Privacy Policy

We need to remind you that in order to use the service, we will try to ask you to enter information about your video learning preferences, age, gender, email, etc. We also automatically collect language settings, IP addresses, location information (coarse or precise), time zone, device type and model, device settings, operating system, Internet service provider, mobile operator, hardware ID and other unique identifiers (such as IDFA) from your device. We need this data to provide our services and analyze how our customers use the services.

This policy describes how MindUp (“MindUp”, “we”) collects, receives, processes, uses, discloses, or shares your information. When you use our website, products, or services or otherwise establish a relationship with us, we may obtain data from you and the devices you use to do so.

This policy aims to transparently display our privacy practices and principles in a format that you can easily browse, read, and understand.

We promise to treat your Personal Data with caution and respect. If you have any questions or concerns about the use of your information, we encourage you to contact us using the methods provided below.

Scope of this policy

This policy describes how we handle the Personal Data we provide or collect on our website, applications, products, or services. In some cases, we may provide additional data privacy statements for certain products, practices, or regions. These terms should be read in conjunction with this policy.

If you provide information to us on a third-party website or platform, the information you provide may be collected separately by the third-party website or platform. The privacy practices of this third-party website or platform will govern the use of your information. The choices you make on this third-party platform do not apply to our use of information collected through our website, products, or services.

We acknowledge that we have an obligation to all recipients of our products and services, including visitors to our website, registered users, and administrators who use our products and services on behalf of our customers. We have an obligation to collect, manage, process, and use their Personal Data (“Personal Data”) in accordance with the laws and regulations of each country in which we operate.

By using the service, you guarantee to us that: (I) you have read, understood, and agreed to this Privacy Policy; (II) You are over 18 years old (or your parents or guardians have read and agreed to this Privacy Policy for you). If you do not agree or are unable to make this commitment, you may not use the service. In this case, you must (a) use the function in the “Settings” of the application or website to delete your account, or contact us and request the deletion of your data; (b) Cancel any subscription based on your subscription method (if you subscribe through the App Store, use the features provided by Apple; if you purchase a subscription through the website, use the features of our website); And (c) remove the application from your device.

“GDPR” refers to the General Data Protection Regulation (EU) 2016/679, issued by the European Parliament and the Council on April 27, 2016, concerning the protection of natural persons in the processing of Personal Data and the free flow of such data.

“Process” in respect of Personal Data, includes collection, storage, and disclosure to others.

Table of contents

1. Categories of Personal Data We Collect

2. The Purpose of Our Processing of Personal Data

3. How We Share Your Personal Data

4. How to Exercise Your Privacy Rights

5. Protection of the Personal Data of Minors

6. International Data Transmission

7. Changes to this Privacy Policy

8. Supplementary Notice for California Residents

9. Supplementary Notice for Virginia Residents

10. Supplementary Notice for Nevada Residents

11. Account Deletion

12. Data Retention

13. How to Handle "Do Not Track" Requests

14. Personal Data Controller

15. Contact Us

1. Categories of Personal Data We Collect

We collect data that you voluntarily provide (e.g. when you enter video learning preferences, age, email). We may also receive data about you from third parties (such as when you log in through your APPLE account). We will also automatically collect data (such as your IP address, activity logs) and use third-party service providers for such collection.

1.1 The data you provide to us

When you register and/or use the service, you will provide us with information about yourself. For example, video learning preferences, age, email address.

1.2 Third party data provided to us

When you register an account in the app using “Sign in Through Apple”, we will obtain Personal Data from your Apple ID account. These data may specifically include your name and verified email address. You can choose to share your real email address or use an anonymous email address with a private email relay service. Apple will display its detailed privacy information to you on the “Sign in tThrough Apple” screen. Apple allows you to revoke access to the app in your Apple ID settings by following these steps.

1.3 Data we automatically collect

a. Data about how you found us

We collect data about your referral application or URL (i.e. the application or network location where you click on our advertisement).

b. Equipment and location data

We collect data from your device. Examples of such data include: language settings, IP addresses, time zones, device types and models, device settings, operating systems and their versions, Internet service providers, mobile operators, hardware IDs, etc.

c. Using data

We will record the way you interact with our services. For example, we will record your clicks/clicks in specific areas of the interface, the features and content you interact with, the frequency of your use of the service, and the time you spend on the service. We will also track your account usage and subscription duration, your subscription orders, whether you currently have advanced access, whether you have accessed trial content, your total expenses and refund activities on our platform.

d. Advertising ID

We will collect your Apple Advertising Identifier (“IDFA”) (depending on the operating system of your device). You can usually reset these numbers through the settings of the device operating system (but we cannot control this).

e. Transaction data

When you make a payment through the service, you need to provide financial account data to our third-party service provider, and we may receive data about the transaction, including the date, time, and amount of the transaction, as well as the type of payment method used.

f. Cookie

Cookies are small text files stored on a user's computer for recording and saving. Cookies can be session cookies or persistent cookies. Session cookies expire when you close your browser and are used to make it easier for you to browse our services. Persistent cookies will remain on your hard drive for a longer period of time. We also use tracking pixels to set cookies to assist in delivering online advertisements.

Cookies are mainly used to automatically recognize you the next time you visit our website. Therefore, the information you previously entered in certain fields on the website may automatically appear the next time you use our services. Cookie data will be stored on your device and in most cases only for a limited period of time.

2. The Purpose of Our Processing of Personal Data

We process your Personal Data:

2.1 To provide our services

This includes enabling you to seamlessly use the service and preventing or resolving service errors or technical issues.

2.2 To customize your experience

We process your Personal Data (such as video learning preferences) to adjust service content and provide customized services based on your personal preferences. After such processing, we will display more videos in the application.

2.3 To manage your account

We process your Personal Data to protect the security of the personal account you access, and send you technical notices or emails regarding the performance of our services, security, payment transactions, notifications about our terms and conditions of use or this Privacy Policy.

2.4 To regarding your use of our services to communicate with you

We communicate with you through email. These may include motivational messages that remind and encourage you to continue learning, or other information about the service.

2.5 To provide customer support for you

We process your Personal Data in response to your technical support request.

2.6 To research and analyze your usage of the service

This helps us better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop services and new products.

2.7 To process your payment and refund

We offer paid products and/or services in our services. For this purpose, we use third-party services for payment processing. After this processing, you will be able to pay the subscription fee and we will receive a notification that the payment has been completed.

We will not store or collect your payment card details on our own. This information will be directly provided to our third-party payment processors.

We will process your Personal Data in accordance with our Terms and Conditions of Use to process your refund request. Please note that if you request a refund for a subscription purchased through the app store, we may share your usage data and other information about your activities on our services with them. The sole purpose of such processing is to promote transparent and fair verification and processing of your refund request by the relevant app store.

2.8 To implement our terms and conditions of use and prevent and combat fraud

We use Personal Data to enforce our agreements and contractual commitments to detect, prevent, and combat fraudulent behavior. In the process of such processing, we may share your information with others (including law enforcement agencies) (especially in case of disputes arising from our Terms and Conditions of Use).

2.9 To compliance with legal obligations

When required by law, we may process, use, or share your data, especially when law enforcement agencies request your data through available legal means.

3. How We Share Your Personal Data

In the process of providing services to you, we may disclose your Personal Data to our subsidiaries and affiliates, as well as our service providers and other third parties. We will carefully choose our service providers and business partners, especially considering the applicability of the technology and organizational measures they adopt. In each case, we will take all reasonable measures to ensure that your Personal Data is protected (such as appropriate data processing protocols).

We may also disclose your Personal Data to service providers and third parties in the following situations: compliance with laws and regulations; Responding to subpoenas and court orders; Exercise our legal rights or defend against legal claims; Investigate, prevent or take action against illegal activities, suspected fraud, potential threats to our property or the personal safety of any person, or violations of our instructions and applicable terms and conditions of use; Facilitating the financing, insurance, or disposal of all or part of our business or assets for our business, or other situations permitted or required by law. We may disclose anonymous or aggregated data at our discretion in accordance with applicable laws.

4. How to Exercise Your Privacy Rights

In order to control your Personal Data, you have the following rights:

Access/review/update/correct your Personal Data. You can review, edit, or modify the Personal Data you previously provided in the service.

Delete your Personal Data. You can request the deletion of your Personal Data in accordance with the law.

When you request the deletion of your Personal Data, we will make reasonable efforts to meet your request. In some cases, we may be required by law to retain some data for a period of time; In this case, we will meet your requirements after fulfilling our obligations.

Oppose or restrict the use of your Personal Data. You can request us to stop using all or part of your Personal Data, or limit our use of it, which may affect the services we provide to you.

To exercise any of your privacy rights, please send a request to mindup@readio.io

Our service is not applicable to children under the age of 18. We will not intentionally collect information from users under the age of 118 through our website, products, and services. If you use our services, it means that you are at least the age of majority required by the laws of your place of residence, or as a minor, you are at least 18 years old and your legal representative has agreed to use our services.

If you believe that your child has provided us with Personal Data, please remind us through mindup@readio.io. If we become aware that we have collected Personal Data of a minor without the consent of their legal representative, we will immediately take appropriate measures to delete such information and terminate the minor's account.

6. International Data Transmission

We conduct business globally. We may transfer Personal Data to countries/regions outside the country/region where the data was originally collected, in order to provide the services specified in the terms and conditions of use and for the purposes indicated in this Privacy Policy. If the data protection laws of these countries/regions are different from the country/region where you initially provided the information, we will deploy special protection measures.

Specifically, if we transfer Personal Data originating from the European Economic Area to countries with insufficient levels of data protection, we will use one of the following legal grounds: (i) standard contractual clauses approved by the European Commission, or (ii) adequacy decisions of the European Commission regarding certain countries.

7. Changes to this Privacy Policy

We may modify this Privacy Policy from time to time. If we decide to make significant changes to this Privacy Policy, we will notify you through our services or other available means and give you the opportunity to review the revised Privacy Policy. By continuing to access or use the service after these changes take effect, you agree to be bound by the revised Privacy Policy.

8. Supplementary Notice for California Residents

This supplemental California Privacy Statement applies only to our processing of Personal Data subject to the 2018 California Consumer Privacy Act ("CCPA"). CCPA grants California residents the right to know which categories of Personal Data we have collected and whether we have disclosed this Personal Data for commercial purposes (such as to service providers) in the past twelve months. California residents can find this information below.

Types of Personal Data collected

Third party categories that disclose Personal Data for commercial purposes

identifier

Service provider

The users or third parties you share with

Advertising partners

Business Information

Payment Solution Partners

Internet or other electronic network activities

Service provider

The users or third parties you share with

Advertising partners

Geographic location data

Service provider

Advertising partners

Based on inferences drawn from other Personal Data, to create personal profiles about consumers

Service provider

Advertising partners

The categories of Personal Data listed in California Civil Code § 1798.80 (e)

Service provider

The users or third parties you share with

The types of sources from which we collect Personal Data and the business and commercial purposes for which we use Personal Data are as described above.

The sale of Personal Data as stipulated by CCPA. As far as CCPA is concerned, we do not “sell” Personal Data, nor do we have actual knowledge of any “sale” of Personal Data of minors under the age of 18.

Non-Discrimination. California residents have the right not to be discriminated against by us for exercising the rights granted by CCPA.

Authorized Agent. Only you or a person authorized by law to act on your behalf may make verifiable consumer requests related to your Personal Data. To designate an authorized agent, please contact us as follows.

Verification. When you make a request, we will ask you to provide sufficient information so that we can reasonably verify that you are the person or authorized representative from whom we collect Personal Data, which may include confirming the email address associated with any Personal Data we have about you.

If you are a California resident and wish to exercise any rights granted to you by CCPA, please contact us through mindup@readio.io. We will handle such requests in accordance with applicable laws.

9. Supplementary Notice for Virginia Residents

This supplementary Virginia Privacy Statement only applies to situations where you reside in Virginia. Where applicable, it describes how we use and process your Personal Data and explains your specific rights under the Virginia Consumer Data Privacy Act (“VCDPA”).

Disclosure of Your Personal Data Use

We may collect and use certain information from you, some of which may be Personal Data (such as your age, email address, IP address, or other information that may reasonably be associated with you), in order to operate our services and maximize your experience.

If you would like to further understand the categories or purposes of the Personal Data we collect from you, please read Sections 1 and 2. To learn more about sharing of your Personal Data with our business partners and other third parties, please read Section 3.

Data Rights

Our Privacy Policy describes the data rights we provide to all users and how to exercise these rights. This includes the right to access, review, correct, update your data, obtain portable copies of your data, or delete data related to your stored preferences and your use of the service. Before completing your request, we may need some information that is sufficient to verify your identity.

In addition, VCDPA provides the following data rights for residents of Virginia:

Choose not to process your Personal Data for targeted advertising. In order to exercise your right of choice as a resident of Virginia, please contact us through mindup@readio.io

with the subject of “Virginia Do Not Sell Request”. We will handle such requests in accordance with applicable laws.

Please note that we will not process Personal Data for the following purposes: (1) selling Personal Data (as defined by VCDPA); Or (2) for further analysis to make decisions that have a significant legal or similar impact on consumers.

Confirm if your Personal Data is being processed. You can confirm whether your Personal Data is being processed by sending an email tomindup@readio.io.

Appeal your request. If we refuse to take action on your data rights request or reject your request, you can do so through mindup@readio.io to contact us to file an appeal against this decision. Please use the subject line “Appeal for Refusal to Take Action on Privacy Request” and provide relevant information in the email. After receiving your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision.

10. Supplementary Notice for Nevada Residents

If you are a resident of Nevada, you have the right to choose not to sell certain Personal Data to third parties who intend to license or sell it. You can exercise this right by contacting us through mindup@readio.io with the subject “Nevada Do Not Sell Request” and providing us with the email address associated with your account. Please note that we currently do not sell your Personal Data as sales are defined in Chapter 603A of the Nevada Revised Statutes.

11. Account Deletion

You can delete your account at any time using the “Settings” function of the application, or contact us through mindup@readio.io. According to your request, we will delete your account and all related data, except for limited information, which will be stored for specific purposes and limited periods, including the purposes specified in this Privacy Policy. The deletion process may take up to 30 days to complete.

Please note that once you initiate the deletion process, your account will no longer be available for use, and you may not be able to access all subscription features or receive a refund of the payment. To avoid any additional fees, you must unsubscribe before deleting your account. For instructions on how to unsubscribe, please refer to our Subscription Terms.

12. Data Retention

We will store your Personal Data for a reasonable and necessary period of time to achieve the purposes specified in this Privacy Policy (including providing services to you), including (but not limited to) the period during which you have a service account. We will also retain and use your Personal Data as needed to fulfill our legal obligations, resolve disputes, and enforce our agreements.

13. How to Handle "Do Not Track" Requests

Unless otherwise specified in this Privacy Policy, this application does not support “Do Not Track” requests. To determine whether any third-party services it uses comply with the “Do Not Track” request, please read its Privacy Policy.

14. Personal Data Controller

CHARAXTON CORPORATION PTE. LTD.

15. Contact Us

You can contact us at any time to learn more about this Privacy Policy and its previous versions. If you have any questions about your account or Personal Data, please contact us through mindup@readio.io.

Last Updated: 06/24/2025