Mindality Privacy Policy


Effective date: 18 August 2026
Last updated: 18 August 2026


Mindality (“we”, “us”, “our”) provides tools for mood logging, emotional reflection, and optional
AI-powered chat and insights. This Privacy Policy explains what data we collect, how we collect it, how
we use it, who we share it with (including our AI provider), how long we retain it, and the choices and
rights you have.


1. Data Controller
Aston Traders Ltd
Company registration number: 10399056
Email: support@mindality.io


2. Key Principle: AI Processing Requires Consent
Mindality includes features that send certain user-provided content to a third-party AI service to generate
responses and insights. When you register for Mindality and select “I agree to the Mindality Privacy
Policy” on the registration page, you provide consent for the processing described in this Privacy Policy,
including the processing of relevant data by OpenAI for Mindality’s AI features. The registration page
provides access to this Privacy Policy before you complete registration. You can withdraw consent at
any time in the app’s Settings, which stops AI processing.


3. What We Collect
A) Account & Identifiers
• Email address (if you create an account).
• Internal account record needed to operate the service (we do not send your email or internal user ID
to our AI provider).
• App settings (e.g., language preferences).
B) User Content You Provide
• Mood check-in score and timestamp.
• Mood “Why?” notes and reflections.
• Chat messages you type into Mindality’s AI chat.
C) App Usage & Diagnostics
• Basic usage data necessary to provide features (e.g., streak count).
• We do not use third-party analytics or crash reporting tools at this time.


4. How We Collect Your Data
We collect information when you provide it directly through the App, and when information is generated
or retrieved automatically as needed to provide App features.

• Registration: your email address and account information are provided when you register for an
account.
• Mood check-ins: mood scores and timestamps are entered by you through the App.
• Reflections: mood “Why?” notes and other reflections are entered by you.
• AI chat: chat messages are entered by you through Mindality’s AI chat feature.
• AI context: when AI functionality is used, the App may retrieve your last 30 days of mood score
history and relevant saved conversation context to provide context for the AI request.


5. How We Use Your Data
• To provide mood logging, history, and summaries.
• To provide AI chat responses and AI-generated insights (only with the consent described in Section
2).
• To maintain app security, prevent abuse, and troubleshoot service issues.
• To comply with legal obligations.


6. AI Processing (Apple Requirements: what, who, permission)
Who the data is sent to
• OpenAI (OpenAI, L.L.C.) via the OpenAI API.
What data is sent
• Chat messages you submit.
• Mood “Why?” notes/reflections you submit.
• Mood score history for the last 30 days (used as context for insights and chat).
• Summarized chat context (we summarize prior conversation context before sending it as part of a
request).
What we do not send
• Your email address.
• Your internal user ID.
Why it is sent
• To generate AI chat responses.
• To generate AI insights and recommendations based on your inputs.
How we obtain your permission
During registration, Mindality asks you to agree to the Privacy Policy by selecting “I agree to the Mindality
Privacy Policy”. By completing registration after being shown the Privacy Policy, you consent to the
processing described in this policy, including the processing of your chat messages, reflections, and last
30 days of mood scores by OpenAI for Mindality’s AI features. The Privacy Policy is available from the registration page before registration is completed. You may withdraw consent at any time in the App’s
Settings. Withdrawal of consent does not affect processing that occurred before consent was withdrawn.
Third-party AI provider privacy and protection
OpenAI processes the information described in this section as a third-party service provider used by
Mindality to provide AI functionality. We require third-party service providers that process personal data
on our behalf to protect that data in accordance with applicable data protection requirements and to
provide protections consistent with those described in this Privacy Policy. For information about
OpenAI’s privacy and data practices, users can review OpenAI’s applicable privacy and data processing
documentation.


7. Storage, Retention, and Deletion
Where we store data
Mindality stores your mood logs and chat history in our database hosted by Supabase in the EU region.
Retention
We store your account data, mood logs, and chat history for as long as your account remains active,
unless you delete the relevant data or delete your account. We do not log prompts/responses for
debugging outside of this stored history. When an account is deleted, we delete or anonymize personal
data from our systems, subject to any legal, security, or other lawful retention requirements.
Account deletion
You can delete your account at any time in the App by going to Settings > Account > Delete Account >
Confirm. When you delete your account, we delete or anonymize your personal data from our systems,
unless retention is required by law.


8. Third Parties and Subprocessors
Mindality uses the following third-party processors to operate core functionality:
• Supabase (EU region) for authentication and database hosting.
• OpenAI via the OpenAI API for AI chat and insights (only after consent, as described above).
We do not sell personal data. We only share personal data with third parties where necessary to provide
the App and its features, where you have consented to the relevant processing, or where required or
permitted by law. We require third-party processors acting on our behalf to provide appropriate
protection for personal data consistent with this Privacy Policy and applicable data protection
requirements.


9. International Data Transfers
OpenAI is based in the United States. When you use AI features, the content described in Section 6 may
be transferred to and processed in the United States or other jurisdictions where OpenAI operates. We
take steps to ensure appropriate safeguards for such transfers.


10. Security
We use reasonable technical and organizational measures to protect your data, including encryption in
transit and access controls. No method of transmission or storage is completely secure.

11. Your Privacy Rights
Depending on your location and applicable data protection law, you may have the following rights in
relation to your personal data:
• Access: request a copy of the personal data we hold about you.
• Correction: request correction of inaccurate or incomplete personal data.
• Deletion: request deletion of your personal data, subject to applicable exceptions.
• Restriction: request that we restrict certain processing of your personal data.
• Objection: object to certain processing where applicable.
• Data portability: request your personal data in a structured, commonly used and machine-readable
format where applicable.
• Withdraw consent: withdraw consent where processing is based on consent. You can withdraw
consent to AI processing through the App’s Settings.
To exercise a privacy right or ask a privacy question, contact support@mindality.io. We may need to
verify your identity before completing certain requests. You also have the right to lodge a complaint with
the relevant data protection authority, including the UK Information Commissioner’s Office (ICO), where
applicable.


12. Sensitive Information & Safety Notice
Mindality is not a medical device and does not provide diagnosis or emergency services. Please do not
enter payment card numbers, passwords, government identifiers, or other highly sensitive information
into the App. If you are in immediate danger or considering self-harm, contact local emergency services.


13. Children
Mindality is not intended for children under 13. We do not knowingly collect personal data from children
under 13. If you believe a child has provided personal data, contact us at support@mindality.io.


14. Changes to This Policy
We may update this Privacy Policy from time to time. If changes are material, we will provide notice
within the App or through other reasonable means.


15. Contact
For privacy questions or requests, contact: support@mindality.io

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