Mintal Tracker

PRIVACY NOTICE

 

Last Updated: January 20th, 2022

HiClub Inc. (“ HiClub ,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Notice explains how your personal information is collected, used and disclosed by HiClub。 This Privacy Notice applies to our websites and our mobile apps for iPhone, Windows or Android mobile devices (collectively, the “Services ”). By accessing or using the Services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Notice and our Terms of Service.

1. INFORMATION WE COLLECT

We collect your personal information in a variety of ways. For example:

• Information you provide to us directly. We may collect personal information, such as your e-mail address when you provide feedback or otherwise communicate with us.
• Data collected through the use of the Services. We collect information through your use of the Services, such as audio files of your breathing activity to detect breathing patterns and to assist you with monitoring your sleep patterns. We also collect information about how you use the Services, your actions on the Services, and content you post to the Services, including providing feedback through the Mintal Tracker App "User Content". Please remember that HiClub may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Services, you consent to the recording, storage and disclosure of such communications.
• Information we receive from third party sites, applications, programs and/or devices you connect to the Services. We may receive personal information about you from third parties and combine that with information we collect through the Services. For example, when you interact with us through a social media site or third-party service, such as when you like, follow or share content on Facebook, Twitter, Pinterest, Instagram or other sites, we may receive information from the social network including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties. At your request, we may also collect information gathered or generated by your use of any third-party application, system, program and/or device that you connect to the Services. For example, if you choose to connect Apple’s HealthKit on your iPhone or Apple Watch, we may receive information such as heart rate, activity (e.g., steps taken), nutrition, sleep data (e.g., sleep times and movement), and information about the source of such data. We use the information obtained through HealthKit to provide you with sleep, health and fitness analysis in connection with our Services. We cannot read or write data from nor to the Apple HealthKit database unless you specifically grant us access to do so. You can stop /disable sharing HealthKit’s sharing of information at any time through your account settings. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or the Services.
• Location information. We may collect information about your location through GPS, Wi-Fi , wireless network triangulation or other method in order to obtain your location for the purposes of providing the Services with your consent. We may also approximate your location by your IP Address.
• Audio information. Upon installation of the app, we may request access to your microphone or audio recordings for purposes such as: to measure your breathing and snoring, to detect your body movements and snoring sounds, to identify any disruptions to your sleep environment, and to determine sleep duration and quality. Thus, we may collect information through your microphone or from audio files. We may also collect information in connection with the audio recording that you provide through the recording labeling feature, which allows you to assign labels to each recording, and which allows for better sound identification (e.g., “snoring”, “dream talk”, “TV”). At your request, we may also back up your audio recordings and associated information so that you may access them from other devices when you log into your Mintal account.
• Calendar information. In connection with your use of the app, we may request access to your calendar for purposes of adding a reminder for you to return to the app to complete certain activities, such as tracking your sleep. If you choose to provide us access to your calendar, your device’s operating system may provide us with access to all the content in your calendar. We only use our access to the calendar to add the reminders you requested and do not otherwise collect or process calendar information.
• Facial Geometry. When using some features of the service, such as the snoring score functionality and the beauty sleep program, with your consent, we access and your device’s camera and collect your images and your facial geometry through the use of facial recognition technology. If you use the snoring score functionality, we may use this information to analyze your facial morphology by using artificial intelligence to match your facial geometry against an images database. This analysis allows us to provide you with a score based on the likelihood that you will snore. If you use the beauty sleep program, collecting your facial geometry allows us to detect skin-related facial information such as type of facial information, position, number, area of wrinkles, acne, dark circles, eye bags, pores and blackheads. We use this information to provide you with a “skin score” based on the conditions detected.

The images and facial geometry collected are only used to conduct the analysis and are not stored in our systems (we delete them as soon as our analysis is complete). Please note t he information provided through the use of our services, including the snoring score feature or the beauty sleep program, is not intended or implied to be a substitute for professional medical advice, diagnosis or treatment.

• Single Sign-On. We may use single sign-on (“SSO”) to allow a user to authenticate their account using one set of login information, including through Google or Apple. We will have access to certain information from those third parties in accordance with the authorization procedures determined by those third parties, which may include, for example, your name, username, email address, and profile picture. We use this information to operate, maintain, and provide to you the features and functionality of the Service. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to the features of the Site, technical and security notices.).
• Payment Transaction Information. If you make a purchase or payment on the Service, such as for a subscription, we collect information provided in connection with your transaction such as name, user ID, transaction date, and type of subscription purchased. We use this information to manage our paid services and to better tailor our offerings. Please note that we use third party payment processors, including through the Apple and Google Play stores, to process payments made to us in connection with paid content, such as premium subscriptions. As such, we do not retain any personally identifiable financial information such as payment card numbers. Rather, all such information is provided directly to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice.
• Other information. We may collect additional information if you contact us or otherwise interact with us directly, such as by participating in a contest or promotion. We may also collect any communications between you and HiClub, and any other information you provide to HiClub.

 

2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

We, and our third party partners, automatically collect certain types of usage information when you visit the Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, inclu ding cookies, web beacons, embedded scripts, location-identifying technologies, file information and similar technology (collectively, “ tracking technologies ”).

We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:

• Your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile d evice or your account, and other such information.
• We also collect information about the way you use the Services, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other actions you take on the Services.
• When you access the Services from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (incl uding, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
• We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Services and to understand more about our users by monitoring aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and online services; (b) provide and monitor the effectiveness of our websites and online services; (c) monitor online usage and activities of our websites and online services; (d) diagnose errors and problems with our websites and online services; (e) otherwise plan for and enhance our online services; and (f) facilitate the purposes identified in the Our Use of Personal Information section below.

We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver ads and information about products and services that may be of interest to you.

Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described above.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Third Party Tracking and Online Advertising below.

3. OUR USE OF INFORMATION

We may use your information, including your personal data, as follows:

•          To operate, maintain, and provide to you the features and functionality of the Services, including provide software updates, product support, product enhancements and other services to you related to the Services;

•          To provide you with products or services that you request or in which you express interest, such as to back up your sleep reports at your request;

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•          To remember your information so you will not have to re-enter it during a subsequ ent visit; recognize and contact you across multiple devices; provide, improve, test, enhance, update and monitor the Services; or diagnose or fix technology problems;

•          To improve, market or promote HiClub’s products and services (including the Services ), for research and product development, and to perform analytics;

•          To communicate directly with you, such as to send you email messages, calendar notifications and push notifications in connection with the Services or your account (e.g., account verification, account reminders, changes or updates to features of the Services, technical and security notices).

•          To customize the advertising and content you see, such as by providing suggestions for how to improve the quality of your sleep based on your sleep reports;

•          To alert you to product upgrades, special offers, updated information and other new products and services offered by HiClub, our Customers and our third-party partners;

•          To respond to comments, questions or requests for customer service;

•          To display advertisements, including advertisements from third parties;

•          To address a violation of the Terms of Service, rules, regulations or policies of the HiClub relating to the Services;

•          For any other purpose we may describe when you provide the information.

4. HOW WE SHARE YOUR INFORMATION

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the Control Over Your Information section below.

We may share your personal information with:

• Third parties at your request. For example, you may have the option to share your activities on the Mintal Tracker App with your friends through email, text or on various social media sites;
• Other companies and brands owned or controlled by HiClub and other companies owned by or under common ownership as HiClub, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Notice;
• With third pary marketing or promotional partners, who may use your information for their own purposes as well as for the benefit of our marketing and promotional activities.
• Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, contest fulfilment, web hosting, or providing analytic services;
• The public when you provide feedback or user content on our site. For example, if you comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our social media pages;
• Other third party services and systems that you connect to the Services, such as Apple HealthKit. You may instruct us to share or write certain information, such as your as your heart rate, activity (e.g., steps taken), nutrition, sleep data (e.g., sleep times and movement), with third party systems such as Apple’s HealthKit on your iPhone or Apple Watch. You may disable sharing permissions at any time in your account settings. HiClub is not responsible for the protection of any information that you agree to share and store in HealthKit, which is governed by Apple’s privacy policy and other applicable terms. We encourage you to review Apple’s applicable policies, terms and procedures before sharing or syncing any information with the HealthKit service.
• Other parties in connection with a HiClub transaction, such as a merger, sale of HiClub assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another HiClub or third party, or in the event of a bankruptcy or related or similar proceedings; and
• Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of the Services; and/or (c) to exercise or protect the rights, property, or personal safety of HiClub, le="font-family:Calibri; font-size:10pt"> our visitors, or others.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

5. CONTROL OVER YOUR INFORMATION

Access to your Device Information. You may control the app’s access to your device information and your geolocation through your “Settings” app on your device. For instance, you can withdraw permission for the app to access your location, microphone or calendar. Please note, the Services may not be able to function properly if it cannot access your microphone data.

How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).

Modifying or deleting your information: If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at trackerhiclub@gmail.com. We may not be able to modify or delete your information in all circumstances.

6. THIRD PARTY TRACKING AND ONLINE ADVERTISING

Interest Based Advertising. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We may share, or we may permit third party online advertising networks, social media companies and other third-party services, to collect, information about your use of our website and apps over time so that they may play or display ads on the Services, on other devices you may use, and on other websites, apps or services, including on Facebook. These third parties may collect information such as click stream information, browser type, time and date you visited the site, mobile device identifiers, app usage, and/or precise geolocation data and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

Social Media Widgets and Advertising. The Services may include social media features, such as the Facebook Like button, LinkedIn, Snapchat, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to the Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in the Services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.

Cross-Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to the Services. We may also work with third party partners who employ tracking technologies, or the application of statistical modeling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.

Your Choices:

• Cookies. If you would prefer not to accept cookies, m ost browsers will allow you to adjust your browser settings to: ( i ) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.

Blocking or deleting cookies may negatively impact your experience using the Services, as some features and services on the Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at: http://www.google.com/policies/privacy/partners You can also view Google’s currently available opt-out options at: https://tools.google.com/dlpage/gaoptout .

• Online advertising. We support the self-regulatory principles for online behavioral advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info . If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices , or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices .

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services.   It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

7. HOW WE STORE AND PROTECT YOUR INFORMATION

Data storage and transfer: Your information collected through our website may be stored and processed in the United States or any other country in which HiClub or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our website. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

8. CHILDREN’S PRIVACY

HiClub does not knowingly collect or solicit any information from anyone under the age of 13 on the Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at trackerhiclub@gmail.com .

9. LINKS TO OTHER WEB SITES AND SERVICES

The Services may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

10. REGION-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

• If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
• If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at trackerhiclub@gmail.com .

11. HOW TO CONTACT US

If you have any questions about this Privacy Notice or the website, please contact us at trackerhiclub@gmail.com .

12. CHANGES TO OUR PRIVACY NOTICE

We may modify or update this Privacy Notice from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy, we will update the “Last Updated ” date above. If you object to any changes, you may close your account. Continuing to use the Services after we publish changes to this Privacy Notice means that you are acknowledging and consenting to the changes.