whether the Operator processes your data, to what extent, and a copy of that data;
• rectification, meaning checking that your data is correct and asking for it to be updated or corrected;
• restriction of processing, in which case the Operator may only store your data;
• erasure of your data;
• data portability, meaning receiving your data in a structured, commonly used, machine-readable format and, where technically possible, having it transferred to another controller;
• lodge a complaint with the competent data protection authority, in Poland the President of the Personal Data Protection Office (UODO).

You also have the right to know the legal basis for transferring data to third countries or international organizations and the security measures used by the Operator. If such a transfer takes place, you will find this information in the relevant parts of this policy or can obtain it from the Operator.

Right to object

If your data is processed in the public interest, in the exercise of official authority or on the basis of the Operator's legitimate interests, you may object on grounds relating to your particular situation.

How to exercise your rights

Send your request to hello@mindshiftlife.space. It is free of charge. The Operator responds as soon as possible and always within one month. The Operator informs every recipient to whom data has been disclosed of any rectification, erasure or restriction of processing, unless this is impossible or would involve disproportionate effort. At your request, the Operator will tell you who these recipients are.

§8Information for Users in Switzerland

This section applies to Users in Switzerland and for them takes precedence over any other, possibly conflicting, information in this policy. You will find the categories of data, purposes, recipients and retention periods in §5.

Under the Swiss Federal Act on Data Protection, within the limits set by law, you have the right to:

• access your Personal Data;
• object to processing, including requesting restriction of processing, erasure or destruction of data and prohibiting its disclosure to third parties;
• receive your data and transfer it to another controller;
• have incorrect data corrected.

Send your request to hello@mindshiftlife.space. It is free of charge and the Operator responds as soon as possible.

§9Information for Users in Brazil

This section supplements the rest of the policy. It is provided by the entity running the website and, as the case may be, its parent, subsidiaries and affiliates (hereinafter “we”). It applies to all Users in Brazil under the Lei Geral de Proteção de Dados (LGPD) and for them takes precedence over any other, possibly conflicting, information. The term “personal data” here has the meaning given to it in the LGPD.

Grounds for processing

We process your personal data only on a legal basis, which is:

• your consent;
• a legal or regulatory obligation that applies to us;
• the implementation of public policies provided for by law or based on contracts and similar instruments;
• research carried out by research bodies, preferably on anonymized data;
• the performance of an agreement to which you are a party and steps taken before concluding it;
• the exercise of our rights in judicial, administrative or arbitration proceedings;
• the protection of your life or physical safety or that of a third party;
• the protection of health in procedures carried out by health entities or professionals;
• our legitimate interests, provided your fundamental rights and freedoms do not override them;
• credit protection.

The categories of data processed are described in §5, and the purposes in §4 and §5. You can learn more about the legal bases by writing to hello@mindshiftlife.space.

Your rights

Under Brazilian law you have the right to:

• confirmation that we process your data;
• access your data;
• have incomplete, inaccurate or outdated data corrected;
• anonymization, blocking or erasure of unnecessary or excessive data or data processed in breach of the LGPD;
• information about the possibility of refusing consent and the consequences of doing so;
• information about the entities with which we share your data;
• portability of your data, except anonymized data, to another provider, while protecting our trade and industrial secrets;
• erasure of data processed on the basis of consent, unless an exception under Article 16 of the LGPD applies;
• withdraw consent at any time;
• lodge a complaint with the ANPD (National Data Protection Authority) or consumer protection bodies;
• object to unlawful processing;
• clear information about the criteria and procedures of automated decisions;
• a review of decisions made solely by automated means that affect your interests, including those concerning your personal, professional, consumer and credit profile.

Exercising these rights will never result in discrimination or any other negative consequences.

How to make a request and when we will respond

You can make a request free of charge, at any time, to hello@mindshiftlife.space or through your legal representative. We respond without delay. If we cannot fulfill the request immediately or at all, we will explain the factual or legal reasons. If we do not process your data, we will, where possible, tell you which entity to contact.

When requesting access or confirmation of processing, state whether you want to receive the data electronically or in print and whether a simplified response given immediately is enough or you need full information. In the latter case we will respond within 15 days, giving the origin of the data, information on whether records exist, and the criteria and purposes of processing, while protecting our trade and industrial secrets.

We will pass on requests for rectification, erasure, anonymization or blocking of data without delay to the entities with which we have shared it, unless this is impossible or involves disproportionate effort.

Transfers of data outside Brazil

We may transfer your data outside Brazil when the transfer is:

• necessary for international legal cooperation between intelligence, investigative and law enforcement bodies, in accordance with international law;
• necessary to protect your life or physical safety or that of a third party;
• authorized by the ANPD;
• the result of a commitment under an international cooperation agreement;
• necessary to implement a public policy or a statutory power to provide a public service;
• necessary to comply with a legal or regulatory obligation, perform an agreement or take steps before concluding it, or exercise rights in judicial, administrative or arbitration proceedings.

§10Information for Users in the United States

This section supplements the rest of the policy. It is provided by the entity running the website and, where applicable, its parent, subsidiaries and affiliates (hereinafter “we”). It applies to Users residing in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota and Montana. For them it takes precedence over any other, possibly conflicting, information. We use the terms Personal Information and Sensitive Personal Information here.

Categories of Personal Information

Below are the categories of Personal Information collected or disclosed in the last 12 months. The breakdown is based mainly on California law, but it also gives a general picture to residents of other states.

For all categories: the retention period is the time needed to fulfill the purpose, we do not sell or share Personal Information and we do not use targeted advertising. Without your consent, we will not process your information for purposes that are unexpected or incompatible with the purposes originally disclosed.

Sources of Personal Information

We collect it from you directly, for example when you submit a form, or indirectly, when you use the website and information is collected automatically. We may also receive it from third parties who work with us on the Service and on running the website.

Your rights under state laws

To the extent permitted by law, you have the right to:

• know whether we process your Personal Information and access it;
• correct inaccurate Personal Information;
• delete your Personal Information;
• obtain a copy of your Personal Information in a portable format, where technically feasible;
• opt out of the Sale of Personal Information;
• non-discrimination for exercising these rights.

California

• the right to opt out of the Sharing of Personal Information for cross-context behavioral advertising;
• the right to limit the use of Sensitive Personal Information to what is necessary to provide the services, in the way an average consumer would reasonably expect.

Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota and Montana

• the right to opt out of processing for Targeted Advertising or profiling that leads to decisions with legal or similarly significant effects;
• the right to freely give, refuse or withdraw consent to the processing of Sensitive Personal Information.

In Minnesota you also have the right to a list of the specific third parties to whom your data was disclosed, as well as specific rights related to profiling: to question its results, learn the reason for a decision, be told what could have been done and what can be done to obtain a different decision, review the data used and have it corrected and the decision reassessed.

Utah and Iowa

• the right to opt out of processing of Personal Information for Targeted Advertising;
• the right to opt out of processing of Sensitive Personal Information.

In each of these states, exceptions provided for by law may apply, for example when processing Sensitive Personal Information is necessary to provide a requested service or to maintain the quality and security of the service.

How to exercise your rights

Send your request to hello@mindshiftlife.space. We need to verify your identity to confirm that the information we hold relates to you. You don't need an account with us. We will use the data collected for verification only for that purpose and will not keep it longer than necessary. As an adult, you may make a request on behalf of a child in your parental care.

You can also opt out of Sale or Sharing and of Targeted Advertising in the website's privacy settings or using a global mechanism such as Global Privacy Control (GPC). We will honor it without undue friction.

We respond without undue delay, within the period required by law. If we need more time, we will explain why and how much. If we refuse, we will give the reasons and, where the law provides for it, you may lodge a complaint with the competent authority. We do not charge a fee unless the request is manifestly unfounded or excessive or the law allows it. In that case we may charge a reasonable fee or refuse, telling you the reasons.

§11Additional information about data processing

Legal action

The Operator may use your Personal Data in court proceedings or at the stage leading up to possible legal action arising from improper use of the website or the Services. The Operator may also be required to disclose data at the request of public authorities.

Additional information on request

In addition to the information in this policy, the Operator may, at your request, provide additional information about specific Services and about the collection and processing of your data.

System logs and maintenance

For operation and maintenance purposes, the website and third-party services may collect files that record interactions with the website (system logs) or use other Personal Data, such as the IP address, for this purpose.

Information not contained in this policy

You can obtain more details on the collection or processing of data from the Operator at any time, using the contact details in §1.

Changes to this privacy policy

The Operator may change this policy at any time, announcing it on this page, on the website and, where technically and legally possible, by sending a notice to the available contact details. Check the date of the last update at the top of the page. If the changes concern processing based on consent, the Operator will ask for new consent where it is required.

This policy has been prepared on the basis of several legal acts and, unless stated otherwise, applies only to mindshiftlife.space.

§12Definitions and legal references

Personal Data (Data) / Personal Information

Any information that directly, indirectly or in connection with other information, including an identification number, makes it possible to identify a natural person.

Sensitive Personal Information

Personal Information that is not publicly available and reveals information considered sensitive under applicable privacy laws.

Usage Data

Information collected automatically by the website or third-party services used on the website, including: IP addresses or domain names of devices, URI addresses, the time and method of the request, the size of the response file, the server response status code, the country of origin, browser and operating system features, the time spent on individual pages, the path and order of pages visited and other parameters of the User's device and IT environment.

User

A natural person using the website who, unless stated otherwise, is the same as the Data Subject.

Data Subject

The natural person to whom the Personal Data relates.

Data Processor

A natural or legal person, public authority, agency or other body that processes Personal Data on behalf of the Controller, in accordance with this policy.

Data Controller (Operator)

The entity that, alone or jointly with others, determines the purposes and means of processing Personal Data, including the security measures concerning the operation of the website. Unless stated otherwise, this is MSLife LLC.

Website (mindshiftlife.space)

The website through which the User's Personal Data is collected and processed.

Service

The service provided by the website, described in the terms and conditions and on the website.

Sale

The transfer of Personal Information to a third party by the Operator in exchange for monetary or other valuable consideration, within the meaning of privacy laws in force in the USA. An exchange of Personal Information with a service provider under a written agreement that meets the legal requirements is not a Sale.

Sharing

The transfer, disclosure or other making available of Personal Information to a third party for cross-context behavioral advertising, whether or not for payment, within the meaning of California law. An exchange of Personal Information with a service provider under a written agreement that meets the requirements of that law is not Sharing.

Targeted Advertising

Displaying ads selected on the basis of Personal Information obtained from a consumer's activity over time and across unrelated websites or apps, in order to predict their preferences or interests, within the meaning of US laws.

European Union (EU)

All member states of the European Union and the European Economic Area.

Cookie

A Tracker consisting of a small set of data stored in the User's browser.

Tracker

Any technology that makes it possible to track Users, for example cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting, that uses information on the User's device or stores information on it.