“We”, “us” or “our” means DAILY MEDITATION Growth Limited. We are a company registered in England and Wales with company number 12254320. Our registered address is at: 20-22 Wenlock Road, London, England, N1 7GU. More information about us and our business is available on our website:  https://love-yourself.tk/dev/ . We are the provider of the DAILY MEDITATION  Application (the “ App ”) and the mediation services provided through the App (our “ Services ”). We are registered with the Information Commissions Office in the UK with reference number ZA854929.

We collect, use and are responsible for certain personal data about you. Our processing of your personal data is subject to the UK General Data Protection Regulation (UK GDPR). Where you are based in Europe, we are also subject to the EU General Data Protection Regulation (EU GDPR) as the App and our Services are available to citizens based in the EU, as well as the UK.

1.  PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that individual can be identified.

This Privacy Notice applies to personal data we collect about you when register for an account on our App, use our App and Services (including purchasing our Premium Services), provide us with feedback, request customer support, or otherwise contact us.

We may collect and process the following personal data about you:

. Identity data:  your name;

. Contact data:  you email address used to register with the App;

. Profile data:  the information you use to registered with the App and create an account, including your username and password;

. Financial data : your payment information used to purchase our Premium Services. We do not collect or process credit or debit card (“Payment Card”) data. The applicable App Store (e.g. Apple’s App Store or GooglePlay Store), collect Payment Card data for purchases of our Premium Services made through the App. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored, and your card’s type, expiration date, billing address, and the last four digits of your card number. How such third parties handle your personal data is governed by their individual privacy notices;

. Technical data : information about how you use and interact with the App and our Services. We use mobile analytics technology to allow us to better understand the functionality of our App on your device. This may record information such as how often you use the Services, how you engage with the pages of the App, aggregated usage and performance data, and where the App was downloaded from. We may link the data we store within our analytics tools to any personal data you submit within the App itself. Please be aware that you are able to login to the App from multiple devices and your account information will be access from any device that is used to login. We will also collect technical data from each device that accesses the App.

. Marketing and communications data:  this includes your preferences in receiving marketing communications from us and our third parties and your preferences about how we communicate with you for these purposes;

Any other information about you which you provide to us when you communicate with us feedback and survey responses.

We collect and use this personal data to provide you with access to our App and to provide our Services. If you do not provide personal data we ask for, it may delay or prevent us from creating your account or being able to provide our Services.

2. HOW YOUR PERSONAL DATA IS COLLECTED

We collect most of your personal data directly from you when your sign-up and use the App. However, we may also collect information from your use of the App through tracking pixels which monitor how you interact and use the App and our Services, such as what pages your visit, what times of the day you use our Services, how long you use the App during each session (etc).

3. HOW AND WHY WE USE YOUR PERSONAL DATA

We must have a legal basis for processing your personal data. We consider that we have a legal basis where:

. you have given us consent to do so for the specific purposes which we have told you about;

. performance of a contract with you – i.e. it is necessary for us to do so to enable us to provide you with our Services that you have requested from us by registering with the App;

. to pursue our legitimate interests – a legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own .Our legitimate interests include things such as providing our Services, improving the services we offer and developing new services, including new or different features and functionality for the App;

. to comply with our legal obligations; or

. the law otherwise permits or requires it.

We have set out below a list of all the ways we may use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Where we process special category personal data, we will also ensure we are permitted to do so  under data protection laws, e.g.:

• we have your explicit consent;

• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or

• the processing is necessary to establish, exercise or defend legal claims.

4. MARKETING

We can only use your personal information to send you marketing messages if we either have your consent or a ‘legitimate interest’. A ‘legitimate interest’ is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

The personal data we have for you is made up of: what you tell us and the data we collect about you when you use our services; or data provided to us from third parties we work with. We consider your information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

We want to ensure that you are informed and aware of the latest features, services, promotions and events that we can offer you. As detailed in the table above, we may send you communications such as those which relate to any Service or App updates or request feedback from you about your user experience of the App. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.

In addition, from time to time we may want to send you additional communications either directly from us or from our named third parties. This includes sending you push notifications through the App. If we decide to do this, we will ask for your consent and clearly set out the purposes for which we’re relying on that consent.

By consenting to receive additional communications (by app push notifications or email) from us and any named third parties that feature at the point of obtaining consent in respect of such information, we will process your personal data in accordance with this Privacy Notice. If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by [changing the settings in your App  OR  on your device] or contacting us at  info@love-yourself.tk .

If you choose not to receive this information, we will be unable to keep you informed of new services and promotions that may interest you.

We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We share information about you as follows and as otherwise described in this Privacy Notice:

•   with companies and contractors that perform services for us or enable us to operate our App – e.g. email service providers; payment processors, android and Apple app stores and other service providers;

• other third parties we use to help us run our business, (e.g. marketing agencies or cloud hosting providers) including our subscription management services operated by RevenueCat;

• in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including court order, subpoena, or other lawful requests by public authorities to meet national security or law enforcement requirements;

• with your consent or at your direction – e.g. you may choose to share actions you take on our Services with third-party social media services via the integrated tools we provide via our Services;

• share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

We also have to share information or data in order to meet any applicable law, regulation, legal process or enforceable governmental request.

We may also share anonymised, aggregated data with third parties for research purposes – this is not considered to be personal data as it cannot identity you as an individual.

6. HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will keep your personal data while you have an account with us or we are providing our Services to you. Thereafter, we will keep your personal data for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;

• to show that we treated you fairly;

• to keep records required by law.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.

7. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA

To deliver provide you with access to the App and deliver Services to you, it is sometimes necessary for us to share your personal data outside the UK and EEA, e.g.:

• with your and our service providers located outside the UK/EEA; and/or

• if you are based outside the UK/EEA.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK and EEA where:

• the UK government or, where the EU GDPR applies, the European Commission, has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);

• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses; or

• a specific exception applies under data protection law – this may be where: 1) you have explicitly consented to the proposed transfer after having been informed of the possible risks; 2) the transfer is necessary for our performance of a contract with you; 3) the transfer is necessary for a contract in your interests, between us and another person; or 4) the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

8. YOUR RIGHTS

You have the following rights, which you can exercise free of charge:

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘ How to contact us ’ below) or see the  Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights .

9. KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. CHILDREN

Our products and services are not directed to persons under the age of 13 and should not be used by any person under the age of 13. If you become aware that your child has provided us with personal information without your consent, please contact us indicated under “How to Contact Us” below. If we become aware that a person under 13 has registered to use our products or services, we take steps to terminate that person’s account and usage rights.

10. HOW TO COMPLAIN

Please contact us if you have any query or concern about our use of your information (see below ‘ How to contact us ’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at  https://love-yourself.tk/dev/  or telephone: 0777120457.

10. CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice from time to time—when we do we will inform you via a notification through the App or by email to the email address used to create an account.

10. HOW TO CONTACT US

1. 1. Individuals in the UK or the United States

You can contact us by post or email if you have any questions about this Privacy Notice or the information we hold about you, to exercise a right under data protection law or to make a complaint, using the following details:

• Email :  info@love-yourself.tk

• Post : 20-22 Wenlock Road, London, England, N1 7GU

10. INDIVIDUALS IN THE EEA – OUR EU REP

We have appointed   Thomas Galea  to  be our data protection representative within the EEA. Their contact details are  email:  info@love-yourself.tk.

 Individuals within the EEA can contact us directly (see above) or contact our European representative.