Privacy Policy

1. Who We Are

The controller of your personal data is:

Users in the EEA and the UK may contact the relevant representative on all matters relating to the processing of their personal data.

This Privacy Policy explains what personal data we collect when you use the Some Quiet mobile application and related websites (the “App”), why we collect it, who we share it with, and what rights you have.

2. Summary

• We collect the minimum needed to run the App, deliver your sessions, and manage your subscription.
• We never sell your personal data.
• Information you enter about how you are feeling is treated as sensitive. We use it only to generate your session and show you your own history. We never use it for advertising, and never disclose it to advertising partners.
• You can delete your account and all associated data directly in the App.
• You can withdraw consent, opt out of marketing, and exercise your privacy rights at any time.

3. What We Collect

3.1 Information you provide

3.2 Information collected automatically

We do not receive or store your payment card details. All payments are processed by Apple or Google.

We do not access your contacts, photos, precise location, microphone or health app data unless you explicitly grant permission for a specific feature, and we will tell you what it is used for at the point of the request.

4. Sensitive Data — Your Emotional Inputs

Some information you choose to provide — for example a description of your stress, mood, sleep difficulties or anxiety — may reveal information about your mental health. In the EEA and the UK this may constitute a special category of personal data under Article 9 GDPR; under several US state laws it constitutes sensitive personal information.

How we handle it:

• We process it solely to generate and personalise your meditation sessions and to display your own session history back to you.
• In the EEA and the UK we rely on your explicit consent under Article 9(2)(a) GDPR. You may withdraw that consent at any time in the App at Sidebar › My profile, or by emailing us, after which personalised session generation will no longer be available to you.
• We do not use it for advertising or marketing.
• We do not disclose it to advertising, analytics or measurement partners.
• We do not sell or share it.
• We do not use it to build profiles for any purpose other than delivering the App to you, and we do not use it to limit, deny or price access to any service.
• It is transmitted to our AI provider (see section 6) only to produce your session.

We do not require you to provide this information. You can use the pre-recorded library without entering anything about how you feel.

5. Why We Process Your Data, and on What Legal Basis

Where we rely on legitimate interests, we have assessed that our interest in operating, securing and improving the App is not overridden by your rights. You may object to that processing — see section 11.

6. Who We Share Data With

We do not sell your personal data.

We share personal data with the following categories of service provider, each bound by a written data processing agreement requiring them to process data only on our instructions and to protect it appropriately:

AI provider. Your emotional inputs are transmitted to our AI provider only to produce your session. We use an enterprise API configuration under which your inputs are not used to train the provider’s models and are subject to zero- or limited-retention terms.

Legal requirements. We may disclose personal data where required by law, regulation, legal process or an enforceable governmental request, or where necessary to protect our rights, safety, or the rights and safety of others.

Business transfers. In the event of a merger, acquisition, financing or sale of assets, personal data may be transferred as part of that transaction. We will notify you and, where required, seek your consent.

7. International Transfers

Personal data is transferred to and processed in the United States, where our infrastructure and several of our providers are located.

Where we transfer personal data out of the EEA or the UK, we rely on:

• the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable); or
• the EU-US Data Privacy Framework (and the UK Extension) where the recipient is certified.

A copy of the relevant safeguards is available on request at hello@mindbloomingapps.com.

8. How Long We Keep Data

When you delete your account, we delete or irreversibly anonymise your personal data within 30 days, except where we are required to retain specific records for legal, tax or fraud-prevention purposes.

9. How We Protect Data

We implement technical and organisational measures appropriate to the risk, including encryption of data in transit and at rest, access controls limiting access to the minimum number of personnel, confidentiality obligations for staff and contractors, and regular review of our providers.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Automated Processing

The App uses automated processing to personalise your sessions based on the information you provide. This is not automated decision-making producing legal or similarly significant effects on you within the meaning of Article 22 GDPR. You can stop it at any time by withdrawing consent in the App at Sidebar › My profile and continuing to use the pre-recorded library.

11. Your Rights

You can exercise the rights below by emailing hello@mindbloomingapps.com, or directly in the App where indicated. We will verify your identity before responding. We do not charge a fee unless a request is manifestly unfounded or excessive.

11.1 Everyone

• Delete your account — in the App at Sidebar › My profile › Delete Account
• Unsubscribe from marketing — via the link in any marketing email, or in the App at Sidebar › My profile
• Withdraw consent to personalisation — in the App at Sidebar › My profile
• Disable push notifications — in your device settings

11.2 EEA and UK residents (GDPR / UK GDPR)

• Right of access to your personal data and information about how we use it
• Right to rectification of inaccurate or incomplete data
• Right to erasure
• Right to restriction of processing
• Right to object to processing based on our legitimate interests, on grounds relating to your particular situation, and to direct marketing for any reason
• Right to data portability — to receive your data in a structured, commonly used, machine-readable format
• Right to withdraw consent at any time, without affecting the lawfulness of processing before withdrawal
• Right to lodge a complaint with your local supervisory authority. A list of EEA authorities is available at edpb.europa.eu. UK users may complain to the Information Commissioner’s Office at ico.org.uk. You may also complain to the supervisory authority in the country of our EU Representative.

We respond within one month, extendable by two further months for complex requests, in which case we will tell you.

11.3 California residents (CCPA, as amended by the CPRA)

You have the right to:

• know the categories and specific pieces of personal information we have collected, the sources, the business purpose, and the categories of third parties to whom we disclose it;
• delete personal information we hold about you;
• correct inaccurate personal information;
• opt out of the sale or sharing of personal information — we do not sell personal information;
• limit the use and disclosure of sensitive personal information — we already limit our use of emotional and wellbeing inputs to delivering the App to you, as described in section 4;
• non-discrimination — we will not deny you services, charge you a different price, or provide a different level of quality because you exercised your rights;
• use an authorised agent to submit a request on your behalf, with proof of authorisation.

We acknowledge requests within 10 business days and respond within 45 days, extendable by a further 45 days with notice.

11.4 Other US state residents

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, or another state with a comprehensive consumer privacy law, you have rights to access, correct, delete and obtain a portable copy of your personal data, and to opt out of targeted advertising, sale, and certain profiling.

Appeals. If we deny your request, you may appeal by replying to our decision or writing to hello@mindbloomingapps.com with “Privacy Appeal” in the subject line. We will respond to appeals within 45 days. If your appeal is denied, you may contact your state Attorney General.

12. Cookies and Similar Technologies

Our website uses cookies and similar technologies. Strictly necessary cookies are required for the site to function. Any analytics, functional or advertising cookies are set only with your consent, which we request through a consent banner and which you can change at any time in our cookie settings.

The mobile App does not use browser cookies but does use device identifiers and SDKs as described in sections 3 and 6.

13. Children

The App is intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, contact hello@mindbloomingapps.com and we will delete it promptly.

14. Data Breaches

Where a personal data breach occurs, we will notify the competent supervisory authority within 72 hours of becoming aware of it, in accordance with Article 33 GDPR, unless the breach is unlikely to result in a risk to your rights and freedoms.

Where a breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay, unless one of the exceptions in Article 34(3) GDPR applies. We will also comply with applicable US state breach notification laws.

15. Links to Other Sites

The App may contain links to websites and applications we do not control. We are not responsible for their privacy practices or content. We recommend reviewing their privacy policies. This Privacy Policy applies only to the App.

16. Changes to This Policy

We may update this Privacy Policy. Where changes are material, we will notify you in the App or by email before they take effect, and we will update the “Last Updated” date above.

17. Contact

Questions, requests or complaints:

EEA users may also contact our EU Representative, and UK users our UK Representative, at the addresses in section 1.