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ComSyWorld › Mindfulness › Privacy Policy

Privacy Policy

Mindfulness · Last Updated: 09 July 2026

1. Introduction

Welcome to the My Mindfulness App mobile application ("My Mindfulness App" or the "Application"). This Privacy Policy explains how Emwiasoft Ltd (the "Company", "we", "our", or "us") collects, uses, processes, stores, and protects information in connection with your use of the Application. The Company is incorporated and operates under the laws of the Republic of Bulgaria. My Mindfulness App has been designed in accordance with the principles of Privacy by Design and Data Minimisation. The Application processes only the minimum amount of information necessary to provide its intended functionality. This Privacy Policy has been prepared in accordance with the following:

  • Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”);
  • Google Play Developer Program Policies;
  • Google Play User Data Policy;
  • Apple App Store Review Guidelines;
  • Apple Developer Program License Agreement;
  • Other applicable privacy and consumer protection laws.

2. Data Controller

Emwiasoft Ltd 2A Frederic Joliot-Curie Blvd., 1113 Sofia, Bulgaria Company Registration Number: BG207392577 Email: marketing@emviasoft.com

3. Scope

This Privacy Policy applies solely to the My Mindfulness App mobile application on Android and iOS. It does not extend to Google Play, the Apple App Store, Google Play Billing, Apple In-App Purchases, or any operating system services, each of which is governed by its own respective policy.

4. Information We Collect

The Application does not require an online account and does not collect or store on our servers your name, email address, telephone number, postal address, payment card information, precise location, contacts, photos, videos, microphone recordings, or any journal entries, mood logs, or session history that you create within the Application. Certain limited technical data (such as IP address or device identifiers) may pass through Google's and Apple's own infrastructure when the Application communicates with Google Play Billing or Apple In-App Purchases in connection with your one-time purchase. This technical data is processed directly by Google or Apple under their respective privacy policies; the Company does not receive, view, or store it.

5. Local Data Storage

All journal entries, mood logs, meditation and breathing session history, and preferences created within the Application are stored locally on the user's device. The Company has no ability to access, read, modify, or recover such records. If the operating system's standard backup feature is enabled on the user's device (such as iCloud Backup on iOS or Google Drive backup on Android), locally stored Application data may be included in that backup as part of the general device backup process. Such backups are created, stored, and controlled entirely by Apple or Google in accordance with their own policies; the Company has no access to, and cannot retrieve or restore, data from these backups.

6. Notifications

The Application may send local notifications to remind you of your meditation or mindfulness practice. These notifications are generated entirely on your device and are not sent through, or logged by, the Company's servers. You may disable notifications at any time in your device settings.

7. Analytics

The Application does not use Google Analytics for Firebase or any other analytics, tracking, or advertising service. We do not collect usage statistics, and we do not use analytics for user profiling, targeted advertising, or the sale of user information.

8. Purchases and Payments

Users may use My Mindfulness App free of charge during an initial 7-day trial period. After the trial period, full lifetime access to premium features is unlocked through a one-time in-app purchase. Current pricing is available within the Application and in our Terms of Service. All payments are processed exclusively through Google Play Billing and Apple In-App Purchases. The Company never receives or stores payment card information. This is a one-time purchase, not a subscription. It does not renew and no recurring charge will be made for continued access.

9. Data Sharing

We do not sell or rent user information. User-created records are never shared with third parties. Payment information is processed solely by Google or Apple, as applicable. As Google and Apple may process data outside the European Economic Area, any such international transfer is carried out under the safeguards implemented by Google and Apple, including the European Commission's Standard Contractual Clauses, as described in their respective privacy policies.

10. Security

We implement appropriate technical and organisational measures to protect the Application and its services. Users remain responsible for safeguarding their own devices and any locally stored data.

11. Data Retention

User-created data remains on the user's device until deleted by the user or removed through uninstallation of the Application.

12. Children's Privacy

The Application is not directed to children under the age of 16, and we do not knowingly collect personal data from children.

13. Your Rights

Where applicable, users may exercise their privacy rights under the GDPR. As we do not store user-created records on our servers, most data can be deleted directly from the user's device. To the extent the Company processes any personal data (for example, in response to a query sent to our contact email), users may exercise the following rights by contacting us at marketing@emviasoft.com:

  • Right of access to personal data held about you;
  • Right to rectification of inaccurate or incomplete data;
  • Right to erasure (“right to be forgotten”);
  • Right to restriction of processing;
  • Right to data portability;
  • Right to object to processing based on legitimate interest. The Company has not appointed a Data Protection Officer, as this is not required given the limited scope and nature of the personal data processed. If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection “CPDP”, or with the supervisory authority of your own EU member state.

14. Changes to this Policy

We may update this Privacy Policy from time to time. Any changes become effective upon publication of the updated version within the Application.

15. Contact

Emwiasoft Ltd 2A Frederic Joliot-Curie Blvd., 1113 Sofia, Bulgaria Company Registration Number: BG207392577 Email: marketing@emviasoft.com

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