Privacy policy

Mindspa OÜ (“,” “Supplier”, “us,” “we,” or “our”) is committed to protecting and respecting your privacy in connection with your use as an end consumer or as a business consumer or affiliate of our Site(s), (the “Site”, the “Website(s)”), applications (“Apps”) and other products, services and features thereof (the Site, the Apps and such other products, services and features are collectively referred to herein as the “Services”, “Product” or “Products”, which may be updated from time-to-time at the sole discretion of This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal information or payment information we collect from you, or that you provide to us, in connection with the Services and Products will be processed or stored by us. Please read the following Privacy Policy carefully to understand our practices regarding your personal information and how we will collect, use and disclose it. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our customer support team.

Information we may collect from you

By agreeing to this Privacy Policy, you acknowledge and agree that may collect and process the following data:

  • Personal information including, your name, e-mail address, telephone, home address, gender, date of birth, payment details, company’s name, registration and VAT number, billing address, e-mail address, phone number, and payment details, as well as information about your usage of the Services and Products, and information collected by tracking and/or API technologies (including those by Google or YouTube, in which case you are bound by Google’s Privacy Policy and YouTube’s Privacy Policy) as further described below that may identify you as an individual or allow online or offline contact with you as an individual.
  • Personal information about your well-being including sleep patterns, perceived levels of stress, and perceived levels of happiness, will be collected should you choose to record it in the app by taking the Clarity Test.
  • For individuals using the Products in connection with Groups, Teams, for Business, and Other Community Sharing options, additional information about your business may be requested such as your team members’ telephone numbers and e-mail addresses as well as other related data such as details about your payments and/or refunds.
  • Facebook, Apple, and Google profile information, such as name, email address, Facebook ID and profile picture, Apple ID and profile picture, and Google ID and profile picture, if you choose to log in to the Products through Facebook, Apple or Google.
  • Device information, such as operating system version, device type, amount of free storage on the device, and system performance information.
  • Information collected via tracking technologies as fully described in the section Tracking Technologies below.
  • If you choose to invite a “friend” to use the Products using our system, we may ask for their name, email address, and any relevant additional data that may be collected and stored. We will use this information to invite him or her to join the Products and Services. We store this information for the sole purpose of sending invitations. If your friend would like us to delete his or her information, they can do so by opting out as described in each invitation or by contacting us at
  • If, as a Account holder, you choose to invite additional friends to by sending them a free demo offer, Gift Card, or another campaign by, we will ask for their name and email address or other data. We will use this information to invite him or her to join the Services and Products and track the success of the program. We store this information for the sole purpose of sending invitations to Services and Products. If your invited friends would like us to delete their information, they can opt out as described in each invitation or by contacting to be removed.

Payment details

Mindspa does not store or directly process credit or debit card (“Payment Card”) information. Apple and Google collect and process Payment Card information with respect to in-app purchases made through the Apps, and our third-party payment processors/gateways (including EveryPay, PayPal and Stripe) to collect Payment Card information with respect to purchases made through the Site. These payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they have – stored, your card’s type, expiration date, billing address, email and name, order reference number, date of transaction and the last four digits of your card number. You agree to provide such payment details for storing and processing to our third-party payment processors/gateways for charges and auto-renewals by subject to the Terms of Use. You further agree that a cookie or token may be placed and stored on your device to facilitate such charges and auto-renewals.

Confidentiality and security

The security of your personal information is very important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at Except for the cases described under the “Disclosure of Your Information” section below, we do not provide your personal information to any third party without your specific consent, as defined by applicable law.If you would like to delete your personal information, you can contact us at or, if you wish to delete all data we have collected from you, please go to your profile settings page on the website or mobile and select “delete your account” (this deletes your User Account and all data we have about you).

Newsletters or other electronic communications

If you sign up to receive promotional materials from us via email, we will use the information given by you to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level. If you provide your phone number to us directly or through a third party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such an SMS message (the “SMS Service”). Standard text message rates will apply.

Tracking technologies and our analytics partners use technologies such as cookies, tokens, beacons, tags, and scripts to enable a service to recognize your device so you don’t have to provide the same information several times during one task, recognize that you may have already given a username and password so you don’t need to do it for every web page requested and to measure how users are engaging with the Services, Apps, and Products.

We use local storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on the Services, Apps, and Products also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms as well as across your other devices based on your past visits to our website. Our third-party partners may use technologies such as cookies or tokens to gather information about your activities within the Services, Apps, and Products to deliver such advertising to you, such as retargeting ads. We will acquire consent from you in order to use such trackers for advertising purposes to the extent required by applicable law. We currently do not respond to do-not-track signals.

For more information about interest-based ads, including how to opt out of having your web browsing information used for behavioral advertising purposes, please visit Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third-party platforms. You may also opt out of receiving ads across devices by adjusting your ad preference in your Google account.

We use third-party trackers to let us know when users have visited the Services, Apps, or Products by “clicking through” our sponsored advertising or content hosted on third-party platforms. The Services, Apps, and Products use Google Analytics code to gather statistical information. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Services, Apps, and Products and the volumes of usage of the Services, Apps, and Products. This is done to ensure that the Services, Apps, and Products are available when you want them and are fast. For more information on how Google Analytics processes this information, visit You can also read Google Privacy Policy at

YouTube API clients

The App and Services may use an API Client that uses YouTube API Services. When you are using the app and Services, you also agree to be fully bound by the Google Privacy Policy at, as well as YouTube’s Terms of Service at

Through the API, we may collect and store your e-mail address, as well as usage of the app content, statistics, and information that is logged and displayed to you. does not share this API Data related information with third parties. does not allow third parties to serve content, including advertisements through the API Client.

You can contact our customer support at with all relevant inquiries.

Mobile analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application.

Log files

As with most websites, we gather certain information and automatically store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.


“Cookies” are small text files that are placed on your device by a web server when you access our Services. We may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you do not accept cookies, you might be unable to access all portions or features of the Services. Some third-party service providers that we engage with (including third-party advertisers) may also place their own cookies on your device. Note that this Privacy Policy covers only our use of cookies and does not include the use of cookies by such third parties.


“Pixels”/“Web Beacons” (also known as Web bugs, pixel tags, or clear GIFs) are small graphics with a unique identifier that may be included in our Services for several purposes, including delivering or communicating with cookies to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an email).


“Social Media Widgets”, such as the Facebook “like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs) may be on our Site. These features may collect your IP address and which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing them.


We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services and to develop website content. This analytics data is not tied to any personal information.

For more information about Google Analytics, please visit You can opt out of Google’s collection and processing of data generated by your use of the Services by going to’s use of such technologies fall into the following general categories:

Operationally necessary

We may use cookies, web beacons, or other similar technologies that are necessary for the operation of our Sites, Services, Applications, and tools. This includes technologies that grant you access to our Sites, Services, Applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping carts, saved search, or similar functions;


We may use cookies, web beacons, or other similar technologies to assess the performance of our Sites, Applications, Services, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve the Site content, Applications, Services, or tools;


We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, Applications, or tools. This may include identifying you when you sign in to our sites or keeping track of your specific preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;

Advertising or targeting-related

We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or third-party sites. This includes using technologies to understand the usefulness of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement or not. If you would like to opt out of the Technologies we employ on our Sites, Services, Applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Location information

In some cases, we may collect and store information about where you are located, such as by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

Where we store your personal information

All information you provide to us through the Services, Apps, and Products is stored on our secure servers located in the US and the European Union. Any payment transactions will be encrypted using SSL technology; all payment information is stored with our payment processor and is never stored on’s servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and suggest that you change your password frequently.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the Products; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Groups, business users, and other community sharing

If you have registered to use the Products through a code or other registration credential furnished by a Group (a “Group Subscription”, “Team”, “Team Subscription”, “Business Subscription”, “B2B” or any other mass subscription package or B2B Admin page), this Privacy Policy applies in full., the Group, and Admin may have access to your name and the date you registered to use the Products and will have access to your usage information on an aggregated basis with all other members of the Group that are using the Products. Your Group may also have access to your usage information on an individual basis if you have provided appropriate consent for such sharing.

Single sign-on

You can log into our Products using sign-in services such as Facebook Connect, Google Sign-In, or an Open ID provider. These services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities on our Products or to your profile page to share with others within your network.

Access to and deletion of personal information

Upon request, will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please email

You may access your personal information to modify or update at any time via an online account, or by emailing

To request the deletion of your personal data that we have on file please email us at Upon request, will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual.

We will respond to your request in a reasonable timeframe.

Disclosure of your information

  • In some circumstances, based on your specific requests, we may need to disclose your personal information to a third party so that they can provide a service you have requested from such a party, or fulfill a request for information from such a party. An example of this is the SMS Service.
  • In some circumstances, we may disclose the personal information that you have provided to to a third party that offers and/or provides goods or services complementary to our own to enhance our users’ experiences by offering you integrated or complementary functionality, complementary services, or bundled pricing options.
  • If’s service providers (like hosting, market analytics, and payment service providers) require this information to provide services to requires each of its service providers to agree to maintain the confidentiality and security of your personal information.
  • In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
  • If or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, or similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
  • With your Community, if your subscription is a Community Subscription, as described under Corporate and Other Community Sharing above.
  • With third parties, such as Facebook and Google, in order to serve advertisements on such third-party platforms, to the extent that you have consented to such practices under applicable law.

Withdrawal of consent for processing activities

To the extent that you have provided appropriate consent under applicable law to certain processing activities, such as the use of trackers for retargeting activities, such consent can be withdrawn at any time by emailing

Links to third-party sites

The Services, Apps, and Products may, from time to time, contain links to and from the Products of our partner networks, advertisers, and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal information to these external websites.

International transfer

Your personal information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. By choosing to visit the Site, utilize the Services, or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the Republic of Estonia, and the adjudication of any disputes arising in connection with or the Site will be per the Terms of Use.

Data retention retains the personal information we receive as described in this Privacy Policy for as long as you use our Services, Apps, and Products or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

HealthKit, GoogleFit, and other health apps

Mobile users, including Apple iOS and GoogleFit and Google users, may opt-in to allow the Products to provide personal data regarding the use of, such as the number of minutes and the number of times listening to the tracks to the health apps found on their mobile devices. This data will not be shared with third parties or used for marketing purposes.

Children policy

Our Services are not directed to children under 13 and we do not knowingly collect personal information from children under 13. If we learn that we have collected the personal information of a child under 13 we will take steps to delete such information from our files as soon as possible. If you are under the age of 18, you must have your parent’s permission to access the Services, Apps, and Products.

Information posted on forums users may have the ability to post content to one or more forums. All such users may request and obtain the removal of such posted content by contacting at and specifically identifying the content to be removed. Please be advised that any such removal does not ensure the complete or comprehensive removal of all traces of the content posted on the forum(s).

Cookies and interest-based advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at, or and You can also choose not to be included in Google Analytics here.

Whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted out of. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. Advertisements on third-party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Changes to our Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by in-Product message, email (sent to the e-mail address specified in your account), or by employing a notice in the Products before the change becomes effective. We encourage you to periodically review this page for the latest information on our privacy practices.


Please contact us at if you have any questions about our practices or this Privacy Policy.