PRIVACY POLICY

LATEST UPDATE: MAY 7, 2017

OUR POLICY

Jaedye Labs Pte. Ltd. ("MindFi", "us ", "we", or "our") provides users with information, services, and tools through the MindFi.co website, the MindFi mobile applications ("Apps"), and other websites, apps, and online services that link to this Privacy Policy (collectively, the "Services"). This Privacy Policy sets forth our policies with respect to how we collect, use, and share information through the Services. This Privacy Policy is incorporated by reference in the MindFi.co End User Terms of Use, which govern your use of the Services.

By voluntarily providing us with Personal Data, as defined below, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data through the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to our offices and servers, or those of our affiliates or contractors, located in Singapore and other countries. Those countries may have data protection laws that are different from those in your country of residence. If you would like us to cease using your Personal Data, you may delete your account by following the instructions provided in the "Data Retention and Deletion" section below or exercise the choices described in the "Your Choices and Access to Information" section below.

INFORMATION WE COLLECT

We collect both Personal Data and Other Information in connection with the Services. "Personal Data" is information that relates to an identified or identifiable natural person, such as your name, email address, and similar information associated with your MIndFi account. "Other Information" is any information that is not Personal Data, such as information about usage of the Services that does not identify you personally. If we combine Other Information with Personal Data, we will treat the combined information as Personal Data in accordance with this Privacy Policy.

We collect various types of Personal Data through our Services, including:

To learn more about how we use and share location data, please see "Our Use of Your Personal Data and Other Information" and "Our Disclosure of Your Personal Data and Other Information" below. If you would like to stop the collection of precise location information through our Apps, you can adjust your mobile device settings by following the instructions here for iOS 8 and later and here for Android 6.0 and later.

We also collect Other Information through our Services. Such information may be collected passively using various technologies, or via submission of data by fitness devices you have configured to work with the Services. We may store such information ourselves, or it may be included in databases owned and maintained by our affiliates, agents, or service providers. We may use such information and pool it with additional information to track, for example, the total number of visitors to the Services, the number of visitors to each page of the Services, and the domain names of our visitors' Internet service providers. Other Information may be collected in the following ways:

OUR USE OF PERSONAL DATA AND OTHER INFORMATION

We use the Personal Data and Other Information we collect for various purposes, including:

OUR DISCLOSURE OF PERSONAL DATA AND OTHER INFORMATION

We may share your Personal Data and Other Information with third parties in the following circumstances:

YOUR CHOICES AND ACCESS TO INFORMATION

We provide users with a variety of choices regarding how we or third parties collect, use, and share information, including as follows:

If you are a California resident under 18 years of age and a registered user of our Services, you may request that we remove content and information that you post on our Services. To obtain removal of such content and information, please send us an email at help@mindfi.co with a short description of the content or information you would like to have removed. Please note that such a request does not necessarily ensure complete or comprehensive removal of content posted by you, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been re-posted by another user.

Users may have additional rights to access, review, correct, delete, or inquire about information that we hold about them. To make such a request, please send us an email at help@mindfi.co . Please note that we may need to verify your identity or request additional information from you before we are able to comply with your request.

DATA RETENTION AND DELETION

We retain information for as long as reasonably necessary to deliver our Services to you or to fulfill the purposes described in this Policy. For example, we may retain your profile information and information about your fitness activities for as long as you maintain your MindFi account. This provides you with the ability to review your activities over time, track your progress toward personal goals and challenges, and remember your past achievements and milestones (for example, your first session, or other personal achievements).

If you choose to delete your MindFi account, we will make our best effort to delete all information associated with your account, including your profile information, historical fitness activities, historical location information, and third-party authorizations for services connected to your account (e.g., Facebook, Twitter, Fitbit). However, please note that certain information may be retained in backup databases or for analytics purposes.

In limited circumstances, we may retain information for a longer period of time as required by law.

SECURITY

We implement reasonable administrative, technical, and physical measures to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via e-mail or the Internet.

DATA INTEGRITY

We process Personal Data for our legitimate business purposes and in accordance with this Policy or any applicable service-specific privacy notice. We take reasonable steps to ensure that the Personal Data we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Data whenever necessary.

HEALTH INFORMATION

We do not use information collected through the Services to infer health information that we consider sensitive, such as a user's past, present or potential future health or medical condition or treatment, including but not limited to genetic, genomic, and family medical history. We may, however, infer a user's potential interest in certain non-sensitive health and wellness categories, such as exercise and fitness activities, diet and weight loss, nutrition, healthy living, or physical and massage therapy. We may use this non-sensitive health and wellness information for the purpose of delivering more relevant content, services, offers to our users.

CHILDREN

We do not knowingly collect Personal Data from children under the age of 13 and do not target our Services to children under 13. If you are under 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Data through any of our Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us, please contact us, and we will endeavor to delete that information from our databases.

LINKS TO OTHER WEBSITES OR SERVICES

This Privacy Policy applies only to information collected through the Services. The Services may contain references or links to other websites or services not operated or controlled by us (the "Third Party Services"). The policies and procedures we described here do not apply to the Third Party Services. The links from the Services do not imply our review or endorsement of the Third Party Services. We suggest contacting those sites directly for information on their privacy policies.

CHANGES TO OUR PRIVACY POLICY

Our Services may change from time to time. As a result, we may need to change this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. We will post any revised Privacy Policy on our website with an "effective date" indicating when the changes will take effect. We encourage you to review this Privacy Policy periodically, and especially before you provide any Personal Data. Your continued use of the Services after a revised Privacy Policy becomes effective shall indicate your agreement with the terms of such revised Privacy Policy.

CONTACTING US

If you have any questions or concerns about this Privacy Policy or our information collection, use, and sharing practices, please feel free to contact us at any time at help@mindfi.co