Last revised: March 2019.
1. General provisions
You will also transfer certain information to us when you access our website or the 7Mind App, e.g., your IP address. We will also receive data about which terminal device (computer, smartphone, tablet, etc.) you are using, which browser (Internet Explorer, Safari, Firefox, etc.) you are using, the time at which you access the website and/or the 7Mind App, the so-called referrer, and the data volume transferred.
Such data cannot be used by us to identify the user. It is used for statistical purposes only. Such analyses help us make our services more attractive and, if necessary, to improve our services.
2. What are personal data?
The term“personal data” is defined by the Federal Data Protection Act (BDSG) and, after its effective date, the European General Data Protection Regulation (GDPR). You can think of your personal data as any data that allow you to be identified or that can be correlated to you. Such data include, for example, your name and contact information. We need some of this information so that we can offer you our 7Mind Services.
On the other hand,“non-personal” data cannot be correlated to any specific user. By removing identifiable parts from and anonymizing personal data, personal data can be converted into“non-personal data.”
3. How are personal data collected and processed?
Your personal data will be stored for as long as this is necessary for achieving the defined purposes. If you cancel your user account, we will also erase or block your personal data. An exception applies only if we have a legal obligation to archive data for a certain time period.
4. What are log files?
A log file automatically logs all or defined actions on a computer system. Such log files are important, for example, for process control and automation. In the case of databases a log file tracks changes to the database of correctly executed transactions. In the event of an error (e.g., a system crash), this allows the current dataset to be restored. Log files are also created by web servers. Inter alia, the following data are logged: the address of the accessing computer, authentication fields, date and time of access, access method, content of HTML access, status code of the web server, and information about the browser and operating system used by the client.
Every time you access our website and/or open up the 7Mind App, the aforementioned data will be automatically stored in log files.
5. What are cookies and tracking pixels?
We collect information about visitors to our website and about users of our 7Mind App in order to improve our services. For this purpose we use different kinds of so-called cookies and tracking pixels (a.k.a. web beacons).
Websites that include flash media write user-specific data to your computer and later read such data. Such files are called flash cookies or local shared objects (LSO).
Such files are not managed by your browser, but rather by the flash player plug-in. Flash cookies are subject to the same rules as conventional cookies. Flash cookies, too, can only be read by the website that caused those flash cookies to be placed. However, flash cookies can store a substantially greater volume of data.
Your browser offers extensive setting options to manage cookies. For example, you can deactivate cookies in your browser or limit cookies to certain websites. You can also program your browser to first notify you before a cookie is placed. You can also choose these settings on your mobile terminal devices. You can at any time manage cookies by changing the settings of your devices, delete cookies, or block cookies altogether.
You can also visit our website, even if you block cookies on your terminal device. If you block cookies, the display of our website may however be impaired and not all functions may be available to you. You can also use the 7Mind App without cookies. In that case, you may however no longer be able to use all functions of the App as conveniently.
Tracking pixels are small graphics in HTML e-mails or on websites. When you access such a website, your access to the tracking pixel will be recorded in a log file. This allows statistical analyses which, in turn, can be used to improve our services. You can set your e-mail program or your browser so that HTML e-mails will be displayed as text only, thereby preventing the use of some tracking pixels.
6. Which types of data do we collect, process, and use?
We collect three types of data:
- data you provide to us voluntarily,
- data we receive when you use our services, and
- data we receive from third parties.
In other words, we process and use data (including personal data) you make available to us voluntarily on the website or through the 7Mind App in various situations (e.g., when you send us an email). We also use data that are collected automatically on our website or through the 7Mind App. Finally, we may also receive data about you from third parties, for example when another user provides us with information about you.
It is therefore impossible to provide you with an exhaustive list of all possible types of data that we may possibly collect, process, and use. Typically, we collect, process and use the following data:
- your name and address;
- your personal contact information (telephone, e-mail, fax, etc.);
- your username and password;
- your user profile data (e.g., workout schedule);
- your user preferences (e.g., preferred language settings);
- your IP address, operating system, browser type, browser version, browser configuration, name of Internet provider, and any other relevant information regarding your computer and Internet connection in order to identify the type of your device, to connect you to the website, to exchange data with your (mobile) terminal device, or to ensure proper use of the website and 7Mind App;
- the URL and IP address of the website from which you access our website or from which you are transferred to our website, including date and time;
- any pages of our website on which you click during your visit, and any links on our website on which you click, including date and time;
- the entire Uniform Resource Locator (URL) clickstream regarding, through, and from the website, including date and time;
- your service inquiries and your orders;
- your transaction history, including open and completed transactions;
- search terms you input;
- information regarding your orders and payments;
- information collected by cookies or similar technologies (as explained below);
- your survey answers, critiques, evaluations, or other responses;
- the content of all messages sent through the website or 7Mind App, including information uploaded to social networks through the website or the 7Mind App or otherwise shared with us and/or other users, as well as chat messages and chat logs;
- information about exercises you download using the 7Mind App;
- your newsletter subscriptions;
- any consents you have given us;
- any other information input or uploaded by you through the website or the 7Mind App (e.g., information you provide when completing an online form, photos you upload); or
- data we receive when you log in through social media (e.g., if you log in with Facebook).
7. Where are data stored?
Information Shared with Other Systems, Such As HealthKit or Google Fit
- The 7Mind App and services do not use HealthKit or Google Fit data for advertising purposes and will not sell HealthKit oder Google Fit data.
- The 7Mind Services do not disclose HealthKit or Google Fit data to third parties or use it for purposes other than medical research.
- We do not sell any of your information, including information gained through the Apple HealthKit or Google Fit, to advertising platforms, data brokers or information resellers.
- We do not use any of the information obtained through Apple HealthKit or Google Fit for any purposes other than providing health and/or fitness services in connection with the 7Mind services.
We use cloud services. This means we will transfer your data to a third party – the cloud services provider – and store data on the servers of that provider. In some cases, your data may also be stored on servers outside the European Union (EU) or European Economic Area (EEA). In some cases, your data may also be processed there. We either ensure through appropriate contracts that such service providers guarantee the same level of data privacy to which you are also entitled in the European Union or we use only providers that are EU-US Privacy Shield certified (https://www.privacyshield.gov/welcome). Either alternative ensures an appropriate level data privacy.
8. For what purposes are data used?
We will collect, process, and use your personal data and other data in particular for the following purposes:
- to administrate, operate, maintain, and improve the website and the 7Mind App;
- to allow and process orders for services placed by you through the website or the 7Mind App;
- to customize your experience of our website or the 7Mind App (e.g., by tailoring content and offers to your personal preferences);
- to assess your right to receive certain types of offers or services;
- to support the improvement and customization of the 7Mind Services;
- to analyze and research customer behavior;
- to respond to your questions and inquiries;
- to provide you with information about services that may be of interest to you;
- to communicate with you about certain concerns;
- to manage awards, surveys, winning games, lotteries, or other promotional activities or events;
- to comply with our legal obligations to prevent any unlawful use of the website or 7Mind App, to settle disputes, — and to enforce our contracts;
- for any other purposes to which you have consented in a particular case, or
- otherwise as permitted by applicable law.
If required by law, we will ask for your consent before collecting, processing, or using your personal data for any of the aforementioned purposes.
We will also notify you if we want to use your personal data for a new or different purpose. We will use your personal data for such other purposes only if and to the extent necessary or permitted by applicable law or with your consent.
9. Registration of 7Mind user account
You may create an 7Mind user account through our login system on our website or the 7Mind App. Following registration, you will be able to use your user account to subscribe to all 7Mind Services. To register, you must provide us with at least the following information:
- e-mail address
You can also link your 7Mind user account in the App and/or website to your Facebook profile. To do so, simply choose“Login with Facebook” during the registration process in the App or Web-App; you will then be transferred to Facebook. There, you will be shown to which Facebook data we will receive access. We will store your Facebook e-mail address. This is the e-mail address we will use to contact you, if necessary. We will also record the fact that you have registered through Facebook.
10. Collection, processing, and use of data in connection with the 7Mind App
7Mind is an app that teaches you how to meditate and easily integrate mindfulness into your everyday life. After registering in the 7Mind App and/or Web-App, you will be able to listen to our guided audio-meditations and/or watch videos included in the 7Mind App.
During the registration process you will provide us with personal data, such as your name. After registering, you can add additional information to your user profile. If you do so, you will once again provide us with personal data. We will also receive data (including personal data) from you when you communicate with us or other users through the 7Mind App. We will receive information about which and how many meditations you have completed in the 7Mind App and/or Web-App. We will also receive information about how you use the 7Mind App. In that case, too, you will provide us with personal data.
We use all such data to improve our products or to support your progress. For example, we will send you reminders to motivate you to meditate or exercise with our App. We also use such data for marketing purposes.
For you to be able to use the 7Mind App to the full extent, we will also need certain access rights to your smartphone. For example, we need access to your camera or your photos if you upload or want to change a profile photo. We use push messages to send you reminders or to notify you. When you want to use such a function for the first time, we will ask you whether you grant us such access rights or we will ask you to grant us access by selecting the appropriate settings. Generally, you may revoke such access rights at any time by changing the appropriate settings.
11. How to contact us
You can contact us by sending us messages to email@example.com.
If you transmit personal data to us by e-mail, we will use such data only for the purpose for which you entrust us with such data when you contact us.
The same applies when you communicate with us by using a contact form.
You can register for our newsletter. That way, you will receive regular updates about the 7Mind Services. All you need to receive our newsletter is a valid e-mail address. If you are no longer interested in receiving the newsletter, you may unsubscribe at any time using the link that is included in each newsletter.
13. Cookies and tracking pixels
We use our own cookies and tracking pixels. As explained above, this will however allow no inferences as to your identity.
14. Data processing – third-party services and partners
To be able to offer you all functions and services of the 7Mind App in the most convenient way possible and to be able to continuously improve our product, we use third-party services and partners. We also use the assistance of third parties to improve our website. Finally, we use certain tools for our marketing. What tools we use and for what purposes is explained below:
We use a number of different Google services (Google Inc., 1600 Amphitheater Pkwy., Mountain View, CA 94043, U.S.A. – hereinafter“Google”) for analysis and marketing purposes. These tools collect and statistically analyze data about your use of our services in different ways. We also use your data to show you personalized ads with the help of Google services. By using our website or our 7Mind Services, you consent that we may use your data for these purposes. In what follows, we will explain the different services and the ways in which you can to conveniently revoke your consent, and we provide you with additional important information.
Additional information about how Google handles data transmitted by us is available here:
Information generated by Google tools is generally transferred to a server of Google in the United States and stored there. Google and its subsidiaries are EU-US Privacy-Shield certified.
Google AdWords: We use Google AdWords to advertise our offers. Following a search on Google, our ads will be shown in the areas designated for this purpose. Our website registers with the help of cookies how many users have found our services through our ads. We use such data to optimize our ads. A cookie is stored by Google when an ad is clicked. You can block the cookie by selecting the appropriate settings in your browser. In that case, your visit to our website will not be included in anonymous user statistics.
If you wish to receive no personalized ads, you can place an opt-out cookie:
You can block cookies, for example, by installing an appropriate browser plug-in, which is available here:
If you wish to receive no personalized ads, you can place an opt out cookie:
You can block personalized ads by installing the appropriate browser plug-in, which is available here:
You can also block personalized ads from Google and other advertising networks by opting out on the following page:
14.2 Social plug-ins
We use the following social plug-ins for our website:
- Facebook (operator: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, U.S.A.)
- Twitter (operator: Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, U.S.A.)
- Google+ (operator: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S.A.)
These plug-ins routinely collect data from you and transfer such data to servers of the provider.
- Facebook: http://www.facebook.com/policy.php
- Twitter: http://twitter.com/privacy/
- Google+: http://www.google.com/intl/de/privacy/
We use the“Facebook Connect” function, so that you can register and login with the 7Mind App, using your Facebook account.
If you use Facebook Connect, Facebook profile data and public data from your Facebook profile will be transferred to us. Conversely, data may be transferred from us to your Facebook profile. Such data are used by us to register you on our website or for the 7Mind App or to allow you to log in. For this purpose we also store and process such data.
By registering on our website or for the 7Mind App with the help of Facebook Connect you consent that your profile data from your Facebook profile may be transferred to us and, conversely, that we may transfer data to Facebook.
Please also note that Facebook receives information through Facebook Connect about how you use our 7Mind App and our website.
You can change the settings for the storage of your data here: https://help.pinterest.com/entries/25010303— How— does— Pinterest— use— data— about— other— websites— I— visit. You can do so whether or not you are a Pinterest user.
Our 7Mind App and our website use the Adjust service of adjust GmbH (Saarbrücker Str. 37A, 10405 Berlin). The Adjust service has been audited and certified in accordance with the ePrivacyseal (European Seal for Your Privacy) (see http://www.eprivacy.eu/vergebene— siegel/). This service allows us to monitor our marketing performance, to adjust our advertising campaigns, and to better understand, overall, how you use our app. To achieve this goal, we can, inter alia, monitor in real time how you interact with our app. For this purpose Adjust, for example, collects your IP address in anonymous form (as a hash value), and tracks when you install and open our 7Mind App for the first time, how you interact with the app, or on which ads you click.
Once collected, such data are not merged with any other data for personal identification purposes.
You may choose at any time that such data shall no longer be collected in the future. If so, please simply use the opt-out option of adjust at https://www.adjust.com/opt-out/.
14.5 Facebook Custom Audiences
We use the remarketing function“Custom Audiences” of Facebook Inc. (1601 Willow Road, Menlo Park, California 94025). This function allows us to show visitors of our website and users of our 7Mind App interest-based ads when they visit Facebook (“Facebook ads”), and to analyze such Facebook ads for statistical and market research purposes, which helps us optimize future advertising. For this purpose we use the so-called Facebook pixel (website) and Facebook SDK (7Mind App).
Such data may allow Facebook and its partners to show ads on or off Facebook.
Facebook generally also stores such data on servers in the United States. Facebook is EU-US Privacy Shield certified.
You can generally block the placement of cookies on your computer by selecting the appropriate settings in your browser, so that cookies will no longer be placed on your computer in the future and/or so that cookies that have already been placed will be deleted. If you do so, you may no longer be able to correctly use some functions on our website.
With the help of an appropriate opt-out cookie from Digital Advertising Alliance you can also completely deactivate advertising by third-party providers such as Facebook:
In the alternative, you can deactivate the remarketing function“Custom Audiences” in your Facebook settings:
To do so, you must be registered with Facebook.
15. Transfer of data to third parties
Your personal data will be transferred to third parties only if we have a legal obligation to do so, if the data transfer is necessary for performance of the contract, or if you have consented to the transfer of your data. Third-party service providers and partner companies will receive your data only if and to the extent necessary for performance of the contract or with your consent. In such cases, the extent to which data are transferred will however be kept to the absolute minimum. To the extent that our service providers come into contact with your personal data, we will make sure that they too will comply with all applicable data protection laws. Please also read the data privacy policies of such third-party providers.
16. Data security
Data transfers are generally subject to security gaps. It is technically impossible to protect your data 100% from access by third parties. However, we strive to minimize this risk as much as possible. We therefore maintain state-of-the-art measures to guarantee data security and to protect your data from access by third parties. In addition, we use strong SSL or TLS encryption for all data transfers. However, please make sure not to provide your login data to any third parties.
17. Websites of third parties
19. Your rights: information/revocation/erasure and data controller
You may at any time and at no cost demand information about your personal data that is being processed by us, correction of any errors in your personal data, termination of processing of your personal data, or erasure of your personal data – subject to mandatory legal provisions or obligations to the contrary. To exercise these rights, simply contact us at any time by letter or e-mail at:
Managing director: Jonas Leve, Manuel Ronnefeldt
Recorded in the Commercial Register at the Local Court of Berlin
under number HRB 26916
VAT ID No.: DE297708431
External Data Protection Officer
HC Plus Gesellschaft für Datenschutz UG(h)
represented by DanLahiri Agboli
Geneststraße 5, 10829 Berlin, Germany
For all request concerning the security of your data you can contact our data protection officer at firstname.lastname@example.org.
If you have a particularly sensitive request, please contact our data protection officer by postal mail. The communication by email can always be flawed by security gaps.