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PRIVACY POLICY

This Privacy Policy explains how UMIND LTD, 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom ("we," "us," "our") collects, uses, and protects your personal data when you use the Entwined mobile application and related services (the "Services"). UMIND LTD acts as the data controller for the personal data processed under this Privacy Policy. Entwined is a self-development and relationship support application and does not provide medical, psychological, or therapeutic services. By using our Services, you agree to this Privacy Policy. This Policy may be updated from time to time.

1. Data Collection

1.1 Information You Provide

We collect information you provide directly to us when you:

  1. Create an account or subscribe
  2. Complete in-app quizzes, assessments, or relationship exercises
  3. Make a purchase or manage your subscription
  4. Communicate with our support team This may include:
  5. Email address and account credentials
  6. Quiz responses and relationship-related information you choose to provide, which may include personal reflections, communication preferences, emotional experiences, or relationship concerns
  7. Subscription and purchase details
  8. Any other information you choose to provide

1.2 Information We Collect Automatically

When you use our Services, we automatically collect certain information, including:

Device Information

  • Device model
  • Operating system and version
  • Language settings
  • Time zone
  • Mobile carrier

Network Information

  • IP address
  • Approximate location derived from IP address

Usage Information

  • Screens viewed
  • Features used
  • Session duration
  • In-app interactions
  • Crash reports and diagnostics

Identifiers

  • Advertising identifiers (such as IDFA on iOS and GAID on Android)
  • App instance identifiers

Website Technologies

  • Cookies and similar tracking technologies used on our website

1.3 Information from Third Parties

We may receive information about you from third parties, including:

  1. Payment providers and subscription platforms (such as Stripe, Apple App Store, Google Play, and RevenueCat) regarding transactions and subscription status
  2. Advertising and attribution partners (such as Meta/Facebook, TikTok, and AppsFlyer) regarding how you discovered our Services
  3. Analytics providers (such as Firebase and Amplitude) regarding your interaction with the Services

2. How We Use Your Data

2.1 To Provide and Improve the Services

We use your information to:

  1. Operate, maintain, and improve the Entwined app and Services
  2. Generate personalized insights, exercises, and recommendations
  3. Process subscriptions, payments, and renewals
  4. Provide customer support
  5. Detect, investigate, and prevent fraud, abuse, security incidents, and unauthorized access

2.2 Marketing and Advertising

We may use your information to:

  1. Send promotional emails, push notifications, and in-app messages where permitted by law and your settings
  2. Measure and improve the effectiveness of our marketing campaigns
  3. Display and measure personalized advertising on third-party platforms such as Meta, TikTok, and Google Where required by applicable law, we will obtain your consent before using advertising cookies, SDKs, or similar technologies for personalized advertising and attribution.

2.3 Compliance and Legal Obligations

We may process your information to:

  1. Comply with applicable laws, regulations, and legal processes
  2. Enforce our Terms of Use
  3. Protect the rights, safety, and property of UMIND LTD, our users, and third parties

2.4 Legal Bases for Processing (GDPR)

Where the UK GDPR or EU GDPR applies, we rely on the following legal bases:

  1. Performance of a contract — to provide the Services you requested or subscribed to
  2. Consent — for marketing communications, advertising technologies, and certain analytics or relationship-related data processing
  3. Legitimate interests — to improve our Services, maintain security, prevent fraud, and operate our business
  4. Legal obligations — to comply with applicable laws and regulatory requirements You may withdraw your consent at any time by contacting us using the details below.

3. Data Sharing

We do not sell personal data for monetary compensation. However, certain data sharing for advertising and attribution purposes may be considered “sharing” under applicable privacy laws such as the CCPA/CPRA.

3.1 Service Providers

We may share information with third-party service providers, including:

  1. Payment and subscription providers (Stripe, Apple App Store, Google Play, RevenueCat)
  2. Analytics providers (Firebase, Amplitude)
  3. Advertising and attribution providers (Meta/Facebook, TikTok, AppsFlyer)
  4. Cloud hosting and infrastructure providers
  5. Customer support and communication tools These providers may process data on our behalf or as independent controllers under their own privacy policies.

3.2 Legal Requirements

We may disclose your information if required by law or in response to valid legal requests from courts, regulators, law enforcement agencies, or public authorities.

3.3 Business Transfers

If UMIND LTD is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify users where required by applicable law.

3.4 Advertising and Attribution

We may share certain identifiers and event-related data with advertising and attribution partners for marketing measurement and campaign attribution. Under certain privacy laws, this activity may be considered “sharing” of personal information for cross-context behavioral advertising purposes. You may opt out as described in Section 4 below.

4. Your Rights

4.1 Rights Under UK GDPR and EU GDPR

If you are located in the UK or European Economic Area, you may have the right to:

  1. Access the personal data we hold about you
  2. Correct inaccurate or incomplete data
  3. Request deletion of your personal data
  4. Restrict or object to certain processing activities
  5. Request portability of your personal data
  6. Withdraw consent where processing is based on consent
  7. Lodge a complaint with your local supervisory authority For UK users, the supervisory authority is the UK Information Commissioner’s Office (ICO): https://ico.org.uk/

4.2 Rights Under CCPA / CPRA

If you are a California resident, you may have the right to:

  1. Know what personal information we collect, use, disclose, share, or sell
  2. Request deletion of your personal information
  3. Request correction of inaccurate personal information
  4. Opt out of the sharing of personal information for targeted advertising purposes
  5. Limit the use of sensitive personal information where applicable
  6. Be free from discrimination for exercising your rights You may also manage advertising preferences through your device settings, including:
  • “Allow Apps to Request to Track” on iOS
  • Advertising personalization settings on Android

4.3 Exercising Your Rights

To exercise your privacy rights, contact us at: Email: team@entwinedapp.com We will respond within the timeframes required by applicable law.

5. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

  1. Maintaining active accounts and subscriptions
  2. Complying with legal, tax, accounting, and regulatory obligations
  3. Resolving disputes and enforcing agreements
  4. Preventing fraud and protecting the security of the Services We periodically review the data we hold and delete or anonymize personal data when it is no longer necessary for these purposes.

6. Security Measures

We implement appropriate technical and organizational safeguards designed to protect personal data, including:

  1. Encryption of data in transit using TLS/HTTPS
  2. Access controls and authentication measures
  3. Security monitoring and periodic assessments
  4. Vendor due diligence for third-party processors and service providers However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

7. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including the United States and other jurisdictions where our service providers operate. Where required by law, we use appropriate safeguards for international transfers, including:

  • Standard Contractual Clauses approved by the European Commission
  • UK International Data Transfer Addendum
  • Adequacy decisions where available

8. Children’s Privacy

The Services are intended only for individuals who are at least 18 years old. We do not knowingly collect personal data from individuals under 18 years of age. If we become aware that we have collected such information, we will take reasonable steps to delete it. If you believe a child has provided personal information to us, please contact us.

9. Cookies and Tracking Technologies

Our website and app use cookies, SDKs, pixels, and similar technologies for:

  1. Essential functionality
  2. Analytics and performance measurement
  3. Advertising and attribution You can manage your preferences through:
  4. Our website cookie banner
  5. Device settings and app permissions
  6. Browser cookie settings On iOS devices, we comply with Apple’s App Tracking Transparency framework and request permission before tracking users across third-party apps and websites where required.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we may notify you through the app, by email, or through other appropriate communication methods. Your continued use of the Services after such updates constitutes acceptance of the revised Privacy Policy.

11. Contact Information

For questions, requests, or concerns regarding this Privacy Policy or our privacy practices, please contact: UMIND LTD 71–75 Shelton Street, Covent Garden London, WC2H 9JQ United Kingdom Email: team@entwinedapp.com Last Updated: 18 May 2026