Privacy Policy

MindChoices iOS Application  ·  MindAction LLC (101XP North America LLC)  ·  Effective: April 10, 2026

 

This Privacy Policy for MindAction LLC (101XP North America LLC) ("MindAction LLC," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), including when you:

  • Download and use our iOS mobile application, MindChoices.
  • Engage with us in other related ways, including customer support or communications.

 

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@themindaction.com.

SUMMARY OF KEY POINTS

What personal information do we process? When you use our App, we may process personal information depending on how you interact with MindAction LLC and the App, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We may receive limited information from third-party sign-in providers (Google, Apple). We do not receive data from marketing data brokers for our App.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific categories of service providers. We do not sell your personal information.

How do we keep your information safe? We have organisational and technical processes in place to protect your personal information. However, no electronic transmission over the internet can be guaranteed 100% secure.

What are your rights? Depending on where you are located geographically, applicable privacy law may give you certain rights regarding your personal information.

How do you exercise your rights? Contact us at info@themindaction.com. We will consider and act upon any request in accordance with applicable data protection laws.

  1. WHAT INFORMATION DO WE COLLECT?

In Short: We collect personal information that you provide to us, and some information is collected automatically when you use the App.

 

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the App, or otherwise when you contact us.

The personal information we collect may include the following:

  • Names
  • Email addresses
  • Usernames and account profile information
  • Authentication data provided via Google Sign In or Apple Sign In

 

Sensitive Information. We do not process sensitive personal information.

 

Payment Data. We do not directly collect or store payment card details. All in-app purchases and subscription billing are processed by Apple Inc. via Apple In-App Purchase and managed through RevenueCat Inc. We receive only transaction identifiers and subscription status information. Please review Apple's privacy policy at https://www.apple.com/legal/privacy and RevenueCat's privacy policy at https://www.revenuecat.com/privacy.

 

Social Login Data. We offer registration via Google Sign In and Apple Sign In. When you choose these options, we receive your name and email address from the respective provider. We do not receive your social media friends lists or other profile data.

 

Information collected automatically

In Short: Some information is collected automatically when you use the App.

We automatically collect certain information when you use the App. This information does not reveal your specific identity but may include:

  • Log and Usage Data. Service-related diagnostic and performance information, including your device information, in-app events, screens viewed, session duration, and actions taken within the App. Collected via Google Firebase and DevToDev analytics.
  • Device Data. Information about your mobile device, including device model, operating system version, unique device identifiers, and mobile network information.
  • Crash Data. Error reports and crash logs collected via Firebase Crashlytics to help us identify and fix bugs.
  • Location Data. We collect only approximate location based on IP address for analytics and fraud prevention purposes. We do not collect precise GPS location.

 

Information we do NOT collect

  • We do not use Meta Pixel, Facebook SDK, or any advertising tracking SDK within the App.
  • We do not collect cookies within the App (cookies apply only to our web properties).
  • We do not collect health or biometric data.
  1. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We process your information so you can create and log in to your account via Google Sign In or Apple Sign In.
  • To deliver and facilitate delivery of services to the user. We process your information to provide you with the App's interactive stories, coaching games, and subscription features.
  • To process subscriptions and manage billing. We process subscription status information via RevenueCat and Apple In-App Purchase to grant you access to your purchased plan.
  • To respond to user inquiries and offer support. We process your information to respond to your questions and resolve issues.
  • To send administrative information. We may send details about changes to our terms and policies, and service-related notifications.
  • To request feedback. We may contact you about your use of our Services to improve them.
  • To protect our Services. We process your information to keep the App safe and secure, including fraud detection and prevention.
  • To identify usage trends. We process anonymised usage data via Firebase and DevToDev to understand how the App is being used so we can improve it.
  • To save or protect an individual's vital interest. We may process your information when necessary to prevent harm.
  1. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we have a valid legal reason to do so under applicable law.

 

If you are located in the EU or UK, this section applies to you.

The GDPR and UK GDPR require us to explain the valid legal bases we rely on:

  • Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract. We may process your personal information when necessary to fulfil our contractual obligations to you, including providing the App and subscription services you purchase.
  • Legitimate Interests. We may process your information when reasonably necessary to achieve our legitimate business interests, including: improving the App, maintaining security, fraud prevention, and understanding how users use our services.
  • Legal Obligations. We may process your information where necessary for compliance with our legal obligations.
  • Vital Interests. We may process your information where necessary to protect your vital interests or those of a third party.

 

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (express consent) or where your permission can be inferred (implied consent). You can withdraw your consent at any time. In exceptional cases, we may be legally permitted to process your information without your consent as permitted by applicable Canadian law.

  1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations and with the following categories of third parties. We do not sell your personal information.

We share data only with service providers necessary to operate the App:

 

Service Provider

Purpose

Data Shared

Privacy Policy

Apple Inc. (Sign In with Apple)

User authentication

Name, email address

apple.com/legal/privacy

Google LLC (Google Sign In)

User authentication

Name, email address

policies.google.com/privacy

Apple Inc. (In-App Purchase)

Subscription billing and processing

Transaction IDs, subscription status

apple.com/legal/privacy

RevenueCat Inc.

Subscription management and analytics

User ID, subscription status, purchase history

revenuecat.com/privacy

Google Firebase (Analytics & Crashlytics)

App analytics, crash reporting, performance monitoring

Anonymised usage events, crash logs

firebase.google.com/support/privacy

DevToDev

Mobile analytics and behavioural analytics

Anonymised in-app events, session data

devtodev.com/policy/privacy-policy

 

We may also share information in the following situations:

Business Transfers. We may share or transfer your information in connection with a merger, sale of company assets, financing, or acquisition of all or part of our business.

Legal Requirements. We may disclose your information where required to comply with applicable law, respond to legal process, or protect our rights.

  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We do not use cookies within the iOS App. The App uses Firebase and DevToDev SDKs for analytics.

The MindChoices iOS App does not use browser cookies. We use Firebase Analytics, Firebase Crashlytics, and DevToDev SDKs which collect anonymised usage and performance data to help us improve the App. These SDKs may use device identifiers (such as the iOS Identifier for Vendors, IDFV) for analytics purposes.

You can limit ad tracking and analytics on your iOS device via Settings → Privacy & Security → Tracking, and Settings → Privacy & Security → Apple Advertising.

  1. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: We receive limited profile information when you sign in via Google or Apple.

Our App offers you the ability to register and log in using Google Sign In or Apple Sign In. When you choose to do so, we will receive certain profile information from the respective provider — typically your name and email address.

We use this information only to create and manage your account within the App. We do not control, and are not responsible for, the use of your personal information by Google or Apple. We recommend you review their privacy policies to understand how they collect, use, and share your personal information.

  1. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own, primarily the United States.

Our servers and those of our service providers are primarily located in the United States. If you are accessing the App from outside the United States, your information may be transferred to, stored, and processed in the US.

If you are a resident of the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we implement appropriate safeguards for international data transfers, including the European Commission's Standard Contractual Clauses where required. Our Standard Contractual Clauses can be provided upon request.

Firebase (Google) stores data in Google's global infrastructure. DevToDev processes data in accordance with GDPR. RevenueCat's servers are hosted in the United States.

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as your account is active or as needed to provide our Services.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law (such as tax, accounting, or other legal requirements).

When you delete your account via the in-app Delete Account button, we will delete your personal data within 30 days. Some information may be retained in anonymised form for analytics purposes, or where retention is required by law (e.g., financial transaction records retained for up to 7 years for tax compliance).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, information stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process, including:

  • Encrypted data transmission via TLS/HTTPS.
  • Secure server infrastructure hosted on Google Firebase and Apple's platforms.
  • Access controls limiting who can access personal data within our organisation.
  • Regular monitoring of our systems for vulnerabilities.

 

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that unauthorised third parties will not be able to defeat our security measures. You should use the App only within a secure environment.

  1. DO WE COLLECT INFORMATION FROM MINORS?

In Short: The App is rated 16+ and we do not knowingly collect data from children under 16.

The MindChoices App is rated 16+ on the Apple App Store. We do not knowingly solicit data from or market to children under 16 years of age. Users aged 16–17 must have parental or guardian consent to use the App.

If we learn that personal information from users under 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 16, please contact us at info@themindaction.com.

  1. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time. Depending on your location, you may have additional privacy rights.

In some regions (EEA, UK, Canada), you have certain rights under applicable data protection laws:

  • Right to access — request a copy of your personal information.
  • Right to rectification — request correction of inaccurate personal information.
  • Right to erasure — request deletion of your personal information.
  • Right to restriction — request that we restrict the processing of your personal information.
  • Right to data portability — request your personal information in a machine-readable format.
  • Right to object — object to certain types of processing of your personal information.
  • Right to withdraw consent — where we rely on consent, withdraw it at any time without affecting prior processing.

 

To exercise these rights, contact us at info@themindaction.com. We will respond within 30 days. We may need to verify your identity before processing your request.

 

Account Deletion

You may delete your account at any time via the Delete Account button within the App settings. Upon deletion, your personal data will be removed from our active systems within 30 days.

 

EEA / UK Residents

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority. Details available at: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

 

Switzerland

The contact details for the Swiss data protection authority are available at: https://www.edoeb.admin.ch/edoeb/en/home.html

  1. CONTROLS FOR DO-NOT-TRACK FEATURES

Most mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online activities monitored and collected.

The iOS App does not currently respond to DNT signals, as no uniform technology standard for recognising and implementing DNT signals has been finalised. If a standard is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

You can limit certain tracking on iOS by going to: Settings → Privacy & Security → Tracking and disabling "Allow Apps to Request to Track."

  1. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes. Residents of certain US states have specific rights regarding their personal information.

 

California Residents (CCPA / CPRA)

California Civil Code Section 1798.83 and the California Privacy Rights Act (CPRA) give California residents specific rights regarding their personal information:

  • Right to Know — you may request information about the categories of personal information we collect, the purposes for which we use it, and the categories of third parties with whom we share it.
  • Right to Delete — you may request deletion of your personal information, subject to certain exceptions.
  • Right to Correct — you may request correction of inaccurate personal information.
  • Right to Opt-Out of Sale or Sharing — we do not sell or share your personal information for cross-context behavioural advertising.
  • Right to Non-Discrimination — we will not discriminate against you for exercising your privacy rights.
  • Right to Limit Use of Sensitive Personal Information — we do not process sensitive personal information.

 

To exercise your California privacy rights, contact us at: info@themindaction.com. We will respond within 45 days.

 

Categories of personal information collected in the past 12 months:

Category

Examples

Collected

A. Identifiers

Name, email address, user ID, device identifiers

Yes

B. Personal information (Cal. Customer Records)

Name, contact information

Yes

C. Protected classifications

None

No

D. Commercial information

Subscription purchase history

Yes

E. Biometric information

None

No

F. Internet / network activity

App usage, session data (anonymised)

Yes

G. Geolocation data

Approximate location via IP address

Yes (approximate only)

H. Sensory data

None

No

I. Professional / employment information

None

No

J. Education information

None

No

K. Inferences

App usage patterns for personalisation

Yes (anonymised)

 

Other US States

Residents of Colorado, Connecticut, Virginia, Utah, Texas, and other states with comprehensive privacy laws may also have rights similar to those described above. To exercise any applicable rights, contact us at info@themindaction.com.

  1. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes. Residents of certain other regions have specific rights regarding their personal information.

 

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. If you are not satisfied with our response to your privacy inquiry, you can contact the Office of the Australian Information Commissioner (oaic.gov.au) or the New Zealand Office of the Privacy Commissioner (privacy.org.nz).

 

Republic of South Africa

At any time you have the right to: request access to your personal information; request correction; request deletion; object to processing; and withdraw consent. To exercise these rights, contact us at info@themindaction.com. If you are not satisfied, you may contact the Information Regulator of South Africa at inforegulator.org.za.

  1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to, correct, or delete your personal information. To request to review, update, or delete your personal information, please:

  • Use the Delete Account button in the App settings (for account and data deletion).
  • Email us at info@themindaction.com with your request.

We will respond to your request within 30 days (or as required by applicable law).

  1. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Effective" date at the top of this document. If we make material changes, we will notify you by updating the Effective date and, where required by law, by providing an in-app notification. We encourage you to review this Privacy Policy periodically.

  1. HOW CAN YOU CONTACT US?

If you have questions or comments about this Privacy Policy, please contact us at:

 

Company: MindAction LLC (101XP North America LLC)

Address: 155 South Orange Grove Blvd, Unit J, Pasadena, CA 91105, United States

Email: info@themindaction.com

 

 

 MindChoices Privacy Policy  ·  Effective April 10, 2026  ·  MindAction LLC (101XP North America LLC)