Privacy Policy

Last updated: 3 Feb 2025

This Privacy Policy describes how MentalJourney (referred to herein as “We”, “Us”, or “Our”) collects, uses, stores, and discloses your personal data when you access or use the MentalJourney App (the “App”). The App is operated by Aaron Charles Gabriel (“I”, “me”, or “my”), who is the Controller of your personal data. By accessing or using the App, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Definitions and Key Terms

In this Privacy Policy, the following terms have the meanings as set out below:

Personal Data:
- For EEA residents, any information relating to an identified or identifiable natural person (“data subject”).
- For US residents, any data that identifies, relates to, or could reasonably be linked to you or your household.
- For Singapore residents, any data—whether factual or not—relating to an identified or identifiable individual.
Data Subject: An identifiable natural person who can be directly or indirectly identified by reference to an identifier such as a name, identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
Processing: Any operation or set of operations performed on personal data, whether or not by automated means. This includes collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction of data.
Controller: The natural or legal person (in this case, Aaron Charles Gabriel) who determines the purposes and means of processing your personal data.
Processor: A natural or legal person, public authority, agency, or other body that processes personal data on behalf of the Controller.
Third Party: Any natural or legal person, public authority, agency, or body other than the Data Subject, Controller, Processor, or persons under the direct authority of the Controller or Processor.
Consent: A freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your personal data.
CCPA: The California Consumer Privacy Act.
GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data.
PDPA: The Singapore Personal Data Protection Act 2012 and its subsequent amendments.
Business (as defined under the CCPA): A legal entity that collects and determines the purposes and means of processing consumers’ personal data, either alone or in conjunction with others.

2. Purpose of Data Collection

The primary purpose of collecting your personal data is to ensure the proper functioning of our App. This includes:

Maintaining and operating the App.
Managing your account (including registration, if applicable).
Fulfilling and managing contractual obligations (for example, in connection with purchases or subscriptions).
Communicating updates, responding to your inquiries, and providing customer support.
Improving our services, monitoring usage, and analyzing trends.

3. How We Use and Process Your Personal Data

We process your personal data only for the purposes described in this Privacy Policy. These operations include, but are not limited to:

Service Delivery: Enabling you to use the App and its features.
Account Management: Handling registrations, logins, and security.
Communication: Sending you updates, newsletters, or marketing materials (where you have consented).
Analytics and Improvements: Monitoring and analyzing App usage to enhance service performance.
Legal Compliance: Processing data as required by applicable laws, regulations, or legal requests.

4. Sharing Your Personal Data

We will not sell your personal data. We may share your personal data only under the following circumstances:

With Service Providers: We may share your information with trusted third parties (processors) that assist us in operating our App, processing payments, providing customer service, and analyzing usage data.
For Business Transfers: In the event of a merger, sale of assets, financing, or acquisition, your data may be transferred as part of the transaction. In such cases, we will ensure that the transferee agrees to protect your data in accordance with this Privacy Policy.
With Affiliates and Business Partners: We may share your information with our affiliates or business partners, provided that such parties are contractually obligated to protect your personal data in a manner consistent with this Privacy Policy.
Public Interactions: Any personal data you voluntarily disclose in public areas of the App may be accessible by other users and/or third parties.
With Your Consent: We may share your personal data for any other purpose with your explicit consent.

5. Data Storage and Retention

Storage Location: Your personal data is stored primarily on secure servers provided by Amazon Web Services (AWS).
Retention: We retain your personal data only as long as necessary for the purposes for which it was collected or as required by law. Once your data is no longer needed, it will be securely deleted unless retention is required for legal obligations, dispute resolution, or enforcement of our agreements.

6. Cookies and Tracking Technologies

Our App does not use cookies for tracking purposes. However, please note that we utilize Google AdMob for advertising purposes. You are encouraged to review Google AdMob’s privacy practices via the link provided in their policy documentation.

7. International Data Transfers

We may store and process your data in countries outside your country of residence. In such cases, we will ensure that your personal data is afforded a level of protection comparable to that under your local laws, including the PDPA for Singapore residents and the GDPR for EEA residents. If international transfers are involved, we will obtain your consent where required and implement appropriate safeguards.

8. Legal Bases for Processing Your Data

Depending on your location, our processing of your personal data is based on one or more of the following legal bases:

Consent: Where you have provided explicit consent for specific processing activities.
Contractual Necessity: Processing necessary for the performance of a contract or to take steps at your request prior to entering a contract.
Legal Obligation: Processing necessary for compliance with a legal obligation to which I am subject.
Legitimate Interests: Processing is necessary for the purposes of legitimate interests pursued by me, provided that such interests are not overridden by your fundamental rights and freedoms.
Protection of Vital Interests: In rare cases, processing may be necessary to protect your vital interests or those of another natural person.

For Singapore residents, your consent is used as a basis for the collection and processing of your personal data under the PDPA.

9. Your Rights Regarding Your Personal Data

Your rights vary depending on your location. Below are your rights as applicable to US, EEA, and Singapore residents:For US Residents (under the CCPA):

Right to Notice: You have the right to be informed about the categories and purposes of the personal data we collect.
Right to Request: You may request details about our collection, use, sale, or disclosure of your personal data, including:
- Categories of personal data collected.
- Sources of the personal data.
- Business or commercial purposes for collection.
- Categories of third parties with whom your data is shared.
Right to Opt-Out: You have the right to direct us not to sell your personal data. To exercise this right, please contact us.
Right to Delete: You may request deletion of your personal data, subject to certain exceptions (e.g., to complete a transaction, detect security incidents, comply with legal obligations, or engage in research).
Right Against Discrimination: You will not be discriminated against for exercising your CCPA rights.

For EEA Residents (under the GDPR):

Right to be Informed: We will provide you with clear information on how your personal data is used.
Right of Access: You can request access to the personal data we process about you.
Right to Rectification: You can ask us to correct any inaccurate or incomplete data.
Right to Erasure (“Right to be Forgotten”): Subject to certain exceptions, you may request the deletion of your personal data.
Right to Restrict Processing: You may request that we limit the processing of your personal data.
Right to Data Portability: You have the right to receive your data in a structured, commonly used, and machine-readable format.
Right to Object: You can object to the processing of your data, including for direct marketing purposes.
Rights Related to Automated Decision-Making and Profiling: You have the right to obtain meaningful information about any automated decision-making or profiling.

For Singapore Residents (under the PDPA):

Right to Access: You may request access to your personal data held by us.
Right to Correction: If you believe your data is inaccurate or incomplete, you may request that we correct it.
Right to Withdraw Consent: You may withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing conducted prior to the withdrawal.
Right to Accuracy and Protection: We will take reasonable measures to ensure that your personal data is accurate, complete, and protected from unauthorized access or disclosure.
Right to Private Action: Should you suffer loss or damage due to a breach of your rights, you may have the right to seek redress through legal action.

To exercise any of your rights, please send a written request to the contact details provided below. We may require additional information to verify your identity before processing your request. We will respond to your request in accordance with applicable laws and within a reasonable time frame.

10. Liability Disclaimer

While we take reasonable steps to safeguard your personal data, the App and our data processing practices are provided “as is” and “as available.” We make no express or implied warranties regarding the security or reliability of our systems. In no event shall I, Aaron Charles Gabriel, be liable for any direct, indirect, incidental, consequential, or punitive damages arising from your use of the App or your reliance on the security of your personal data, except where prohibited by applicable law.

11. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. When we do, the updated version will be posted on the App with a new “Last Updated” date. Your continued use of the App after any modifications constitutes your acceptance of the updated Privacy Policy. Please review this Privacy Policy periodically to stay informed about our practices.

12. Contact Us

If you have any questions, comments, or requests regarding this Privacy Policy or our data processing practices, please contact us at: Email: support@mentaljourneyapp.com

By using the MentalJourney App, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy.