The Cross.social platform, which was utilized to create the "Mind University" website and mobile application, handles user data in a manner that is legal, impartial, and clear regarding privacy. All data is used solely for the purposes that have been defined, and only to the extent that is necessary to achieve those objectives. Our goal is to maintain the accuracy, confidentiality, security, and appropriate protection of your personal information.
To guarantee that your information is processed appropriately, "Mind University" adheres to the regulations of the General Data Protection Regulation (referred to as "GDPR"), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other legal statutes concerning the processing of personal data.
Principles of Data Processing
We follow strict principles when processing your data:
- We process your personal data in a lawful, fair, and transparent manner.
- We comply with the applicable legislation, including the GDPR.
- We collect data for legitimate, clearly defined, and specified purposes, and we do not process it in a way that is incompatible with those purposes.
- We make sure that your personal data is accurate, relevant, rectified, supplemented, suspended, or deleted promptly if incorrect.
- We store your personal data for as long as necessary, in a form that permits the identification of data subjects.
- We process your personal data with appropriate technical and organizational measures to ensure the proper security of the data.
Purposes and Justification for Data Processing
We process your personal data for the following purposes:
- To provide services to registered users on the Website, such as using the social networking platform, posting comments, sharing information, receiving notifications about topics of interest, etc.
- To ensure the functionality of the Website and improve it by offering better services tailored to your needs.
- To improve and measure the performance of our Website and social media accounts.
- To ensure the functionality and improvement of our mobile application.
We collect and process your personal data based on the following legal grounds:
- The performance of a contract (in case of downloading the mobile app).
- Our legitimate interest.
- Compliance with a legal obligation to which we are subject.
Personal Data Procession and Collection Methods
If you are a registered user of the Website or mobile application, we process the following personal data:
- Identification data, such as your name, surname, nickname, and email address.
- Contact details, such as your phone number.
- Date of registration (automatically generated data).
- Your profile picture or image (if uploaded).
When you post comments on the Website, your social network account is also processed to ensure ethical commenting and identifying the user in case of law violations. This information is removed along with the comment.
If you use personalized content filters, we process the data on topics of interest, authors, and sources that you have marked yourself.
If you visit "Mind University" or its mobile app without registering, some non-personal data is still automatically transmitted after your visit, which is collected to enhance the site's content, attractiveness, and functionality or for other lawful purposes. This data includes the number of visits, the type of web browser used, pages viewed on the Website, the amount of time spent on the Website or mobile application, and your social network public information if you visit "Mind University" social network accounts. If you visit your social network accounts and post comments, your social network account will be visible to ensure ethical comments are posted and users can be identified in case of a breach of Lithuanian laws.
Any additional information provided as a registered user or member of a social network will only be stored until it is deleted. We do not require you to provide or process your special categories of personal data revealing your racial or ethnic origin, philosophical or religious beliefs, political opinions, or trade union membership. We also do not process or request data about your sex life, sexual orientation, or health.
We may combine the personal data we receive from you with data collected from other public or accessible sources. You have the right to correct inaccurate personal data.
You can choose to allow or disallow your personal data to be used to send the "Mind University" newsletter by checking or unchecking the "I agree to receive the "Mind University" newsletter by email" box when registering on the Site.
Even if you have agreed to process your personal data to send the newsletter, you can withdraw this consent at any time for all or part of the processing of personal data. You can do so by notifying us of your opt-out in the manner indicated in the emails and/or offers you receive. Withdrawing consent does not automatically require us to destroy your personal data.
Collection, use, and sharing of personal data on social networks
If you use our website as a social networking platform, we will safeguard any personal information you share, but you remain responsible for the content you post. You can modify or remove any content you publish at any time. Deleted content is not subject to any additional protections. Still, we reserve the right (if technically feasible) to restore and make available such content when requested by authorized parties in compliance with applicable laws.
When you use our social network, we gather, process, and store the following information about you:
- Content that pertains to you that you and others generate or provide.
This encompasses the content you produce and the information you supply when using our products, such as any data you provide when you register, any content you share or create, any information you provide when engaging with other users, and the data contained within and regarding the content you produce (e.g., metadata, the date or location of the creation of a particular file, etc.). Additionally, we may gather the information you encounter while utilizing our features to execute certain actions. All data is automatically collected and processed.
It is important to note that we do not request sensitive information such as your political or religious views, health status, hobbies, or any other data that may require special protection. Nonetheless, you have the option to disclose such information by including it in your account details or through other content submission means.
- We gather details regarding your network and associations. This covers all groups, pages, individuals, and other pertinent data that you interact with, visit or use through our social network or other services. Additionally, if you choose to import or sync your contact information from your device, we collect and store that data to assist users in locating the people they want to connect with and for other information and functionality purposes.
- We gather information about your usage patterns when you utilize our services, which encompasses various types of data revealing how you engage with our offerings. This includes the content you view, the features you select, the individuals with whom you interact, and the frequency, duration, and timing of your service usage.
- Additionally, we record information and activities relating to you that are provided by others. For example, individuals may leave comments on your uploaded content, send you messages, or sync your contact information. We continually receive and analyze this information.
- We also gather and assess information from the devices you employ to access our services. This information comprises device features (such as operating system, browser type, hardware and software versions, available storage space, signal strength, and more), device activities and operations (such as mouse movements, open window positions, and so on), unique identifiers (such as device IDs and other unique markers), device settings (such as camera access permissions, GPS location tracking settings, etc.), cookie data, device signals (this encompasses Bluetooth signals and information regarding nearby WiFi access points, cell towers, and transmitters), networks and connections (such as your device's language settings, time zone, internet service or mobile operator name, IP address or mobile phone number, internet speed, and in some cases, the devices on your network or nearby devices that may be used to transfer our services to another device).
- We gather data that comes from our partners.
Various app developers, advertisers, and other partners may send us diverse information through the tools they use along with our services. This data includes your activities outside of our website or mobile app and may encompass information such as your device details, web pages visited, advertisements viewed, and your use of our partners' services or purchases. We may get this information even if you are not logged in to an account on our website, but we make sure that our partners have the right to collect, use, and provide your data to us.
All the information we gather, store, and examine when you use our social network is maintained and gathered in compliance with relevant laws. We may utilize this information to enhance our services and analyses, and also for advertising and other lawful purposes. We may use the information we have in the following ways:
- To personalize, improve, and provide our services to you. We use the information we gather to deliver content and offers that are tailored to your preferences and interests, which we obtain from you and others.
- To test and enhance our services. We use the information we gather about your activities and devices to offer you more relevant content or to make our products more convenient for you. We also use location data (such as your current location, frequently visited places, nearby businesses or people, etc.) to improve our services, which may include advertising. We obtain this location data through your IP address, usage of our services, or your consent to share your device's exact location.
- Furthermore, we use the data we have about you, such as your contacts, activities, and interests, to personalize the advertisements and sponsored content we display to you.
When we interact with you, we use the information we collect to:
- Communicate with you about our services, policies, and terms, and send you marketing communications.
- Additionally, we use the information you provide us with when you contact us to answer your questions.
We use the information we receive to promote safety, security, and integrity by:
- Verifying accounts and social network activity to prevent spam and identify harmful or suspicious behavior.
- This also helps us to detect and remove inappropriate content that may jeopardize the safety, security, and integrity of our services.
We use the information we gather to provide analytics, measurement, and other services that:
- Help our partners and advertisers measure the effectiveness and distribution of their services and advertisements.
- The data we collect assists us in understanding how people behave when using services and websites and the types of people who use these services.
We share information about you in different ways and for different reasons. Below is a more detailed explanation of how we share this information.
- Sharing your information or public information on our website or mobile app.
When you use our services to communicate or share something, the information you provide is visible to others, depending on your settings or the location where you share information. Some actions you take while using our services or engaging with sponsored or promotional content may also be visible to others. Certain information, such as your publicly shared content, public profile information, and other data that you have chosen to share with your audience as a whole (even those who are not registered on the social network), is publicly available. We may also share this public information with our other products, such as search results or application programming interfaces, or with users who use them.
- Sharing of information provided by others and re-sharing of information.
It's important to keep in mind that even if you only share certain information with specific people, they may choose to re-share your content, exposing it to others, including individuals or companies who were not part of the original audience. Others may save screenshots, download your content, and reuse or share it.
If you leave a comment or reaction to someone else's content, it may be visible to anyone monitoring that content. The person who posted the content can also adjust their settings, which could make your comment visible to a larger or smaller audience.
Keep in mind that other users of our social network or other services may create content related to you and share it with specific audiences. For example, someone might upload a photo of you or mention you in a post.
If you come across content that violates our rules or have other concerns, you can contact our team to report it.
Our services may provide information about your activity to certain people, depending on your privacy settings. If you're not currently logged in, these individuals may even be able to see the last time you used our social network.
If the operator or owner of our services changes, we reserve the right to transfer your information to the new owner.
Information may be shared with different partners. We may share your information with our partners to improve our services or analytics. However, we have strict requirements in place to ensure that our partners use the information responsibly and we never sell your information.
We provide aggregated data to our partners who use our analytics services to help them understand how users interact with content on our platform. This information includes the number of views on a post or other relevant facts to analyze user engagement.
Advertisers also receive reports with aggregated information about the effectiveness of their ads, demographic information, and the number of people who saw their ads. All information provided to advertisers is anonymous and does not identify you.
We provide your information to our partners to aggregate data and generate reports, and we also share information with vendors who help us with various functions, such as maintenance services.
Please note that we comply with applicable laws and cooperate with law enforcement authorities. We may provide all necessary information to law enforcement authorities if required by law or to respond to legal requests.
As with many other websites and mobile applications, we utilize cookies and similar technologies to collect information about you to make using our Website easier. These small files are temporarily stored on your device's hard drive and enable us to recognize you during subsequent visits to the Site. By saving your browsing history and preferences, we can tailor more relevant content to you, improve the efficiency and reliability of the Site, speed up your searches, and more.
The information collected from cookies is used for various purposes, including but not limited to:
- Ensuring the proper functioning of the Website or mobile application (e.g. personalized settings)
- Ensuring the reliability and security of your account, data, and our services
- Identifying and verifying when you are logged in to your account to make it easier to use our services
- Making appropriate improvements to the Website or mobile application based on your feedback
- Analyzing your use of the Website or mobile app to develop our services
- Targeted marketing
We may combine data collected from cookies with information obtained from other sources, such as the personal data that you have provided to us. We use the following types of cookies:
- Essential technical cookies, which are necessary for the proper functioning of the Website or mobile application
- Functional cookies, which are not necessary but significantly improve performance, quality, and user experience
- Statistical cookies, which are necessary for statistical analysis of visitor navigation methods on the Website or mobile application (collected anonymously)
- Advertising or targeting cookies, which are used to display offers or other information that may be of interest to you.
- By keeping them and/or adjusting your browser settings so that it accepts cookies;
- By selecting the "I agree" checkbox in the cookie settings.
Please note that certain features of the Website or mobile application may be affected, such as slower browsing speed, limited access, or restricted functionality, especially when technical and functional cookies are disabled or not accepted.
Third-Party Data Sharing
To provide certain services, we may disclose your personal information to third-party service providers such as IT, data storage, telecommunications, and delivery services. However, they are prohibited from using your information for any other purposes except for providing services to us.
Duration of data retention
- If you have registered on our Website or mobile application and provided personal data, we will retain it for as long as you are a registered member, until you delete your account.
We make an effort to avoid storing outdated, irrelevant, or incorrect personal data, and only retain the most up-to-date information that has been updated (e.g. if you update your account information). Old data is only retained if required by law or for the performance of our activities.
If you decide to delete your account, all information that you have posted, including photos, posts, and comments, will also be deleted. This information cannot be retrieved at a later date, so please make sure to save any important content before deleting your account. Information shared about you by others is not part of your account and will not be deleted, even if you delete your account.
Ensuring the security of personal data
Please be aware that while we take measures to protect your personal data, the transmission of information over the internet is not completely secure. Therefore, you bear the risks associated with transmitting personal data to us, as we cannot guarantee the security of such data during transmission. Once we receive your personal data, we have strict procedures and security measures in place to protect it from unauthorized access.
In the event of a security breach of your personal data that may seriously threaten your rights or freedoms, we will promptly notify you once we become aware of the breach and identify the data that has been unlawfully accessed.
Please be advised that "Mind University" may include hyperlinks to external websites, such as those of our business partners. Please note that we do not assume responsibility for the privacy policies or the lawfulness of data processing on websites that are not operated by us. Before submitting any personal data or using any services provided by external websites, it is recommended that you review their policies on data protection and processing.
Data subject rights
As we process personal data, we uphold your rights under the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a data subject, you have the following rights:
- The right to be informed about the processing of your personal data.
- The right to access the personal data being processed.
- The right to correct or supplement inaccurate personal data.
- The right to request the destruction of personal data that is no longer necessary for the purposes it was collected for.
- The right to request the destruction of personal data if the processing is unlawful, if you have withdrawn your consent to the processing of your personal data, or if you do not give such consent even though it is necessary.
- The right to object to the processing of personal data.
- The right to withdraw your prior consent to the processing of personal data.
- The right to request the personal data collected with your consent or for the performance of a contract to be provided to you (if technically feasible) or to request that it be transferred to a third party.
We are committed to ensuring that you can exercise your data subject rights effectively and under appropriate conditions. However, we reserve the right to decline your requests or requirements when necessary to maintain compliance with legal obligations, national defense or security, public order, prevention, investigation, detection, or prosecution of criminal offenses, important financial or economic interests of the State, prevention, investigation, and detection of breaches of professional or official ethics, or the protection of your rights and freedoms or those of others.
To exercise your rights as a data subject, you may submit requests or demands to us through in-person, post, or email channels. Upon receiving a request, we may ask you to provide proof of identity or additional information related to the request, which we will delete after identification.
We will respond to all requests within 30 calendar days from the date of receipt and after the provision of the necessary data to respond. If necessary, we may suspend the processing of your data, except for storage, until your request is resolved. If you lawfully withdraw your consent or request the erasure of your personal data, we will immediately cease processing your data according to GDPR procedures, except when statutory provisions mandate us to continue processing data or we are under legal obligations, court decisions, binding instructions from the authorities, and other relevant legislation.
If we decline your request, we will provide clear grounds for doing so. If you disagree with our actions or response to your request, you have the right to contact the competent public authority.
Making a complaint
If you believe that your personal rights have been violated under the GDPR, we will work with you to resolve any disputes, but you also have the option of filing a complaint with the State Data Protection Inspectorate, the supervisory authority (address: A. Juozapavičiaus g. 6, 09310 Vilnius, website: www.ada.lt).
If you believe that we have violated your rights or legitimate interests in the field of consumer protection, we also recommend that you first contact us in writing at the contact addresses listed at the end of this policy. Consumer disputes are resolved out of court by the State Consumer Rights Protection Service (address: Vilniaus g. 25, 01402 Vilnius, e-mail: [email protected], phone: 8 5 262 67 51, website: www.vvtat.lt).
By post: Multiverse Ltd, Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro (PO Box 1405), Marshall Islands
By email: we[@]mind.university