Privacy Policy

App: Better Mind
Last updated: December 3, 2025

This Privacy Policy describes how the mobile application Better Mind (“the app”) processes information related to its users. The app is designed in line with the principles of the EU General Data Protection Regulation (GDPR) and similar data protection laws in other jurisdictions.

The app is intended for users who are at least 16 years old. The app does not include third‑party ads or ad tracking.

Disclaimer – Not Medical Advice

Better Mind is designed to inspire, motivate, and support your general wellbeing and mood. It is not a medical or mental health app, and it does not provide professional diagnosis, treatment, or therapy. The app is not a substitute for medical advice from a doctor, psychologist, or other qualified health professional. If you have concerns about your mental health or wellbeing, you should always seek help from a qualified professional or local emergency services.

1. Data Controller

In this Privacy Policy, “we”, “us” and “our” refer to the data controller:

Name: Jarno Tossavainen
Business ID: 3567327-2
Country: Finland
Email: jarnotossavainenapps@gmail.com

2. Data Subjects

This Privacy Policy applies to users who install and use the Better Mind app. The app can be used anonymously without creating an account.

3. Data We Process and Sources of Data

3.1 Personal Data and Other Information

The Better Mind app does not collect or store the following information:

• Name, email address or username
• Passwords or other login credentials
• Profile information (such as age group or preferences)
• Location data (precise or approximate)
• Push notification tokens
• Journal entries, notes or similar content in any service
• Analytics data about how you use the app (for example, screen views or button clicks) tied to your identity

The app does not require you to create a user account and does not send personally identifiable information about you to our own backend or cloud services.

Content created within the app (for example, any entries or settings) is stored only on your own device. This local data is permanently deleted when you uninstall the app or clear the app’s data from your device. We do not have access to this local data.

3.2 Payment-Related Information

Better Mind offers paid features (for example, subscriptions or one-time purchases). Payments and purchase validation are handled by the following third‑party services:

• Google Play Billing (Google LLC)
• Apple Pay / App Store (Apple Inc.)
• RevenueCat, Inc.

Actual payment information (such as credit or debit card numbers) is processed by Google, Apple and/or RevenueCat in accordance with their own terms and privacy policies. We do not store or have access to your full payment card details.

We may receive from these providers certain technical information about your purchases, such as:

• Product or subscription type (for example, product ID)
• Subscription status (active / expired)
• Technical identifiers that allow us to link purchases to a device or anonymous user identifier

We use this information only to:

• verify that your purchase or subscription is valid; and
• enable the corresponding premium features in the app.

We do not use this information for direct marketing or profiling.

4. Purposes and Legal Bases for Processing

The processing of personal data in connection with Better Mind is very limited and mainly concerns the technical handling of purchases via third‑party providers.

We process data for the following purposes:

• To provide and operate the Better Mind app
• To technically enable and validate in-app purchases and subscriptions (via Google Play Billing, Apple Pay / App Store and RevenueCat)
• To troubleshoot technical issues and prevent misuse or fraud

Under GDPR, the main legal bases for processing are:

• Performance of a contract (Article 6(1)(b) GDPR): to provide access to premium content and functionality that you purchase.
• Legal obligations (Article 6(1)(c) GDPR): some purchase-related data may be retained by third‑party providers (such as Google or Apple) to comply with accounting or other statutory requirements.
• Legitimate interests (Article 6(1)(f) GDPR): ensuring the proper operation of the app, preventing misuse and resolving technical issues.

If your local law provides other or additional legal grounds, we rely on those to the extent they apply.

5. Data Retention

Because we do not store your personal data in our own systems, retention mainly concerns:

1. Local data on your device
   Content and settings within the Better Mind app are stored only on your device. This data is deleted when you uninstall the app or clear the app’s data from your device. We have no access to this data.
2. Purchase and subscription information at Google, Apple and RevenueCat
   These providers may retain information in accordance with their own terms and applicable laws (for example, for accounting or fraud prevention). We only access the information necessary to verify your entitlement to use premium features (for example, whether your subscription is active).

6. Sources of Data

Data we process is obtained from:

• Your own device (local app data, which we do not see)
• Google Play Billing, Apple Pay / App Store and RevenueCat (technical purchase and subscription information)

We do not obtain personal data about you from data brokers or for marketing/profiling purposes.

7. Data Sharing, “Sale” and Targeted Advertising

We do not sell your personal information. We do not sell your personal information or share it with third parties for cross-context behavioral advertising or targeted advertising.

We do not share your personal information with third parties for their own marketing purposes.

Data may be processed by the following service providers to the extent necessary for the operation of Better Mind and for handling purchases:

• Google Play (Google LLC) – app distribution and purchases on Android devices
• Apple (Apple Inc.) / Apple Pay / App Store – purchases on Apple devices
• RevenueCat, Inc. – subscription management and receipt validation

We may also disclose data if required by law, regulation, or a valid legal request from a competent authority.

8. International Data Transfers

Google, Apple and RevenueCat may process data in countries outside the European Union (EU) and the European Economic Area (EEA), including the United States.

When such transfers occur, we and our service providers rely on appropriate legal safeguards such as:

• standard contractual clauses approved by the European Commission, and/or
• other safeguards required by applicable data protection laws.

For more details, please refer to each provider’s own privacy documentation:

• Google Play / Google LLC – see Google’s Privacy Policy
• Apple / Apple Pay / App Store – see Apple’s Privacy Policy
• RevenueCat, Inc. – see RevenueCat’s Privacy Policy

9. Your Rights

Better Mind app does not collect or store any personal data to servers or cloud. Users data is stored only on users device.

• The right to be informed about how your data is processed
• The right to access your personal data
• The right to have inaccurate or incomplete data corrected
• The right to request deletion of your data (“right to be forgotten”)
• The right to restrict processing in certain circumstances
• The right to object to processing based on legitimate interests
• The right to data portability, where applicable
• The right to withdraw consent if processing is based on your consent

If you are a resident of California or another U.S. state with specific privacy laws, you may have additional rights regarding your personal information. Because Better Mind does not create user accounts or store personal data on our own servers, many of these rights are limited in practice, but you can still contact us and we will review your request in line with applicable law.

Because our direct processing of personal data is very limited and much of the relevant data is held by Google, Apple or RevenueCat, we will assess each request on a case‑by‑case basis and may direct you to contact the relevant provider when appropriate.

If you wish to exercise your rights or have questions about your privacy, please contact us using the details in section 13.

You may also have the right to lodge a complaint with a data protection authority or other supervisory authority in your country or region if you believe that your rights have been violated.

10. Cookies and Similar Technologies

Better Mind does not use browser cookies within the app, but it may rely on technical identifiers provided by your device and the app stores (for example, identifiers used by Google Play or Apple for purchase validation and technical operation).

The app does not include third‑party ads or third‑party ad tracking.

11. Data Security

We and our service providers use appropriate technical and organizational measures to protect information in connection with the Better Mind app, including:

• Secure connections (for example, HTTPS)
• Access controls and permissions
• Platform-level and server-level security safeguards

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time if the Better Mind app or applicable laws change. When we make material changes, we will notify you in the app or through another appropriate channel where feasible.

The “Last updated” date at the top shows when this Privacy Policy was last revised.

13. Contact Us

If you have any questions, requests or concerns about this Privacy Policy or our data practices, you can contact us at:

Email: jarnotossavainenapps@gmail.com

This Privacy Policy is intended to be transparent and easy to understand. It does not replace any mandatory consumer rights or protections that apply under the laws of your country or state.