Norbu Mindfulness provides services that allow users to play games, breathe and meditate to reduce stress (caused at work, in relationships, with a busy rhythm of life), make the mind more calm, focused and resistant to stress factors, feel more confident and happy in daily life. The methods used in the applications are scientifically based on MEDLINE's most robust database of references and abstracts on life sciences and biomedical topics at PubMed .

PURPOSE OF OUR PRIVACY POLICY

Norbu Mindfulness (“Norbu”, “Company” or “we”) take you privacy very seriously and we ask you to carefully read this privacy statement to understand how we collect your information, what we do with your information, legal basis of processing your personal information, who your information may be shared.

DATA PROTECTION OFFICER

Our data protection officer is responsible for monitoring what we do with your information and for monitoring compliance with data protection laws. If you have any questions or concerns about our use of your personal data, you can contact our Data Protection Officer via email help@mynorbu.com

WHAT INFORMATION DO WE COLLECT?

We do not collect any personal data from the app, except automatically collected data and information that we may receive when a user interacts with the Service via Social Networks or via messages to the Service.

1.Messages and User Content

When you contact us directly by technical support chat, we will record your comments and opinions. We also may collect messages you send to us (for example technical support in order to provide support).

How we may use it: a) to provide, maintain, operate you the features and functionality of the Service; b) to address your questions, issues, concerns; с) to develop new products and features, to improve the Service.

Legal basis of the processing: a) the basis for this processing is to perform the contract that is related to these associated activities and services; b) the processing is necessary for our legitimate interests, communication with users, responding to queries, complaints, concerns; с) the processing is necessary to develop and improve our Service for our legitimate interests, which is necessary for the legitimate interests of our business.

2.Social media

Information received from third parties, such as social networks. If you interact with the Service, we may receive your name, profile information (your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list), and any other information that you permit the social network you share with third parties. Information that we receive depends on your privacy settings on social networks.

How we may use it: a) to promote our Service such as tagging you in comments on our social media pages; b) to define products and services that may be interesting to you for marketing purposes.

Legal basis of the processing: a) The processing is necessary for promotion of our Service, which is necessary for the legitimate interests of our business; b) the processing is necessary informing direct marketing, which is necessary for the legitimate interests of our business.

Please always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Company’s Service.

How we may use it: a) to communicate with users; b) to monitor and improve our Service.

INFORMATION COLLECTED AUTOMATICALLY

When a user visits Company website or mobile application, read our emails or otherwise interact with us we and our partners may automatically collect some information through the use of technology such as cookies, web beacons, log files, embedded scripts or other tracking/record tools. The information that we collect through the use of tracking technologies:

1. Information about how you access and use the Services:

• Website from which you came.

• Website to which you are going when you leave our website.

• How frequently you access the Service.

• Time and how long you use our Service.

• Approximate location from where you access the Service.

• Access the Service from multiple devices.

• Actions that you take in the Service.

How we may use it:

• Remember information, so owners will not have to re-enter it every visit of Service.

• To monitor and improve our Service and business, to resolve issues and inform developers of new products and services.

Legal basis of the processing:

• The processing is necessary for adapting our Service, which is necessary for the legitimate interests of our business.

• The processing is necessary for informing our direct marketing, which is necessary for the legitimate interests of our business.

• The processing is necessary for improving our Service, monitoring and resolving issues related to the Service, which is necessary for the legitimate interests of our business.

We may share your information with:

• Google Inc. for the purposes of analysing information related to the Service crashes.

2. Information of your device

2.1 Log files and information of your device:

Information about your computer, smartphone, tablet and electronic devices that you use in our Service, including:

• Unique ID of your computer, smartphone, tablet and electronic devices that you use in our Service for the purposes to identify your device in a unique way (UDID).

• Device type,

• Operating systems,

• Browser type,

• Mobile carrier,

• Model and manufacturer,

• Your Internet provider (mobile network),

• Mobile device operating system brand and model

• IP addresses,

How we may use it:

• To present our Service to you when you use information or connect with us.

• To monitor and improve our Service and business, to resolve issues and inform developers of new products and services, monitoring of the effectiveness of our Service.

• Monitoring aggregate indicators, such as the total amount of visitors, users, traffic and demographic trends;

• Diagnosis and troubleshooting of technical problems related to the above data (IP address, user ID) and automatically update mobile application on user device.

• Automatically update mobile application on owner device and related devices.

• Analytics. To improve the quality of Service, third-party analytics tools can be used. These tools collect information sent by your mobile device, browser, including visited pages.

Legal basis of the processing:

• The basis for this processing is to perform the contract that is related to these associated activities and services.

• The processing is necessary for adapting our Service, which is necessary for the legitimate interests of our business.

• The processing is necessary for improving our Service, monitoring and resolving issues related to the Service, which is necessary for the legitimate interests of our business.

We may share your information with:

• Google Inc. for the purposes of analysing information related to the Service crashes and due to the performance of interest based advertising.

We can anonymize and aggregate any personal information we collect and it does not identify you directly. We may use anonymous information for purposes that include testing our IT systems, researching, analyzing data, improving our Service, and developing new products and functions. We may also share such anonymous information with others.

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience no matter how you interact with us.

HOW WE STORE AND TRANSFER YOUR INFORMATION

Company will store the personal information that we collect about user for no longer than necessary in paragraph “WHAT INFORMATION DO WE COLLECT?”and “INFORMATION COLLECTED AUTOMATICALLY” for the purposes described there, according to our legal obligations and legitimate business interests.

Company takes care of our users and takes all sorts of technological, administrative, physical, reasonable protective measures aimed at limiting unauthorized access, use or disclosure of personal information of our users. Despite these measures, the user should know that the Company can not completely eliminate the risks related to security and can not guarantee the security of our service 100%. In case of any information under our control is compromised because of security breach, Company will take necessary steps to investigate the situation, the Company will notify users whose information is compromised and will act in accordance with any applicable laws and regulations. Company will never send you unsolicited emails or contact you by phone requesting your credit or debit card information or national identification numbers.

WHO YOUR INFORMATION MIGHT BE SHARED WITH

1. Providers of Service, business partners, advisors. We may share your personal information that may include providing payment, email or chat services, fraud prevention, web hosting, or providing analytic services with third party service providers that perform our Service or on our behalf and vendors.

2. Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to:

• comply with the law and the reasonable requests of law enforcement;

• detect and investigate illegal activities and violation of agreements,

• including our Terms of Service;

• exercise or protect the rights, property, or personal safety of Company, its users or others.

HOW COMPANY PROTECT YOUR INFORMATION

We take care of our users and take all sorts of technological, administrative, physical, reasonable protective measures aimed at limiting unauthorized access, use or disclosure of personal information of our users. Despite these measures, the user should know that no security system is impenetrable and Company cannot guarantee the security of our systems 100%.The user is also responsible for the security of his personal information. To protect personal data, the user should not give the login and password to third parties. In case of any information under our control is compromised because of security breach, Company will take necessary steps to investigate the situation, the Company will notify users whose information is compromised and will act in accordance with any applicable laws and regulations.

WHAT RIGHT DO YOU HAVE?

In accordance with the privacy laws, you have the following rights regarding your personal information that we hold:

Right to request a copy of your information

You have rights as a data subject. There are:

You have the right to request a copy of your personal information provided to us.

Right of access.You have the right to access your personal data that we hold. You can request a copy of the information that we hold (it’s known as a subject access request). We must respond to your request within a month. To request access to your information, please email help@mynorbu.com

Right to correct any mistakes in your information.You can require us to correct any mistakes in your personal data which we had about you where it is inaccurate or incomplete. Please write to us via email help@mynorbu.com so we can put it right. We will respond to you within the time frame specified within the applicable data protection law, which is generally within one month of receipt of the request.

Right to be informed. We must inform you how we’re doing to use your personal information and we do this via our Privacy Statement.

Right to erasure. You have the right to require us to delete your personal information without any delay if the continuation of the processing of personal data is not justified. To request it, please email help@mynorbu.com

Right to restrict processing. You have the right to restrict processing of your personal information in the following circumstances:

• You contest the accuracy of your personal data

• You have objected to our processing of your data, and we are considering your objection because we have said the processing is necessary for the purpose of our legitimate interests.

• Processing is unlawful and you do not wish for the data to be erased but require restricted processing of the data instead.

• We no longer require your personal data but you require the data to establish, exercise or defend a legal claim.

Right to object to the processing of your personal data. You have the right to refuse us the processing of your personal data if our legal basis for data processing is:

• for the purposes of our legitimate interests. If you object to us processing your personal data on these legal grounds, your objection must be based on the basis of your particular situation. Please write to us help@mynorbu.com, we will stop processing personal data if we cannot demonstrate a convincing legal basis for processing that rejects your interests, rights and freedoms or if processing is necessary to carry out or defend lawsuits;

• Direct marketing. If you object to our processing of your personal data for direct marketing purposes, we will stop processing your personal data for this purpose.

• Statistical purposes. If you object to us processing your personal data on this legal basis, your objections should be based on the basis of your particular situation.

Right of portability. You can obtain and reuse your personal data for your own purposes.

YOUR CHOICE ABOUT YOUR INFORMATION

To opt-out or control third-party tracking:

You may opt-out of certain Firebase features through your mobile device settings by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en

We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

You may opt-out of certain AppsFlyer features using this link https://www.appsflyer.com/optout

We also encourage you to review the AppsFlyer’s policy for safeguarding your data and for more information on what type of information AppsFlyer collects, please visit the: https://www.appsflyer.com/services-privacy-policy/

And to review privacy of Amplitude, please visit the Amplitude Privacy Policy or write to Amplitude at privacy@amplitude.com.

You can opt-out of Amplitude data collection by writing to us at help@mynorbu.com.

COMPLAINTS

If you think that we have problems with the processing of your personal data, we recommend that you contact us directly via email help@mynorbu.com to see if you can solve your problems.

You also have the right to lodge a complaint with your national data protection authority. Additional information on how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

CHILDREN’S PRIVACY

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, such as your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete such data without delay. If you believe that we might have any data from or about a child under the age of 13, please contact us.

MEDICAL DISCLAIMER

NORBU IS A PROVIDER OF MEDITATION AND BREATHING TECHNIQUES IN THE WELLNESS. WE ARE NOT A HEALTH CARE OR MEDICAL DEVICE PROVIDER. OUR SERVICE SHOULD NOT BE CONSIDERED AS MEDICAL ADVICE OF ANY KIND, AND IS NOT INTENDED TO TREAT ANY ILLNESS, DISEASE, OR ADVERSE MEDICAL CONDITION OR MANAGE A CHRONIC DISEASE OR CONDITION. ONLY YOUR PHYSICIAN OR OTHER HEALTH CARE PROVIDER CAN DO THAT.

There is a third party evidence from research that meditation can assist prevent a wide range of conditions, improve some of the problems with working capacity, concentration and relationships, Norbu makes no claims or guarantees that the Service provide a therapeutic benefit. Any information provided in the Service is for general informational purposes only. You make a decision regarding the information provided in the Service and take responsibility for your actions.

People with existing mental health conditions should speak with their health care providers before starting a meditation practice.

By using the Service, you expressly agree that use of the Service is at your sole risk. The Service is provided on an “AS IS” and “as available” basis. Company does not warrant that use of the Service will be uninterrupted or error-free. The Company does not warrant the accuracy, integrity or completeness of the content provided on the Service or the products or services offered for sale on the Service.

CHANGES TO OUR PRIVACY STATEMENT

Company may modify or update the Privacy Policy periodically. You should from time to time review this Privacy Policy. When we update Privacy Policy we also update “last modified date” at the bottom of the page. If there are material changes to this Privacy Policy or in how we will use your personal information, the Company will either notify the user in advance by posting a notice or directly sending a notification.

CONTACT US

Regarding privacy policy and any other issues, the user can contact us help@mynorbu.com

COPYRIGHT

The techniques, sequence of steps in the session, breathing methods, graphics, music and texts (content) used in the applications are created and owned by Norbu. Copying, modification of content, commercial use without our permission is not allowed.

Last modified on: 27 April 2021

website: Norbu

Google Play: Norbu Game · Neuron Massage

App Store: Norbu Game · Neuron Massage