Mindletic Application Privacy Policy

1. Last updated: October 7, 2020

2. This Privacy Policy outlines how we will collect, use, store and share Your Personal Data when You use the Application and tells You about Your privacy rights and how the law protects You.

3. We are committed to protecting your privacy. It is important that You understand how We look after Your Personal Data and how We make sure that We meet our legal obligations to You under Data Protection Law.

4. If You have any questions in relation to this policy or generally how Your Personal Data is processed by Us please contact Us by email info@mindletic.com.

Interpretation and Definitions


5. The words of which the initial letter is capitalized have meanings defined under the following conditions.

6. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.​


7. For the purposes of this Privacy Policy:

   •You means the natural person accessing or using the Application.
Under GDPR, You can be referred to as the Data Subject.

  •Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to UAB Emocinis balansas, a company  incorporated and registered under the laws of Lithuania, with legal entity code 305553328, having its registered office address at Kaunas, I. Kanto g. 2-3, Lithuania.

•For the purpose of the GDPR, the Company is the Data Controller which means that we are responsible for looking after it. We will use Your Personal Data fairly, lawfully and in a transparent manner, and in accordance with the applicable Data Protection Law.

•Application means the software program provided by the Company downloaded by You on any electronic device, named Mindletic.

•Personal Data is any information that relates to an identified or identifiable natural person. For the purposes for GDPR, Personal Data means any information relating to natural person such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

•Device means any device that can access the Application such as a computer, a mobile phone or a digital tablet.

•GDPR means General Data Protection Regulation 2016/679.

•Data Protection Law refers to applicable data protection legislation including, but not limited to, the GDPR.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

8.We collect and process Personal Data when you interact with our Application, and in the following ways described below.

9.When You register, an option to have 1on1 talk with a professional, record your emotions, talk in virtual community rooms. We ask You to provide Us with certain personally identifiable information that can be used to book a meeting, contact or identify You. This information may include, but is not limited to:


•Email address


•Promo code (if used)

•Message You wish to leave to the professional prior to the meeting

•Confirmation that You are above 18 years old 

•Confirmation that You wish to get related news

•Country You wish to have the 1:1 consultation from

•Selected language in which You wish to talk with professional

•Selected professional

•Selected time slot for meeting

•Emotions that you are feeling

•Any content that you type in virtual community rooms

10. When You make a complaint or submit a query to Us in relation to the Application or You will initiate restoration of the password, You will provide Us with relevant data including data about Your experience and difficulties with the Application.

11. Usage Data, i.e. data about how you use the Application, is collected automatically when using the Application so that we can analyse how the Application is used by users. This helps Us to improve the Application and We do not use it for any other purpose. Although Usage Data does not identify You by name, and we will not attempt to identify You by name or to use the information to make decisions about You, the information is associated with a unique identifier, namely Your device ID, therefore You are identifiable and the information constitutes Personal Data for the purposes of Data Protection Law. It is important for Us to be able to distinguish different users by using this unique identifier so that We can analyse how individual users use the Application. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), Your Device ID, the type of mobile device You use, Your mobile operating system, information about the Application being opened, Information about the region in which the Application is opened and other diagnostic data.

Purposes and Legal Basis for processing Personal Data 

12. Data Protection Law requires Us only to process Your personal data if We satisfy one of the legal bases of processing set out in the GDPR, for each purpose of processing.

13. The Company may use Personal Data for the following purposes:

•To create for You a personal account

•To arrange Your meeting with Your selected professional and contact or identify You. Processing is necessary for the performance of a contract between You and Us.

•To maintain and improve the Application by collecting and processing Usage Data. The processing is necessary for Our legitimate interest to maintain and improve the Application.

•To reply to and deal with complaints and queries relating to the Application. The processing is necessary for Our legitimate interest to provide users of the Application with good customer service.

•To follow the emotions that you record

•To restore your password

Who do we share Your Personal Data with?

14. We may share Your Personal Data with Our trusted services providers when they provide services to Us, or to You on behalf of Us and under Our instructions. We will control and shall remain responsible for the use of Your Personal Data at all times.

15. We may share Your personal information described in this Privacy Policy with the following recipients:

Developers and administrators of the Application;

Providers of data security, data management, website hosting, cloud hosting, storage solutions, software as a service (SaaS) and other IT services; 

Providers of Application analytics services;

Our staff who need to access Your data to perform their functions and who are bound by confidentiality obligations;

Professionals: when You share personal information in order to book a professional, only your name, submitted message dedicated to chosen professional, language you wish to talk in and country you will be talking from will be shared with them via email and the message you left for the professional. 

Other users of Application: when you participate in community chats, only your submitted messages will be shared with others.

We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

We may also disclose Your Personal Data as required by law, including laws outside Your country of residence, to comply with a court order or to comply with other legal or regulatory requirements, for example, to courts, law enforcement authorities, and regulatory agencies such as data protection supervisory authorities.  

Retention of Your Personal Data

16. The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

17. The Company will also retain Usage Data for internal analysis purposes. We will only retain Usage Data for a period of 1 year after We collect it. This is so that We can understand how You use the Application over time. After 1 year, We will aggregate the data with data of other users so that it no longer relates specifically to You or any other individual.

Transfers outside of the European Economic Area

​18.The Personal Data described in this Privacy Policy may be processed outside of the European Economic Area (EEA), in countries which the European Commission does not consider to provide the same level of protection to personal data as that granted within the EEA. In such cases, we make sure that additional safeguards are in place and your Personal Data is protected. 

19. The data processors Google inc. and Amazon Web Services, engaged by us, ensure security of your personal data, the appropriateness of their systems and operations is confirmed by relevant ISO standards or other reliable safety measures and recognized in the European Union.

Security of Your Personal Data

20. When handling Your personal data, We take appropriate measures reasonably designed to protect Your information from unauthorised access, loss, misuse, disclosure, alteration or destruction. Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect Your Personal Data, We cannot guarantee the security of Your data transmitted to the Application; any transmission is at Your own risk. Once we have received Your information, We will use strict procedures and security features to try to prevent unauthorised access. If you wish to export or delete your data, please write us an email to info@mindletic.com.

Your Rights in relation to Your Personal Data

21.The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. 

22.You have a number of rights under Data Protection Law in relation to the way We process Your Personal Data, which are set out below. You may contact Us using the details at the beginning of this Privacy Policy to exercise any of these rights or if You have any questions about these rights. In some instances, We may be unable to carry out Your request, in which case We will write to You to explain why.

23.You have the right under this Privacy Policy to:

•Request access to Your Personal Data. You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data. 

•Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.

•Object to processing of Your Personal Data. This right exists where We are relying on legitimate interest as the legal basis for Our processing unless we are able to demonstrate that our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.

•You have the right to ask Us to restrict or block the processing of your Personal Data that We hold about You in some cases. 

•Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

•Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.​

What if You have a complaint?

24. If You have any concerns regarding Our processing of Your Personal Data, or are not satisfied with Our handling of any request made by You, or would otherwise like to make a complaint, You have the right to lodge a complaint with the competent data protection authority of Your country of residence (in Lithuania, that is the State Data Protection Inspectorate. You can find contact details of the State Data Protection Inspection here: https://vdai.lrv.lt/en/).

Links to Other Websites​

25. Our Application may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

26. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy​

27. We may update our Privacy Policy from time to time. We will take reasonable measures to communicate any changes to this Privacy Policy to You, and will post any updated Privacy Policies on this page.

28. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us by email: info@mindletic.com

© Copyright 2021 Mindletic. All rights reserved.