Privacy & Policy

Table of Contents

(A Summarized version of connection)

1. What Information We Collect

a. Information You Provide Directly to Us

b. Information that is Passively or Automatically Collected

i. Device/Usage Information

ii. Cookies and Other Electronic Technology

iii. Information Provided By Social Networking Services And Others

2. How We Use Your Information at Elocin

3. Legal Bases For Use Of Your Personal Data

4. No Disclosure to Third Parties for Their Own Marketing Purposes

5. When We Share Your Personal Information With Third Parties

a. Service Providers and agents

b. Affiliates

c. Business transfers

d. Compliance with law and law enforcement requests, and protection of our rights.

e. Consent or At Your Direction

6. Online Analytics And Tailored Advertising

7. Data Subject Rights And Your Choices

8. Retention Of Personal Data And Security

9. Outside The United States Consent To Processing And Transfer Of Information

10. Additional Information

a. Link To Third-Party Websites

b. Blog

c. Referrals and Contacts

d. Social Media Widgets

11. Cross-Border Transfers; EU-U.S. Data Privacy Framework and Swiss-U.S. Data-Privacy Framework

a. Complaints

b. Arbitration

c. Jurisdiction of the Federal Trade Commission

d. Onward Transfers to Third Parties

12. Children

13. California "Do Not Track" Notice

14. Change Policy

15. Contact Information

MindLyft

Last updated: May 15, 2026

MindLyft (“MindLyft “our,” “us,” or “we”) knows your privacy is important to you, and we are committed to providing a safe and secure user experience. This Privacy Policy is incorporated into the MindLyft Terms of Service, and describes the personal information we collect, how we use it, and with whom we share it, including for information collected through the use of (1) MindLyft online at mind-lyft.com, (2) MindLyft online on mobile devices, and (3) any other services that include a link to and/or copy of this Privacy Policy on the home page of the applicable website or similar location (e.g., a settings page) for any applicable mobile applications (collectively, “MindLyft”), which are owned and operated Elocin Ventures, LLC. It describes how we collect, use, secure, and share information of our users and individuals whose payment details are used to purchase MindLyft (collectively, “you” or “your”). It also describes how to access, update, and correct your personal data and the choices available to you regarding your personal data. Under applicable law, Elocin Ventures is the data controller of your personal data.

Before you use or submit any information through or in connection with MindLyft, please carefully review this Privacy Policy. By using any part of MindLyft, you acknowledge that MindLyft may collect, use, and disclose your information as further outlined in this Privacy Policy.

  • What Information We Collect

As described in more detail below, we may collect the following categories of information aboutyou or your use of MindLyft: (1) identifiers (such as name and email address); (2) commercial information (such as transaction data); (3) financial data (such as payment information); (4)internet or other network or device activity (such as browsing history or app usage); (5)geolocation information (e.g. general location inferred from an IP address); (6) sensory information (such as audio or video recordings during research programs or through your use of Figment); (7) professional or employment related data; (8) education data; (9) inference data about you; (10) legally protected classifications (such as gender); (11) medical information (such as information you voluntarily provide to us in a survey); (12) physical characteristics or description; and (13) other information that identifies or can be reasonably associated with you.

  • Information You Provide Directly to Us
 

We may collect information from you in a variety of ways, such as when you:

  • Register for a MindLyft account ("Account");
  • Request certain features (e.g. newsletters);
  • You agree to these Terms of Service on behalf of the Subscribing Entity.
  • Play cognitive training games or engage in other activities that require your information to function (e.g., portions of MindLyft that require an Account to participate)
  • Apply for a job with us
  • Communicate with us; ro
  • Post user-generated content to MindLyft.

You are not required to create an Account to gain access to some areas of MindLyft. If you docreate an Account, we ask for certain information to process your registration, including an email address and password. If you subscribe to a paid Account, we request additional information,including your full name and payment method details

We may also collect (1) name, (2) gender, (3) date of birth, (4) education level, (5) other demographic information, and (6) other information you voluntarily provide to us. Providing most of this information is optional. We also allow you select your preferences for training,language, and receiving email communications

  • Information that is Passively or Automatically Collected
 

In addition to the information you provide directly to us, when you use MindLyft, we automatically collect information about the computer, mobile device, or other devices you use to access MindLyft and about how you use MindLyft. For example, we receive data about the games you play and your performance in those games. We also receive information such as your browser type, IP address, language, the type of device you use, operating system version, unique device identifier (“UDID”), the date and time of your visit and files you viewed on our site (e.g.,HTML pages, graphics, etc.), Internet service provider, clickstream data, the pages you view and the websites you visited immediately before and after visiting MindLyft. In some cases, we link this automatically collected data to other information we collect about you. We do this to improve the services and marketing we offer you

  • Device/Usage Information
 
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access MindLyft. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information (including general location inferred from IP addresses), unique device identifiers, IMEI and TCP/IPaddress, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed MindLyft; and (b) information related to the ways in which you interact with MindLyft, such as: referring and exit web pages and URLs, platform type, the number of clicks,domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of MindLyft, the amount of time spent on particular pages, the date and time you used MindLyft, the frequency of your use of MindLyft, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information
  • Cookies and Other Electronic Technology

Like many other companies, we and third parties that we work with use cookies and other web and mobile tracking technologies, like HTML5, web beacons, scripts, pixels, server logs, and tags. We use these technologies for authentication, to store your preferences or progress, for analytics, and to help us advertise MindLyft. A web server log is a file where website activity isstored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii)understand the web pages of MindLyft you have visited; (iv), enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of MindLyft and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather additional information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari ).You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of MindLyft

 
  • Information Provided By Social Networking Services And Others

We may supplement the information you provide to us with additional information gathered fro mother sources, such as publicly available information, or from third parties, such as marketers,partners, researchers, and others. We may combine information we collect from you with information we obtain from third parties and information derived from any other product or service we provide.

If you sign in to MindLyft using your Facebook or other third-party credentials, we will use that service to authenticate you. We may also receive other information that you have agreed may be provided by that third party, such as your username, name, e-mail address, photo, location, date of birth, gender, an ID associated with the applicable third party platform, user files like photos and videos, your list of friends, people you follow and/or who follow you, and/or your posts or”likes”. We receive this information so that it can be used for the purposes explained in this Privacy Policy. If you do not wish to have this information shared by these third parties, do not use Facebook or another third party to access MindLyft. We may also collect other information through other social networks that you make available to us. For a description on how social networking and other third-party sites handle and share your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. We may combine information that we collect from or about you with information about you that we obtain from such social media and other content platforms and information derived from any other subscription, product, or service we provide.

If you are a subject in a research project or study conducted by Elocin in partnership with are searcher or educational institution, that project may involve the collection of different information than is described in this Section. Research participants may, for example, provide health-related information, including the existence of certain health conditions. Elocin partners with researchers and educational institutions in conducting such studies. Such research projects are typically done on an anonymous basis, such that Elocin acts only as a processor of anonymized or pseudononymized data. For further information on how we handle data associated with such research, please refer to the materials distributed to you as part of the study,contact the researcher leading your study, or contact us using the contact information below
 
  • How We Use Your Information at Elocin

We use the categories of information identified above to operate and provide you with MindLyft and other services. This includes, but is not limited to the following business and commercial purposes:

  • For the purposes for which you provided it;
  • Authenticating your login and processing your payments;
  • Personalizing your MindLyft experience and customizing your training program
  • Allowing you to monitor your performance and progress in MindLyft, by, for example,presenting charts and graphs of your performance to you;
  • Customizing and delivering information about our products and services by email;
  • To contact you with information, surveys, or advertising that we believe may be of interest to you regarding us or MindLyft;
  • Providing customer support and sending confirmations about your Account;
  • For internal research and reporting;
  • Protecting our intellectual property or other rights; and
  • Managing and improving our business, our games, and our training.
  • Legal Bases For Use Of Your Personal Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on
to use or disclose your personal data. To the extent those laws apply, our legal grounds are as
follows:

  • To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them. For example, we handle personal data on this basis for our premium users.
  • Consent: Where required by law, and in some other cases, we handle personal data based on your implied or express consent. Where you have provided consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing that was carried out before withdrawing your consent. To withdraw your consent, please contact us at legal@mind-lyft.com.
  • Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as:
  • Providing a safe and enjoyable user experience;
  • Customer service;
  • Marketing;
  • Protecting our users, personnel, and property;
  • Analyzing and improving our business;
  • Processing job applications; and
  • Managing legal issues.
  • We may also process personal data for the legitimate interests of our research partners, such as to provide cognitive training, research, and analytics for such partners.
  • Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
  • To protect the vital interests of the individual or others: For example, we may collect or share personal data to help resolve an urgent safety situation
  • No Disclosure to Third Parties for Their Own Marketing Purposes

We believe in protecting your privacy and therefore do not provide your personal data to third parties for their own marketing purposes

  • When We Share Your Personal Information With Third Parties

We may share the categories of personal information identified in Section 1 for business purposes (as defined by applicable law) or as required by applicable law. More specifically, we may share your personal information in the following situations:

  • Service Providers and agents

We may share your information with certain third parties selected by us to help support our operations. These include, for example, services that help us process payments, analyze web traffic, send emails, and track customer support requests. In addition, we may share limited personal data with third parties that help us market or advertise MindLyft. These third parties may have access to your information only for purposes of performing these tasks on our behalf, and we contractually require them to protect your information consistent with this Privacy Policy.

  • Affiliates

We may share your information with our corporate affiliates, such as entities under common ownership or control.

  • Business transfers

We may sell, transfer, or otherwise share some or all of our assets in connection with an actual or
contemplated merger, reorganization, business transaction, or in the event of bankruptcy. In such
scenarios, your information may be one of the assets transferred. We will post a notice or
otherwise notify you and collect your consent, as may be required by law, before the information
is transferred and becomes subject to a different privacy policy.

  • Compliance with law and law enforcement requests, and protection of our rights.

We may disclose your information when we have a good faith belief we are required to do so by
law, or in response to a subpoena, court order, or other legal mechanism. We may also disclose
your information when we have a good faith belief that disclosure may prevent fraud and abuse
of MindLyft or its users or protect our property rights

  • Consent or At Your Direction

We may disclose your information when we believe we have your consent to do so, such as when you contact customer support and ask us about your Account, or when we have the consent of someone we believe is authorized to consent on behalf of you, such as the individual associated with the payment method for your Account, or where you share user-generated content with other MindLyft users or publicly. If you have expressly agreed to participate in a research study with us or with a third party that incorporates your personal data collected by MindLyft, we also may disclose your information for the purpose of facilitating the research to which you have consented.

  • Online Analytics And Tailored Advertising

We may use third-party web analytics services on MindLyft, such as those of Google Analytics, Rollbar, and New Relic. These service providers use the sort of technology previously described in the “Cookies and other electronic technologies” section to help us analyze how users use MindLyft, including by noting the third-party website from which you arrive, how often you use our app, the events that occur within our app, where the app was downloaded from, and provide certain features to you. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of MindLyft. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here If you receive an email from us, we may use certain tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications. We may personalize the content and advertising that you see when using MindLyft by using third-party advertising technologies that allow for the delivery of relevant content and advertising on our websites, as well as other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you provide such as your age and gender, your searches, demographic data, user- generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and may be tailored to your interests. Also, third parties whose products or services are accessible or advertised via MindLyft may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of MindLyft to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of MindLyft. We also may allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick, and others) to serve tailored ads to you on MindLyft, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access MindLyft.  We also may share with third-party advertisers a hashed version of your email address, solely in a non-human-readable form for purposes of delivering tailored advertising. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access MindLyft by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into MindLyft, you may still receive advertisements even if you opt out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

  • Data Subject Rights And Your Choices
  • Account Review

You may access, review, correct, and delete certain of your personal data by logging into your Account.

  • Analytics and Advertising

You also can exercise certain opt-out rights by following the instructions at the end of the
“Online Analytics and Tailored Advertising” section above.

  • Your Legal Rights

In addition, individuals in the European Union and some other jurisdictions outside the United
States have certain legal rights to request that we:

  • confirm whether we hold personal data about them
  • provide access to personal data we hold about them (including, in some cases, in portable form),
  • update, amend, and/or correct personal data we hold;
  • delete certain personal data in appropriate circumstances;
  • transfer personal data to a third-party provider of services;

To exercise any of the above rights (or any other rights under applicable law), please contact us via our help center.

In addition, individuals in the European Union and some other jurisdictions outside the United States have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances. They may also object to our uses or disclosures of personal data or exercise legal rights to withdraw consent, though such actions typically will not have retroactive effect. To exercise any of the above rights (or any other rights under applicable law), please contact us via our help center.

The rights described herein are subject to limitations and exceptions under applicable law. In
situations in which we process personal data on behalf of our research partners, we may refer the
request to the relevant research partner and cooperate with their handling of the request, subject to any special contractual arrangement with that research partner.

In addition to the rights above, residents of the European Economic Area also have the right to
lodge a complaint with your relevant supervisory authority. However, we encourage you to
contact us first, and we will do our very best to resolve your concern.

 

  • Marketing

You can opt out of receiving marketing emails by navigating to your Email Notifications page or
by following the unsubscribe instructions included in each email. Please note you may not opt
out of certain transactional emails, such as when we email you to confirm transactions, address
Account issues, or communicate about customer support.

  • Push Notifications

From time to time, we use push notifications in our mobile applications to send you messages
about MindLyft or your Account. You may opt out from receiving push notifications through
your device settings.

  • California Rights

California residents have certain rights, subject to exceptions. California law may permit you to
request that we:

  • Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
  • Provide access to and/or a copy of certain information we hold about you.
  • Delete certain information we have about you.

You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our services to you. If you ask us to delete it, you may no longer be able to access or use MindLyft

You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

If you would like to exercise any of these rights, please submit a request via our help center. We will take reasonable steps to verify your identity.

The CCPA requires us to disclose the categories of “third parties” (as defined by the CCPA) to
whom personal information was disclosed or sold. In the preceding 12 months, we may have disclosed user-generated content, such as when you share user-generated content with other MindLyft users or publicly. If you have expressly agreed to participate in a research study with us or with a third party that incorporates your personal data collected by MindLyft, we also may have disclosed your information for the purpose of facilitating the research to which you have consented. Please review the section above on “When We Share Your Personal Information With Third Parties” for more details on how MindLyft generally shares information collected.

California residents may opt out of the “sale” of their personal information. MindLyft does not
“sell” your personal information as we understand that term to be defined by the California
Consumer Privacy Act and its implementing regulations.

  • Nevada Rights

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable
information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law via our via our help center. Please note that we will take reasonable steps to verify your identity and
the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

  • Retention Of Personal Data And Security

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it, and/or as required to comply with applicable laws. To dispose of personal data, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for an additional time.

We have implemented and maintain security practices to protect against the unauthorized access, use, modification, destruction, or disclosure of your personal data. For example, when you enter sensitive information on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it.However, no method of transmission or storage is completely secure, and we therefore cannot guarantee absolute security. If you have any questions about security on our website, please contact us using the contact information below.

  • Outside The United States Consent To Processing And Transfer Of Information

If you access MindLyft outside of the United States, you fully understand and unambiguously
consent to the transfer of your personal data to, and the collection and processing of such personal data in the United States. The recipients of the personal data disclosures described in the “When We Share Your Personal Data with Third Parties” section above may be in the United States or elsewhere in the world. Privacy laws in these countries may not provide protections equivalent to those of your country of residence, and your government may or may not deem such protections adequate.

  • Additional Information
  • Link To Third Party Websites

Our website includes links to other sites that may collect personal data, and whose privacy practices may differ from those of Elocin. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to review their privacy policies

  • Blog

Our website offers publicly accessible blogs. Some blog posts allow comments via Facebook. You may need to log in or contact Facebook to post comments and to delete personal data that was previously posted in the comments. You can review Facebook’s privacy policy here.

  • Referrals And Contacts

We allow you to refer your friends and contacts to MindLyft, either by manually entering their email addresses or by importing contacts from email accounts you have with third parties. If you choose to utilize these features, we’ll use and store the email addresses only for the purposes of sending the invitation emails you have requested. If you utilize these features, the friends or contacts that you refer may contact us at the contact information listed below to request that we delete their personal data. Please note that we do not collect the username and password to your email accounts; the import features route you to the third-party email provider to log in through their services.

  • Social Media Widgets

Our website may include social media features, such as Facebook and Twitter buttons. Such features may collect your IP address and information about the page you are visiting and may set cookies to function properly. Your interactions with these features are governed by the privacy policies of the company providing them.

  • Cross-Border Transfers; EU-U.S. Data Privacy Framework and Swiss-U.S. Data-Privacy Framework

On 10 July 2023, the European Commission’s adequacy decision for the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) entered into force, followed by the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) on 17 July 2023 and the UK extension to the EU-U.S. DPF on 12 October 2023.

Elocin complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data PrivacyFramework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Elocin has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) about the processing of personal data received from the European Union and the
United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Elocin has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data
Privacy Framework Principles (Swiss-U.S. DPF Principles) about the processing of personal data
received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov.

To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov

Our certification may be located here (look under ‘Data Privacy Framework List’).

With respect to personal data received or transferred pursuant to the EU-U.S. DPF, Elocin is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Elocin may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  • Complaints

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Elocin commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.
If you do not receive timely acknowledgment of your DPF Principles-related complaint from us,or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/submit for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

  • Arbitration

You may, under certain conditions, invoke binding arbitration for complaints regarding DPF compliance, which may not be resolved by any of the other DPF mechanisms. Further information regarding this option may be found at Annex I to the DPF Principles, located here.

  • Jurisdiction of the Federal Trade Commission

The Federal Trade Commission has jurisdiction over Elocin’ compliance with the EU-U.S. DPF
and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Elocin may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

  • Onward Transfers to Third Parties

We remain responsible for all the personal information we receive under the DPF and that we subsequently transfer to third parties acting as agents on our behalf if they process personal information in a manner inconsistent with the DPF principles, unless we prove we are not responsible for the event giving rise to the damage.

  • Children

MindLyft is not directed to individuals under 13 years old. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13, children under the age of 14 in Spain or South Korea, or from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as required by law. As appropriate under applicable law, parents or legal guardians with questions or requests regarding their children’s personal data may contact us as described below.

  • California "Do Not Track" Notice

We do not track our customers’ personal data over time and across third-party websites to provide targeted advertising and therefore do not respond to “Do Not Track” (DNT) signals.

  • Change Policy

This Privacy Policy may be updated from time to time. If we make material changes, we will provide notice to you either by email, by posting notification on MindLyft, or by posting an updated privacy policy on MindLyft 45 days in advance of the effective date of the updated Privacy Policy. Please note that, for existing users, unless otherwise provided by applicable law,your continued use of MindLyft following the effective date means that you agree with, and consent to be bound by, the updated Privacy Policy.

  • Contact Information

We welcome inquiries or comments about our Privacy Policy via our help center.