1. General

• It is of utmost importance for CompEAP to protect your personal data.
• This Privacy Policy explains to you the nature, extent and purposes of the processing of your personal data within the scope of our Online Services in our Application ("App"). In the following you will especially be informed which personal data we potentially collect, process and use when you use our App.

2. Which of your data do we collect, for which purposes and on which legal basis do we process it?

1. Contacting us

   When contact with us via e-mail or through other electronic channels (such as social media platforms), we process the data you voluntarily provided us with (name, e-mail address, nature of the enquiry respectively the subject of your message and the content of your message).

   We process the data provided within the course of contacting us solely for processing your enquiry, to get in contact with you if desired and to provide you with the requested information. This data processing is therefore necessary for the fulfilment of our (pre)contractual obligations.



2. Access data and log files

   We collect and process the following data when you use our App and the connected services, that means accessing the respective server which contains the specifically requested service (so called server log files): name of the accessed site, date and time of access, transmitted quantity of data, server status codes, username, processing time, browser and client type alongside the version, your operating system, referrer URL (the previously visited site), IP-address and the requesting provider, reverse DNS, location data, connection data, source and target (network discovery or address, port numbers, protocol, e-mail address, e-mail subject, connecting server, protocol details, reputation data, reverse DNS, obvious labelling, connected servers), authentication details and e-mail meta information.

   This data is generated automatically through our servers when you use our App and is necessary so that we can provide you with the desired services. We therefore process server log files solely to be able to operate our App and the connected services, to identify you as a user authorized to access, to distribute web server requests in our server pool as well as for security reasons (e.g. for clarification of abusive and fraudulent activities). Thus, this data processing activity is necessary to ensure our legitimate interests in operating a user friendly and secure App.



3. Usage data / Tracking

   Based on your consent declaration, we collect and process the following data about your use and interaction with our App: IP-address of your device, your operating system, the requested files from our App, screen resolution, phone model, your click behaviour in the App (time of access, clicks) as well as the source you install the App from. If the app crashes a crash report is sent to us.

   This data is collected through Tools (see point 3 below). We use this usage data for (i) analysis, (ii) improvements of our services and our App, (iii) increasing usability. This data processing takes place on the basis of your consent to the use of tools in our App. You can withdraw this consent at any time with effect for the future and free of charge.



4. Registration and User Account

   When you are registered in our App and have a user account for the use of our Online Services, we process the following personal data: name, e-mail address, billing data, IP address as well as your access data.

   We process the data of your user account solely for operating your account, the provision of our Services as well as for the billing of our services. This data processing is therefore necessary for the fulfilment of our (pre)contractual obligations.

   To be able to use our services, we ask you about your current state of health. We process this health data only with your prior consent. You can revoke this consent at any time without giving any reason. However, without this consent, the use of our app is not possible, since its main focus is to help you.

3. Tools

• We use several tools in our App. Such tools allow us to store important data in order to provide you with our services and to make the use of our App more comfortable for you.
• In addition, based on our legitimate interests, we use tools that are technically absolutely required to provide our service through the App. For example, to recognize you when you visit us, to make your data available to you, to monitor incoming and outgoing payments or to ensure the security of our App. In the following, we provide you with more transparent details on each of our tools:
  1. We use the tool Firebase to monitor the security and safetiness of the app and be aware of potential problems that we may wish to fix, such as crashes. This also provides us with analytics and reporting in aggregated form. More information is available here: https://firebase.google.com/support/privacy.
  2. We use the tool Sentry to monitor the functionality of the app and track bugs and crashes in order to fix them more efficiently. This also provides us with analytics and reporting in aggregate. More information is available here: https://sentry.io/privacy/.
  3. We also use the tool Codepush from Microsoft to ensure the correct function of your app in case of updates. You can find more information about this here:https://www.microsoft.com/us-en/trustcenter/privacy/where-your-data-is-located.
  4. Amplitude

     Based on your consent, we use Amplitude, an analysis service of Amplitude Inc. (501 2nd Street, Suite 100 San Francisco, CA 94107, United States) to analyse your user behaviour in our App. This data tells us how you interact with our App. When you open our App, information (device related data, such as device type, model operating system, browser type and version of Amplitude, device groups Usage-related information (such as geographical location, language, pages used) is gathered. The Privacy Policy of Amplitude can be found here: https://amplitude.com/privacy.

4. Is your data transmitted to third parties?

1. We entrust your personal data in the extent necessary to the following external service providers (data processors) that support us with the performance of our services:
   • IT-service providers and/or providers of data hosting solutions or similar services;
   • Other service providers, providers of tools and software solutions that support us with the download of our App, performance of our services as well and operate on our behalf (including providers of marketing tools, marketing agencies, communication service providers)
   All our data processors process your data only on our behalf and on the basis of our instructions so that we can provide you with our Online Services.
2. Apart from that, we transmit your personal data in the extent necessary to the following recipients (controllers):
   • Potential third parties that are participating in the provision of services to you for the fulfilment of our contractual obligations (e.g. login-services);
   • External third parties on the basis of our legitimate interests in the extent necessary (e.g. auditors and tax consultants, insurances in case of insured events, legal representatives in case of incidents);
   • Authorities and other public entities in the extent legally necessary.

5. Retention period

1. We store your personal data just as long as necessary for the purposes for which they are processed. Beyond that, we are potentially obligated to store your data for longer in accordance to legal retention periods.
2. Specifically, we store your data in connection with the establishment of contact with us in accordance with legal retention periods for a time period of usually seven years.
3. Access data and log files are stored for a maximum time period of 500 days and are erased subsequently.
4. We store data about your user behaviour for a time period of usually three years, or respectively at the latest until the withdrawal of your consent.
5. Provided that you have only registered for our newsletter and are, apart from that, no client of us, we store your data until the withdrawal of your consent and beyond that for a maximum of three years.
6. We store data in connection with your registration and your user account until the end of your client relationship with us, or respectively beyond that until the expiry of the respective legal retention periods (usually for a time period of seven years).
7. Apart from that, we also store your personal data after an incident beyond the above mentioned time periods as long as legal claims out of the relationship between you and us can be enforced, or respectively until the definitive clarification of an incident or legal dispute. This longer storage occurs for the ensuring of our overriding legitimate interests to the enforcement, clarification and defence of our legal claims.

6. Rights of Data Subjects

1. You have the right to access your personal data that is being processed by us. Apart from that, you have the right to rectification of inaccurate or incomplete data and – under certain circumstances – the right to erasure. Additionally, you have the right to restriction of processing as well as the right to data portability concerning the data you have provided us with.
2. Moreover, you have the right to object on grounds relating to your particular situation. Such an objection can in particular occur relating to processing of data for the purposes of direct marketing.
3. Additionally, you have the right to withdraw your consent at any time with effect for the future.
4. If you have questions relating to this or any other questions, you can contact us at:

   CompEAP, Inc.

   2 Mt Royal Ave, Marlborough, MA 01752

   help@mindtide.app

7. Data security

We comply with appropriate technical and organizational security measures, considering the risks, guarantee an appropriate data protection level, especially to protect your personal data against accidental or unlawful destruction, alteration or against loss and against unauthorised disclosure or unauthorised access.

8. Amendments of our privacy policy

Within the course of internet development, we will amend our Privacy Policy regularly. We will disclose amendments in our App. Therefore, you should visit this Privacy Policy regularly to be informed about the current status.

Updated: 2023-04-01