Service Privacy Policy YoungMindsApp

Effective Date: April 2025

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YoungMindsApp Ltd ("YoungMindsApp", "we", "us", or "our") takes very seriously and is committed to safeguarding its clients’ privacy. This Privacy Policy describes how we collect, use, process, and protect personal data in connection with our YoungMindsApp Services (the "Services"). This Policy is designed to comply with applicable data protection laws, including the General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR), the UK Data Protection Act 2018, and the California Consumer Privacy Act (CCPA), along with other relevant U.S. privacy laws.

Summary

YoungMindsApp processes two types of personal data:

1. Account and Contact Data – You, the user, are the data subject, and YoungMindsApp is the Data Controller.
2. User Data from Monitored Devices – You act as the Data Controller, and YoungMindsApp acts as a Data Processor.

A. DATA PROCESSED BY YOUNGMINDSAPP AS DATA CONTROLLER

1. Contact Information

YoungMindsApp is the data controller of your account and registration information. For any privacy inquiries, contact our Data Protection Officer at: dpo@youngmindsapp.co.uk.

2. Data Collected

• Registration Data: Name, surname, email address, telephone number.
• Device and Technical Data: IP address, device information, browser type, referral URL, etc.
• Payment Data: Collected and processed by third-party processors per their policies.

3. Purpose of Processing

• Manage and provide Services
• Communications and updates (where consented)
• Support and invoicing
• Compliance with legal obligations

4. Legal Basis

• Contractual necessity
• Legitimate interest
• Legal obligation
• Consent (for marketing communications)

5. Disclosure of Data

Personal data may be shared:

• To comply with legal requirements
• With service providers
• In connection with a sale or merger

6. International Transfers

Your data may be transferred outside the European Economic Area (EEA). Safeguards such as Standard Contractual Clauses (SCCs) are in place.

7. Data Retention

Personal data is retained for the duration of your account and up to five years thereafter, in accordance with legal requirements.

8. Security Measures

We implement industry-standard technical and organizational measures to protect your data.

9. Your Rights (UK, EU, US Residents)

You may:

• Access your data
• Request correction or deletion
• Object to or restrict processing
• Request data portability
• Withdraw consent
• File a complaint with a supervisory authority

To exercise these rights, contact: dpo@youngmindsapp.co.uk.

10. CCPA-Specific Rights (US Users)

California residents may request:

• Disclosure of data collected
• Deletion of personal data
• Data portability

Requests can be submitted via email or support request. Identity verification will be required.

B. DATA PROCESSED BY COMPANYA AS DATA PROCESSOR

1. Role Definition

• You: Data Controller
• YoungMindsApp: Data Processor

2. User Data Collection

Collected from monitored devices, may include:

• Device usage
• Applications and websites accessed
• Communications metadata

3. Processing Instructions

Processing is conducted based on your control panel configuration and support interactions. You are solely responsible for configuring and using the parental control tools and ensuring you have the necessary consents from all individuals whose data you collect, particularly children or minors, where required by applicable law. YoungMindsApp processes User Data exclusively according to your instructions.

4. Retention

User data is retained during the subscription and may be deleted at any time by the account holder. Disassociated data may be retained for analytics.

5. Sub-processors

YoungMindsApp may share User Data with authorised third parties, as listed in Appendix I, who comply with applicable data protection standards.

6. Security Breaches

In the event of a breach, YoungMindsApp will notify you and the competent authority within 72 hours, where required.

7. End of Services

Upon account termination, data is deleted unless legally required to be retained.

8. Users’ Rights

YoungMindsApp will assist you in facilitating any rights requests made by data subjects.

9. Legal Compliance and Indemnification

As the Data Controller, you warrant that:

• You have obtained all necessary consents to collect and process User Data, particularly where such data involves minors.
• You will use the Services in compliance with applicable laws, including data protection laws and child privacy regulations.

You agree to indemnify and hold YoungMindsApp harmless from any claims, damages, or losses arising from the processing of User Data where such claims result from your failure to obtain valid consent or from your misuse of the Services.

C. CHILDREN’S PRIVACY (UK, EU, US)

We comply with:

• Article 8 of the EU GDPR
• UK Age Appropriate Design Code
• US Children’s Online Privacy Protection Act (COPPA)

Parental consent is required before processing personal data of children under 13. We do not knowingly collect data from children under this age without verifiable parental consent.

By using the Services, you confirm that:

• You are the parent or legal guardian of any child whose data you are monitoring.
• You have informed all users aged 14 and above that their device usage may be monitored and have obtained their consent, if required by local law.

D. COMMERCIAL COMMUNICATIONS

Users may receive emails including alerts, promotions, and updates related to our Services. You can opt out at any time by clicking "unsubscribe" or contacting support@youngmindsapp.co.uk.

E. UPDATES TO THIS POLICY

This Privacy Policy may be updated. The effective date will be revised and users will be notified via the platform or email.

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‍Appendix I: Third Party Processors

• Amazon Web Services (AWS) – provides us with cloud hosting services in and outside the European Economic Area (UK). For more information, visit Amazon’s Privacy Policy at:  https://aws.amazon.com/privacy/
• Twilio/SendGrid – is our mail marketing service provider. For more information, visit Twilio’s Privacy Policy at: https://www.twilio.com/legal/privacy