MINTAL SLEEP

PRIVACY NOTICE

Last Updated: 14th.Apr.2021

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. We may also collect personal information, such as payment method, through our third-party payment processors, including the Apple App Store and Google Play App Store.
Data collected through the use of the Services. We collect information through your use of the Service, such as audio files of your breathing activity to detect breathing patterns and to assist you with meditations. We also collect information about how you use the Services, your actions on the Services, and content you post to the Service, including providing feedback through the Mintal Sleep 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.
Location Information. We may collect information about your location through GPS, WiFi, 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.
Information we receive from third parties. From time to time, we may receive information about you from third parties and other users, such as your Apple billing record. We may also collect information about you that is publicly available.
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, including 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 device 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 (including, 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;
To remember your information so you will not have to re-enter it during a subsequent 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 and push notifications in connection with the Services or your account (e.g., account verification, change or updates to features of the Services, technical and security notices).
To customize the advertising and content you see;
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:

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 party 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 or third party sites. For example, if you comment on our social media fan pages, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on such social media pages;
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

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, 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 through your “Settings” app on your device. For instance, you can withdraw permission for the app to your microphone. Please note, the Service may not be able to function properly if it cannot access your microphone data.

How to control your communications preferences: In the event that we send promotional emails, 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 sleephiclub@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, most 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.
Google Analytics and Advertising. We use Google Analytics to understand the demographics of our users and how our users interact with our Service and to tailor our advertisements and content to you. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

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 sleephiclub@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 sleephiclub@gmail.com

11. HOW TO CONTACT US

If you have any questions about this Privacy Notice or the website, please contact us at sleephiclub@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 and 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.

MINTAL SLEEP

CALIFORNIA PRIVACY NOTICE

Last Updated : 14th.Apr.2021

CALIFORNIA RESIDENTS

This section applies to you if you are a resident of the state of California. California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device, or that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, such as the HIPAA, the FCRA, GLBA or the Driver's Privacy Protection Act of 1994. This section does not apply to information relating to our employees, contractors, applicants and other personnel. This section also does not apply to personal information we collect when we are acting as a “service provider” to process information in accordance with a contract with our business customers.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information from and about you for a variety of purposes.

To learn more about the types of personal information we collect and the purposes for which we use this information, please refer to the Information We Collect, How We Use Cookies and Other Tracking Technology to Collect Information and Our Use of Information sections of our Privacy Notice .

In the last 12 months, we have collected the following categories of personal information:

Identifiers , such mobile device IDs;
Commercial information , such as purchase history;
Internet/Network Information , such as device information, logs and analytics data;
Sensory Information , such as audio files of your breathing activity when the sleep monitoring function is enabled;
Other Personal Information , including information you submit into the feedback form;
Inferences , such as predictions about your sleep habits based on usage of the app, and your clicking and browsing patterns.

DISCLOSURE OF PERSONAL INFORMATION

As described in the Information Shared With HiClub and the Sharing Information With Other Parties sections in our Privacy Notice , we share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see The Right to Opt-Out of Personal Information Sales section below).

The categories of third parties to whom we sell or disclose your personal information for a business purpose may include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks.

In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:

All of the categories of personal information we collect, explained above.

Unless you have exercised your Right to Opt Out of personal information sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.

In the previous 12 months, we have sold the following categories of personal information to third parties:

Personal Identifiers
Internet
Other Information

As is common practice among companies that operate online, we have permitted third party advertising networks, social media companies and other third party businesses collect and disclose your personal information (including Internet / Network Information, Commercial Information, and Inferences) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. To learn more, please see the Third Party Tracking and Online Advertising section of our Privacy Notice .

YOUR CALIFORNIA CONSUMER RIGHTS

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know	You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: The specific pieces of personal information we have collected about you; The categories of personal information we have collected about you; The categories of sources of the personal information; The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and The business or commercial purposes for collecting or, if applicable, selling the personal information.
The Right to Request Deletion	You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales	You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination	You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
“Shine the Light”	California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

TO EXERCISE YOUR CALIFORNIA CONSUMER RIGHTS

To Exercise Your Right to Know or Right to Deletion

To exercise your Right to Know or your Right to Request Deletion, please submit a request by:

Filling out our California Consumer Rights Request Form, or
Emailing us at gtfeedback@creativeappnow.com

We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

To Exercise Your Right to Opt Out of Personal Information Sales

To exercise the Right to Opt Out of Personal Information Sales, you may submit a request by clicking the following link:

Do Not Sell My Information

Third Party Tracking and Online Advertising

We do allow certain third-party partners and providers to collect information about consumers directly through our services, from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our service as well as other sites and services. These third parties use your personal information for purposes of analyzing and optimizing our services and ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.

Please see the Third Party Tracking and Online Advertising section of our Privacy Notice for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those activities.

Minors Under Age 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at gtfeedback@creativeappnow.com to inform us if you, or your minor child, are under the age of 16.

California’s “Shine the Light” Law

California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click Do Not Sell My Information and provide your contact information to be added to our suppression list.

ADDITIONAL INFORMATION

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to gtfeedback@creativeappnow.com