Updated on September 23, 2022

Please take a moment to learn about our privacy practices by visiting the headings below and contacting us if you have questions.

What is personal data at SoftenMind?

At SoftenMind, we strongly believe in fundamental privacy rights and the uniform application of those fundamental rights no matter where in the world you live. That is why we treat any data relating to an identified or identifiable individual, or data that SoftenMind has linked or may link to that individual, as “personal data” , regardless of where the person lives. This means both data that directly identifies you – such as your name – and data that does not directly identify you but can reasonably be used to identify you. – such as device serial numbers – are all personal data. For the purposes of this Privacy Policy, aggregated data is treated as non-personal data.

This Privacy Policy addresses how SoftenMind or an affiliated company of SoftenMind (collectively, “SoftenMind”) handles personal data, whether you interact with us on the website, through applications application of SoftenMind or in person (including by phone or when you visit our office). SoftenMind may also link to third parties when providing services or allowing the download of third-party applications on the platform. SoftenMind’s privacy policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policy and understand your privacy rights before interacting with them.

Your privacy at SoftenMind

At SoftenMind, we respect your ability to understand, access, correct, transfer, limit processing and delete your personal data. We have made these rights available to our global customer base, and if you choose to exercise these privacy rights, you have the right not to be discriminated against nor to receive a lower level of service from SoftenMind. . SoftenMind does not sell your data.

To exercise your privacy rights and choices, even in the case of a third-party service provider acting on behalf of SoftenMind, please contact us by email [email protected].

However, it may happen that we cannot accept your change request – for example, if you ask us to delete transaction data while SoftenMind is legally obligated to keep the record. transaction records to comply with the law. We may also refuse to accept a request if it would impair our ability to use data in a legitimate way for anti-fraud and security purposes, such as when you request deletion of an account. account is under investigation due to security concerns. Other reasons that a privacy request may be denied include: the request affects the privacy of others, the request is frivolous, offensive, or extremely impractical.

Personal data that SoftenMind collects from you

At SoftenMind, we believe you can have great products and guaranteed privacy. This means that we strive to collect only the personal data we need. The personal data that SoftenMind collects depends on how you interact with SoftenMind.

When you create a SoftenMind account, sign up for a course at SoftenMind, connect to our services, contact us (including via social media), take an online survey or interact with SoftenMind in alternatively, we may collect a variety of information, including:

• Account information. Your SoftenMind ID and account-related details, including email address, registered device, account status and age

• Device Information. Data on which to identify your device, such as your device’s serial number, or data about your device, such as browser type

• Contact Info. Data such as name, email address, physical address, phone number or other contact information

• Billing Information. Billing address and payment method data, such as details about

• banking, credit card, debit card or other payment card information

• Transaction information. Data on purchases of SoftenMind products and services or transactions supported by SoftenMind, including purchases on SoftenMind platforms

• Fraud prevention information. Data used to help identify and prevent fraud, including device trust scores

• Usage data. Data about your use and activity on our products and services, such as app launches within our services, including browsing history; calendarsearch history; product interaction; malfunction, performance and other diagnostic data; as well as other usage data

• Location information. Exact location is only intended to support the Find app, as well as approximate location

• Health information. Data relating to an individual’s state of health, which includes data relating to a person’s physical or mental condition or health. Personal health data also includes data that can be used to infer or detect an individual’s health status.

• Physical information. Details regarding fitness and fitness information in case you choose to share

• Economic information. The details include salary, income and asset information in the case collected, as well as information related to SoftenMind-branded financial products

• Government-issued identification data. In some jurisdictions, we may require government-issued identification under certain circumstances, including when setting up a wireless account and activating the device, as needed to renew commercial credit, reservation management or as required by law

• Other information you provide to us. Details such as communications between you and SoftenMind, including interactions with customer support and contacts through social media channels

• You are not required to provide the personal data we have requested. However, if you choose not to provide this information, in many cases we will not be able to provide you with our products or services or respond to your requests.

• Personal data that SoftenMind receives from other sources

• SoftenMind may receive personal data about you from other individuals, from businesses or third parties acting at your request, from partners who work with us to provide products and services. services and assist us with security and fraud prevention, and from other legitimate sources.

• As your request. You can ask other individuals or third parties to share data with SoftenMind. For example, you can ask your mobile carrier to share data about your carrier account with SoftenMind to activate your account, or ask a loyalty program to share information about your participation so that you can receive rewards for purchases of SoftenMind.

• Partner of SoftenMind. We may also verify the information you provide, such as when generating a SoftenMind ID, with third parties for security and fraud prevention purposes.

• For research and development purposes, we may use datasets, such as those containing images, voices, or other data that can be linked to an identifiable individual. When we obtain such datasets, we will comply with applicable law, including the law in the jurisdiction where the datasets are stored. When using such datasets for research and development, we will not attempt to re-identify individuals who may appear in them.

How SoftenMind uses personal data

SoftenMind uses personal data to provide services, process your transactions, communicate with you, secure and prevent fraud, and comply with the law. We may also use personal data for other purposes with your consent.

SoftenMind only uses your personal data where we have a valid legal basis to do so. Depending on the case, SoftenMind may rely on your consent or the necessity of processing the information. in practice to perform a contract with you, protect your important interests or those of others, or to comply with the law. We may also process your personal data when we believe it is in our legitimate interests or that of others, however, with due regard to your interests, rights and expectations. If you have questions about the legal basis, you can contact the Data Protection Officer at [email protected]

• Service Provider. SoftenMind collects personal data necessary to provide the service, which may include personal data collected to improve our products and services, for internal purposes such as testing or data analysis, or for troubleshooting.

• Process your transactions. In order to process transactions, SoftenMind must collect data such as your name, purchases and payment information.

• Communicate with you. To respond to communications, contact you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. return. From time to time, we may use your personal data to send important notifications, such as information about purchases and changes to our terms, conditions and policies. Since these are important information that affects the communication between you and SoftenMind, you cannot opt ​​out of receiving these important notifications.

• Security and fraud prevention. To protect individuals, employees and SoftenMind as well as to prevent loss and prevent fraud, including to protect individuals, employees and SoftenMind for the benefit of all users, and to pre-screen or scan uploaded content to detect potentially illegal content, including material about child sexual exploitation.

• Personal data for personalization. If you choose to personalize your services or communications where such options are available, SoftenMind will use the information collected to provide you with personalized services or communications. make that. You can learn more about how related services use information to personalize your experience by reviewing the privacy information that appears the first time you use a service to use. personal data.

• Compliance with laws. To comply with applicable law – for example, to meet tax or reporting obligations, or to comply with a lawful governmental request.

• SoftenMind does not use algorithms or profiles to make any decisions that could significantly affect you without giving you a chance to personally review them.

• SoftenMind retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in the rights notices privacy of each service, or as required by law. We will retain your personal data for as long as necessary to fulfill the purposes set forth in the Policy

this privacy policy and the privacy summaries of each service. When assessing the retention period, we first carefully check whether it is necessary to retain the collected personal data, and if retention is required, we will endeavor to retain the personal data. multiplied in the shortest possible time by law.

How SoftenMind shares personal data

SoftenMind may share personal data with SoftenMind affiliated companies, service providers acting on our behalf, partners, or other parties upon your request. Furthermore, SoftenMind does not share personal data with third parties for their own marketing purposes.

• Service Provider. SoftenMind may hire third parties as service providers and do certain things on our behalf, such as processing or storing data, including personal data, relating to your use use our services and deliver products to customers. SoftenMind’s service providers are obligated to process personal data in accordance with this Privacy Policy and in accordance with our instructions. They may not use the personal data we share for their own purposes and must delete or return the personal data when they complete our request.

• Partners. From time to time, SoftenMind may partner with third parties to provide other products or services. For example, SoftenMind financial products such as SoftenMind Card and SoftenMind Cash are offered by SoftenMind and our partners. SoftenMind requires partners to protect your personal data.

• Other parties. SoftenMind may share personal data with other parties at your request or with your consent, such as when we share information with carriers to activate your account. We may also disclose information about you if we determine that disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance. they. We may also disclose information about you when there are lawful grounds to do so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions. , or to protect our operations or users, or in the event of a reorganization, merger or acquisition.

Protect personal data at SoftenMind

At SoftenMind, we believe that privacy is only guaranteed when there is good security. We use administrative, technical and physical safeguards to protect your personal data, taking into account the nature of your personal data and its processing and threats. latent. We are constantly working to improve these protections to help keep your personal data safe.

Personal data and children

SoftenMind understands the importance of protecting children’s personal data. By our definition, a child is an individual under the age of 13, or the equivalent age required by law in your jurisdiction. That’s why SoftenMind has implemented additional safeguards and procedures to help keep children’s personal data safe.

To access some SoftenMind services, a child must have a young SoftenMind ID em. A child’s SoftenMind ID can be created by a parent or, in the case of a managed SoftenMind ID, by the child’s educational institution.

• Parents. To create a child account, parents must carefully review the Disclosure of Family Privacy to Children page, which describes how SoftenMind handles children’s personal data. If consent is obtained, the parent must provide SoftenMind with verifiable parental consent.

• If we become aware that a child’s personal data has been collected without proper authorization, that data will be deleted as soon as practicable.

• Cookies and other technologies

• SoftenMind websites, online services, interactive applications and advertisements may use “cookies” and other technologies such as web beacons. These technologies help us better understand user behavior, including for security purposes and to prevent fraud, tell us what parts of the site people have visited, and facilitate and measure the effectiveness of advertising and web search.

• Communication cookies. These cookies are used to assist with network traffic to and from SoftenMind’s systems, including helping us detect errors.

• Essential cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our web pages in the right format and language, validate and verify your transactions, and preserve the contents of your Shopping Cart as you shop. online at SoftenMind.com.

• Other cookies. These cookies are used to understand how visitors interact with our websites and online services, including to help us measure the effectiveness of advertisements and web searches. SoftenMind also uses these cookies to remember your choices when browsing the web, thereby helping us deliver a personalized experience for you.

• If you want SoftenMind not to use cookies, we provide you with a way to disable the use of cookies. If you want to disable cookies and are using the Safari web browser, select “Block all cookies” in Safari’s privacy settings. If you are using another browser, consult your provider’s information to learn how to disable cookies. Some features on SoftenMind’s website may not be available if you disable all cookies.

• In addition to cookies, SoftenMind uses other technologies to achieve similar goals.

In some of the emails SoftenMind sends you, we provide a “quick click URL” to link you to content on SoftenMind’s website. When you click on one of these URLs, it passes through a separate server before reaching the landing page on our website. We track this click behavior to determine interest in specific topics and measure whether we are communicating with you effectively. If you don’t want to be tracked in this way, you shouldn’t click on pictures or text containing links in emails.

SoftenMind generally treats data collected by these cookies and similar technologies as non-personal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data in that area. In addition, SoftenMind will from time to time combine non-personal data collected from these technologies with other personal data that SoftenMind holds. When we combine data in this way, we will treat the combined data as personal data for the purposes of this Privacy Policy.

Ads provided by SoftenMind’s advertising platform may appear on SoftenMind’s website or on the App Store / Google Play Store. If you do not wish to receive interest-targeted advertising from SoftenMind’s advertising platform in such applications, you may choose to disable Personalized Advertising so that your SoftenMind ID does not receive advertising regardless of you What kind of device are you using?

Transfer of personal data between countries

SoftenMind products and services connect you to the world. In order to do so, not only SoftenMind affiliated companies but also worldwide entities may transfer or access your personal data in order to carry out processing activities such as the one described above. in this Privacy Policy with respect to your use of our products and services. SoftenMind complies with personal data transfer laws between countries to help ensure your data is protected, wherever it is.

The unit SoftenMind controls your personal data may vary depending on where you live. For example, retail store information may be controlled by individual retailers in each country, while personal data relating to SoftenMind Communication Services may be controlled by different SoftenMind entities. specified in the terms of service.

Commitment oncompany-wide about your privacy

To ensure your personal data is safe, we will communicate our privacy and security principles to SoftenMind employees, and take privacy protections seriously. in company.

Questions about privacy

If you have questions about SoftenMind’s Privacy Policy or privacy practices, including where a third-party service provider acts on our behalf, or if you would like to contact Data protection officer or would like to file a complaint, contact us at [email protected] or call the SoftenMind Support number in your country or region. You can also ask us how to file a privacy complaint and we’ll try to help.

SoftenMind takes privacy questions very seriously. A dedicated team will review your question to determine how best to respond to your question or concern, including those related to access or download requests. In most cases, all questions about a serious matter are answered within seven days. In other cases, we may ask for more information or notify you that we need more time to respond.

If we find that your complaint contains details that help us improve our handling of privacy issues, we will take steps to update the improvement at the next appropriate time. In the event that a privacy issue has had a negative impact on you or another person, we will take steps to resolve it with you or that person.

If you are not satisfied with SoftenMind’s response, you may refer your complaint to the appropriate regulatory body. If you request it, we will endeavor to provide you with information about the relevant complaints process that may apply to your case.

When this Privacy Policy makes a material change, we will post a notice on this website at least one week prior to the change and contact you directly to notify you of the change if we have any your data on file.