This Privacy Policy applies to the Clear Mind services ("Clear Mind" or "Platform"), namely the Clear Mind application. Clear Mind is provided by TOOLHUB. LTD., a company operating under the laws of Singapore.
We understand how valuable your privacy is to you, and we are dedicated to protecting your personal information. This Privacy Policy outlines our practices regarding the collection, use, sharing, and processing of your personal data when you use our services. The policy applies worldwide, with specific provisions for different jurisdictions detailed in the "Supplemental Terms - Jurisdiction-Specific" section. If you do not agree to this Privacy Policy, please refrain from using Clear Mind.
Important Notice: Your privacy rights matter. Please take the time to carefully review and understand this entire Privacy Policy before using Clear Mind.
We may gather the following categories of personal data:
When engaging with our support services on Clear Mind, you may voluntarily provide:
We also maintain records of all communications when you reach out to us regarding:
During your engagement with Clear Mind, our systems automatically capture the following data categories:
Usage Analytics
Device Specifications
Advertising Ecosystem Data
Local Data Retention
Tracking Technologies
For opt-out procedures regarding these technologies, please consult the "Your Rights and Choices" section.
We may acquire the categories of information specified in this Privacy Policy through the following channels:
Third-Party Authentication Data
Users may access Clear Mind services by authenticating through:
When utilizing third-party login, we retrieve limited profile data including:
This authentication data serves three primary purposes:
Publicly Available Records
We may process information legally obtained from governmental disclosures or public social media content.
Third-Party Disclosures
In limited circumstances, we may receive personal data when:
We process the information we gather to fulfill the following objectives:
2.1 Service Delivery & Operations
2.2 User Engagement
2.3 Promotional Activities
2.4 Experience Enhancement
2.5 Security Infrastructure
2.6 Regulatory Compliance
2.7 Innovation Development
We will not share your personal information unless explicitly stated in this Privacy Policy. Your personal information may be shared under one or more of the following circumstances:
3.1 Sharing With Your Consent
We may share information with third parties when we have obtained your consent or at your direction.
3.2 Sharing With Business Partners
You understand and agree that some of our services will be provided by or jointly with our business partners. To comply with this Privacy Policy, you agree that we may share necessary personal information with the following partners:
We strictly review third-party qualifications and impose legal, compliant, and secure requirements.
Primary third-party SDK providers include:
3.3 Sharing in Business Transactions
We may transfer your personal information to another entity in the context of mergers, acquisitions, financing, restructuring, bankruptcy, or asset transfers. We will provide notice and require the new data holder to comply with this Privacy Policy.
3.4 Legal Compliance Disclosures
We may disclose your personal information when legally required to comply with law enforcement, regulators, courts, or other public institutions to enforce agreements, investigate violations, or protect rights and safety.
4.1 Data Storage Practices
4.1.1 Storage Locations
Servers storing your personal information related to Clear Mind are located in Singapore. We may transfer and store your data on these servers in compliance with applicable laws and regulations. We will implement safeguards to protect your information and comply with cross-border data transfer requirements.
4.1.2 Retention Periods
We retain your personal information until your account is terminated or the information is no longer required for its original purpose. Additional retention may occur to comply with legal obligations, enforce agreements, or resolve disputes. Retention duration varies based on information category, purpose of use, and legal retention requirements. Upon expiration, we delete or anonymize the data unless required by law.
4.2 Information Protection Framework
We implement appropriate technical and organizational measures including data encryption and de-identification techniques. These safeguards are regularly reviewed and enhanced. No electronic transmission or storage is 100% secure; we cannot guarantee absolute security.
4.2.1 Technical Safeguards
Under applicable laws and regulations, you possess certain rights regarding your personal information:
To exercise these rights, contact us using the details below. We will verify your identity and respond within a reasonable timeframe or the period required by your jurisdiction's laws.
Our services are not directed at individuals below the age of 13 or the legal minimum age in your jurisdiction. We do not knowingly collect personal data from users under this age threshold. If we become aware that we collected data from an underage user, we will promptly delete such information and deactivate the account.
For users above the minimum age but still legally considered minors, parental or guardian oversight is required. Minors must review these terms with a parent or legal guardian and obtain approval before sharing any personal data.
To deliver our services, your personal information may be processed in or transferred to jurisdictions outside your own. We adhere to applicable regulations and implement appropriate measures to secure your data.
We may periodically revise this Privacy Policy to reflect legal, operational, or technological changes. Updates will be marked with a revised "Last Updated" date, and material modifications will be communicated via prominent notices. Where mandated by law, we will seek your explicit consent before enforcing changes affecting your rights.
If you have any questions, comments, complaints, requests, or suggestions regarding this Privacy Policy or any privacy-related matters, you may submit feedback in-app via "Profile - Help & Feedback" or email us at team@mindsclear.uk.
This Privacy Policy is originally written in English and may be translated into other languages. In case of any discrepancy, conflict, or ambiguity between the English version and a translated version, the English version shall prevail.
This Privacy Policy is governed by and construed in accordance with the laws of Singapore, without regard to its conflict of laws principles. Any disputes arising under this policy shall be resolved in accordance with the Terms of Service.
In the event of a conflict between the provisions of the Supplemental Terms applicable to your jurisdiction and the rest of this Privacy Policy, the relevant Supplemental Terms shall prevail.
Over the past 12 months, we have collected and disclosed your personal information as described in the "What Information We Collect" and "How We Share Your Information" sections for purposes set out in "How We Use Your Information."
Categories defined in CCPA include:
We do not knowingly collect any information about anyone under the age of 16.
In the past 12 months, we have not sold or shared personal information of California residents within the meaning of "sold" and "shared" in the CCPA. We will not sell or share your personal information without providing notice and an opportunity to opt-out.
Your California Rights
How to Exercise Your Rights
You may exercise your rights using the methods described in "Your Rights and Choices." We may need additional information to verify your identity. We respond in good faith within 45 days, with an extension of up to 90 days when necessary. We do not ordinarily charge a fee unless requests are excessive or manifestly unfounded.
Legal Basis for Processing
Your GDPR Rights
We may transfer your personal information outside the EEA using EU adequacy decisions, Standard Contractual Clauses (SCCs), or other GDPR-compliant mechanisms to ensure equivalent protection.