THE NOT YOU™ Privacy Policy

Mind Clarity Works LLC (“Mind Clarity Works,” “we,” “us,” or “our”) operates THE NOT YOU™ mobile application and related digital experiences covered by this Privacy Policy (collectively, the “Services”). This Policy explains how we collect, use, disclose, retain, protect, and delete personal information when you use the Services.

This Policy applies to THE NOT YOU™ mobile application on iOS and Android, thenotyou.com where this Policy is posted, and related THE NOT YOU™ digital services that expressly link to or incorporate this Policy. It does not automatically apply to unrelated products that Mind Clarity Works LLC may operate under a separate privacy notice.

For purposes of applicable privacy laws, Mind Clarity Works LLC is the business, controller, or other entity responsible for personal information unless a different role is stated for a particular service or jurisdiction.

2.1 Information You Provide

• Account and identity information, such as your name, email address, sign-in method, account identifier, and authentication-related information when you create or access an account through email, Google Sign-In, Sign in with Apple, or another supported method.
• Profile and preference information, such as language, notification choices, saved settings, selected session preferences, and personalization settings.
• Assessment and wellness information, including Mind Clarity Index™ responses and scores, progress information, and interactions with features such as Daily Mind Detox, Trauma Trigger, Addiction Breaker, Guilt Cleanser, Anger Tamer, Blind Forgiveness, and other mindfulness or self-development modules.
• Communications, including messages, feedback, support requests, survey responses, and other information you choose to provide to us.

2.2 Information Collected Automatically

• Usage and playback information, such as sessions or audio tracks played, playback progress, completion status, feature engagement, session duration, and interactions with app features.
• Device and technical information, such as device model, operating system and version, app version, IP address, device or installation identifiers, language, time zone, network information, and similar technical data.
• Diagnostics and security information, such as crash reports, performance logs, authentication events, error reports, and information used to detect abuse, fraud, or unauthorized access.

2.3 Subscription and Transaction Information

Subscriptions and promotional trials purchased through the mobile application are processed by Apple through In-App Purchase or by Google through Google Play Billing. Mind Clarity Works LLC does not directly receive or store your full payment card credentials from those purchases. We may receive information such as subscription tier, entitlement status, purchase or transaction identifiers, renewal status, trial status, and related billing metadata needed to provide access and support.

THE NOT YOU™ is designed around mindfulness, self-observation, personal development, and emotional wellness. Some information you provide or generate through the Services may be sensitive because it can reflect or allow inferences about your thoughts, emotions, habits, behavioral patterns, or wellness interests.

We apply heightened care to Mind Clarity Index™ responses and scores, wellness-module interactions, progress information, and similar information. We use this information to provide requested features, maintain progress, personalize the experience where enabled, support the user, maintain safety and security, and improve the Services in accordance with this Policy.

Privacy commitment: We do not intend to sell Mind Clarity Index™ responses, assessment responses, or wellness-module activity, and we do not intend to use that information for third-party behavioral advertising. If our practices materially change, we will update this Policy and provide any notice or consent required by law before the new practice applies.

Please do not submit information through the Services that you do not want us to process. The Services are not designed to receive medical records, clinical diagnoses, psychotherapy notes, or emergency medical information.

We collect information directly from you when you create an account, complete an assessment, change settings, use a wellness module, communicate with us, or otherwise provide information. We also collect certain information automatically from the App and devices through which you access the Services. We may receive limited information from platform providers and service providers, such as Apple, Google, and Firebase, when necessary to authenticate users, process subscriptions, maintain security, or operate the Services.

We may use personal information to:

• Create, authenticate, maintain, and secure user accounts.
• Provide audio sessions, assessments, wellness modules, progress tracking, personalization, language preferences, and other requested functionality.
• Calculate and display Mind Clarity Index™ scores and related progress information.
• Administer free and paid subscription tiers, promotional trials, purchases, and feature entitlements.
• Send service messages, requested reminders, daily detox notifications, weekly assessment reminders, and other communications consistent with your preferences.
• Provide customer support and respond to requests, feedback, complaints, and privacy inquiries.
• Detect, investigate, and prevent fraud, abuse, security incidents, unauthorized access, and technical problems.
• Analyze performance and usage, diagnose crashes, improve reliability, develop features, and understand how the Services are used.
• Comply with applicable law, enforce our agreements, protect our legal rights, and protect users and others.

Where laws such as the European Union General Data Protection Regulation (“EU GDPR”) or United Kingdom GDPR require a legal basis, we process personal information under one or more of the following bases, depending on the purpose and circumstances:

• Performance of a contract or steps requested before entering a contract, including providing the account, subscription, and requested Services.
• Legitimate interests, such as maintaining security, preventing fraud, improving product reliability, providing support, and understanding service performance, where those interests are not overridden by your rights and interests.
• Consent, where we ask you to make an optional choice or where applicable law requires consent for a particular activity.
• Compliance with legal obligations, including tax, accounting, consumer protection, privacy, security, and lawful process requirements.
• Other lawful grounds available under applicable law, including where processing is necessary to establish, exercise, or defend legal claims.

Where sensitive information requires a separate legal condition or consent under applicable law, we will rely on an appropriate condition and obtain consent where required.

THE NOT YOU™ may use automated systems to deliver or personalize digital experiences. If we introduce artificial intelligence features that process personal information, we will evaluate the data flows and disclose material practices in this Policy or an in-product notice before or when those features are introduced.

We do not authorize third-party AI providers to use private Mind Clarity Index™ responses or private wellness-assessment information to train their general-purpose models unless we have clearly disclosed that practice and obtained any permission required by law. We may use de-identified or aggregated information to improve the Services where permitted by law and subject to appropriate safeguards.

If you enable notifications, THE NOT YOU™ may send reminders such as daily detox notifications, weekly assessment reminders, subscription-related notices, or other service messages. You can manage push notifications through in-app settings where available and through your device settings. You may opt out of non-essential promotional communications by using the unsubscribe method provided in the message or by adjusting available communication preferences. We may still send non-promotional communications necessary to operate your account, respond to requests, or provide important legal or security notices.

Mobile subscriptions are administered through the platform on which they were purchased. Apple and Google are independent providers with their own privacy and payment practices. Deleting THE NOT YOU™ App from your device does not cancel your subscription. Deleting your THE NOT YOU™ account also does not automatically cancel a recurring Apple App Store or Google Play subscription. To stop recurring charges, you must cancel the subscription through the applicable store account or subscription settings.

We may retain limited transaction and entitlement records when necessary for accounting, fraud prevention, customer support, dispute resolution, legal compliance, and subscription administration.

We do not disclose personal information indiscriminately. We may disclose information in the following circumstances:

• To service providers and processors that perform services for us, such as cloud hosting, authentication, storage, diagnostics, payment/subscription administration, communications, customer support, security, and analytics.
• To Apple or Google as necessary to authenticate users, administer platform services, validate purchases, manage subscriptions, or comply with platform requirements.
• To professional advisers, auditors, insurers, or other advisers when reasonably necessary for legitimate business, legal, security, or compliance purposes and subject to appropriate duties of confidentiality.
• To government authorities, courts, law enforcement, or other parties when required by law or when reasonably necessary to protect rights, safety, security, users, or the public.
• In connection with a merger, financing, acquisition, reorganization, sale of assets, or similar business transaction, subject to applicable law and appropriate protections.
• With your direction or consent.

We require service providers that process personal information on our behalf to use it only for authorized purposes and to provide protections appropriate to the nature of the information and applicable law.

The Services currently rely on or may integrate with platform and infrastructure providers including:

• Google Firebase / Google Cloud services for functions such as authentication, cloud data storage, app infrastructure, diagnostics, and related backend services as configured in the production environment.
• Google Play Billing for Android subscription purchases and entitlement-related information.
• Apple In-App Purchase and related Apple platform services for iOS subscription purchases and entitlement-related information.
• Google Sign-In and Sign in with Apple, where enabled, for authentication.

We may add, replace, or remove service providers as the Services evolve. Before launch and after material technical changes, we review the production SDK and service-provider inventory so that this Policy and applicable App Store / Google Play privacy disclosures accurately reflect the data practices of our code and integrated third parties.

We do not intend to sell personal information in exchange for money. We also do not intend to sell or use private wellness-assessment information for third-party behavioral advertising. If THE NOT YOU™ introduces advertising, cross-context behavioral advertising, cross-app tracking, or other practices that constitute “sale,” “sharing,” or “targeted advertising” under applicable law, we will update our disclosures and provide legally required choices before those practices apply.

Where Apple App Tracking Transparency or comparable platform permissions apply, we will request permission as required before engaging in covered tracking. You can also manage certain device-level privacy choices through your operating system settings.

Certain U.S. state laws may define “consumer health data” broadly enough to cover information that identifies or can reasonably be linked to a consumer and relates to health, mental or physical condition, or wellness-related inferences. Depending on how you use THE NOT YOU™ and where you reside, assessment responses or wellness interactions could fall within such definitions.

Where a consumer health data law applies to our processing, we will provide any additional notice, consent, authorization, access, deletion, or other rights required by that law. We do not intend to sell consumer health data. We do not intend to use consumer health data for third-party behavioral advertising.

If a jurisdiction requires a separate Consumer Health Data Privacy Notice, that notice may supplement this Policy and will be made available through the applicable Service or website.

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including providing the Services, maintaining security, resolving disputes, enforcing agreements, meeting legal obligations, and supporting legitimate business operations. Retention periods vary by data type, purpose, account status, and legal requirements.

Account/profile data

While the account remains active, then deleted or de-identified following a valid deletion request, subject to limited lawful retention.

Mind Clarity Index™ and wellness progress

Generally while needed to provide progress and requested features, until deleted by the user or through account deletion, subject to lawful retention.

Playback and usage information

For the period reasonably necessary to operate, personalize, secure, and improve the Services, then deleted, aggregated, or de-identified.

Diagnostics/security logs

For a limited operational period appropriate to troubleshooting, security, fraud prevention, and legal obligations.

Support communications

For the period reasonably necessary to resolve requests, maintain support history, protect legal rights, and comply with law.

Subscription/transaction records

As necessary for entitlement administration, accounting, tax, fraud prevention, disputes, and legal obligations.

Backups

May persist temporarily in secure backup systems until overwritten or deleted through normal backup lifecycle procedures.

We may retain limited information longer where required or permitted for security, fraud prevention, legal compliance, tax/accounting, dispute resolution, or establishment, exercise, or defense of legal claims. When information is no longer needed, we take reasonable steps to delete, de-identify, or otherwise dispose of it.

We use administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, destruction, or loss. Depending on the system and context, these measures may include access controls, authentication, encryption in transit, encryption at rest where supported, logging, monitoring, secure cloud infrastructure, least-privilege access practices, and incident-response procedures.

No method of internet transmission or electronic storage is completely secure. We therefore cannot guarantee absolute security. If we become aware of a security incident affecting personal information, we will investigate and provide notices to affected individuals or regulators when required by applicable law.

Mind Clarity Works LLC is based in the United States, and our service providers may process information in the United States and other countries. Those countries may have privacy laws that differ from the laws where you live. Where required, we use recognized transfer mechanisms and safeguards for international transfers, such as adequacy decisions, contractual protections, or Standard Contractual Clauses, as applicable.

17.1 In-App Account Deletion

If you have a THE NOT YOU™ account, you can initiate deletion through the account or settings area of the App where the feature is available. We may ask you to reauthenticate or confirm the request to protect your account from unauthorized deletion.

17.2 External Deletion Request

If you cannot access the App, you may use the account-deletion resource published on thenotyou.com or contact Mind Clarity Works LLC using the contact information in Section 26. We may verify your identity before completing a deletion request.

17.3 What Deletion Means

When an account deletion request is completed, we delete or de-identify the personal information associated with the account that we are not required or permitted to retain. This may include account/profile information, Mind Clarity Index™ assessment history, wellness progress, saved preferences, and associated usage information. Limited information may remain temporarily in backups or may be retained where necessary for security, fraud prevention, legal compliance, accounting, transaction records, dispute resolution, or legal claims.

17.4 Subscription Cancellation Is Separate

Deleting your account does not automatically cancel a recurring Apple App Store or Google Play subscription. To avoid future recurring charges, cancel the subscription through the applicable store. Account deletion and subscription cancellation are separate actions.

Depending on where you live and subject to applicable exceptions, you may have rights to:

• Access or obtain a copy of personal information we hold about you.
• Correct inaccurate personal information.
• Delete personal information or your account.
• Object to or restrict certain processing.
• Withdraw consent where processing is based on consent, without affecting processing already lawfully completed.
• Receive certain information in a portable format.
• Opt out of certain targeted advertising, sale, sharing, or profiling practices if they apply.
• Appeal certain decisions regarding a privacy request where applicable.
• Not be discriminated against for exercising applicable privacy rights.

You can exercise available rights through in-app controls, the privacy or account-deletion resources on thenotyou.com, or the contact methods in Section 26. We may verify your identity and may ask for information reasonably necessary to process the request. Authorized agents may submit requests where permitted by law, subject to verification requirements.

If you are in the European Economic Area or United Kingdom, applicable law may provide rights including access, correction, erasure, restriction, objection, data portability, and withdrawal of consent. You may also have the right to lodge a complaint with the data protection authority in your country or region. Where we rely on legitimate interests, you may object to processing in circumstances provided by law. Where we rely on consent, you may withdraw it at any time for future processing.

Mind Clarity Works LLC is the controller of personal information covered by this Policy unless otherwise stated. If applicable law requires appointment or disclosure of a local representative or data protection contact, we will publish the relevant details in an updated notice.

Residents of California and certain other U.S. states may have privacy rights concerning access, deletion, correction, portability, opt-out of certain sale/sharing/targeted advertising, sensitive personal information, profiling, and appeal. The availability and scope of these rights depend on the law that applies to Mind Clarity Works LLC and to the particular processing activity.

We do not intend to sell personal information for monetary consideration. We also do not intend to sell or use private wellness-assessment information for third-party behavioral advertising. If our practices change in a way that creates an opt-out right under applicable law, we will provide the required method to exercise that choice.

We will not discriminate against you for exercising a privacy right protected by applicable law. We may need to verify your identity before completing certain requests.

THE NOT YOU™ is not directed to children under 16. We do not knowingly collect personal information from children under 16 through the general-audience Services. If you believe a child under 16 has provided personal information to us, contact us so that we can investigate and take appropriate action, including deletion where required.

If we later offer a version or feature specifically intended for younger users, we will implement age-appropriate notices, parental or guardian consent mechanisms, and other safeguards required by applicable law before offering that experience.

THE NOT YOU™ is an educational self-help, mindfulness, and personal-development service. It does not provide medical, psychiatric, psychological, or clinical diagnosis, advice, or treatment. Mind Clarity Index™ scores, assessments, exercises, audio sessions, and wellness-module interactions are intended for personal reflection and mindfulness tracking and are not medical records or diagnostic tests.

Use of the Services does not create a doctor-patient, therapist-client, psychologist-patient, or other licensed healthcare relationship with Mind Clarity Works LLC. THE NOT YOU™ is not a substitute for professional medical or mental-health care.

THE NOT YOU™ is not an emergency response or crisis-intervention service. If you believe you or another person is in immediate danger, contact local emergency services or an appropriate qualified crisis resource in your jurisdiction.

The Services may link to or rely on third-party websites, app stores, identity providers, or other services. Their privacy practices are governed by their own terms and privacy notices. We encourage you to review those notices. This Policy does not control independent processing performed by Apple, Google, or other third parties acting for their own purposes.

If Mind Clarity Works LLC is involved in a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar transaction, personal information may be transferred as part of that transaction subject to applicable law and appropriate safeguards. We may also preserve or disclose information when reasonably necessary to comply with law or valid legal process; enforce agreements; investigate fraud, security, or abuse; protect the rights, property, or safety of Mind Clarity Works LLC, users, or others; or establish, exercise, or defend legal claims.

We may update this Privacy Policy as the Services, technology, legal requirements, or data practices change. We will post the updated Policy and revise the “Last Updated” date. If a change is material, we will provide additional notice where required, such as an in-app notice, email, or consent request. Unless a different effective date is stated, the updated Policy becomes effective when posted or as otherwise permitted by law.

Mind Clarity Works LLC is responsible for this Privacy Policy. For privacy questions, requests, complaints, or account/data deletion matters, contact us through the privacy contact channel published in THE NOT YOU™ App or at thenotyou.com.