AI Usage Policy for Mindyro

Effective Date: June 30, 2025
Last Updated: June 30, 2025

Riveat Software S.R.L. ("we", "us", "our"), located at Str. Dambovitei, Nr.48a, Et.2, 310001 Arad, Romania, operates the Mindyro mobile application (the "App"), which provides guided meditations and non-fiction book summaries. This AI Usage Policy explains how we use artificial intelligence (AI) technologies in the App to enhance your experience. This policy supplements our Terms and Conditions, Privacy Policy, and Subscription Terms.

By using the App, you agree to this AI Usage Policy. If you do not agree, you may opt out of AI-driven features or refrain from using the App.

1. Purpose of AI in Mindyro

We use AI to improve the functionality and user experience of the App. Specifically, AI is employed for:

  • Content Personalization: Analyzing your preferences, such as meditation types or book genres, to recommend tailored content.
  • Book Summary Generation: Assisting in creating accurate and concise summaries of non-fiction books.
  • User Feedback Analysis: Processing user feedback to improve content quality and app features.
  • Performance Optimization: Enhancing technical aspects, such as app load times, user interface interactions, and content delivery efficiency.

2. How AI Processes Your Data

AI systems process the following types of data, as outlined in our Privacy Policy:

  • Personal Information: Name, email address, and account preferences to personalize recommendations.
  • Usage Data: Interactions with meditations, book summaries, and app features to refine AI models.
  • Feedback Data: Comments or ratings you provide to improve content and services.
  • Device Information: Device type and operating system to optimize AI-driven performance.

All data processing complies with the General Data Protection Regulation (GDPR) and is conducted securely using industry-standard measures.

3. Legal Basis for AI Processing

Under GDPR and the EU AI Act (Regulation (EU) 2024/1689), we process data for AI purposes based on:

  • Consent: You provide explicit consent for AI-driven personalization when you enable these features in the App or during account setup. You can withdraw consent at any time (see Section 6).
  • Contractual Necessity: AI is used to deliver core App functionalities, such as content recommendations, as part of the service you request.
  • Legitimate Interests: AI improves the App's performance and user experience, provided this does not override your rights.

4. Transparency and User Control

We are committed to transparency in our AI usage:

  • Notification: You are informed about AI-driven features during onboarding and in this policy.
  • Opt-Out: You can disable AI-driven personalization in the App's settings or by contacting support@mindyro.com. Disabling these features may limit personalized content but will not affect core App functionality.
  • Explainability: Upon request, we can provide general information about how our AI systems make decisions, such as recommendation algorithms, subject to technical and proprietary limitations.

5. Compliance with EU AI Act

If our AI systems are classified as high-risk under the EU AI Act (e.g., due to processing special categories of data like health-related meditation data), we ensure compliance by:

  • Risk Assessment: Conducting regular assessments to identify and mitigate risks.
  • Non-Discrimination: Designing AI systems to avoid bias and ensure fair treatment across all users.
  • Human Oversight: Implementing human review for significant AI-driven decisions, where required.
  • Transparency: Providing clear information about AI usage, as outlined in this policy.

Non-high-risk AI systems, such as those used for content recommendations, adhere to general transparency and accountability obligations.

6. User Rights

Under GDPR, you have rights regarding your data processed by AI, including:

  • Access: Request details about how your data is used in AI systems.
  • Rectification: Correct inaccurate data used by AI.
  • Erasure: Request deletion of your data, which may disable AI-driven features.
  • Restriction: Limit AI processing under certain conditions.
  • Objection: Object to AI processing based on legitimate interests.
  • Automated Decision-Making: Request human intervention if AI decisions significantly affect you.

To exercise these rights, contact us at support@mindyro.com. We will respond within one month, as required by GDPR.

7. Data Security

We use industry-standard technical and organizational measures, such as encryption and access controls, to protect data processed by AI systems. Data is stored securely, and access is limited to authorized personnel and trusted service providers bound by GDPR-compliant agreements.

8. Third-Party AI Providers

We may use third-party AI services for tasks like analytics or content generation. These providers are carefully selected and contractually obligated to comply with GDPR and the EU AI Act. Data shared with them is minimized and protected through Standard Contractual Clauses for transfers outside the European Economic Area (EEA).

9. Special Categories of Data

If you track meditation sessions or mood in the App, this may be considered health data under GDPR Article 9. AI processing of such data requires your explicit consent, which you provide when enabling these features. You can withdraw consent by disabling these features in the App or contacting support@mindyro.com, though this may limit access to certain functionalities.

10. Changes to This Policy

We may update this AI Usage Policy to reflect changes in our AI practices or legal requirements. You will be notified of material changes via email or through the App at least 30 days before they take effect. Continued use of the App constitutes acceptance of the updated policy.

11. Contact Information

For questions, concerns, or to exercise your data rights related to AI usage, contact:

Riveat Software S.R.L.
Email: support@mindyro.com
Address: Str. Dambovitei, Nr.48a, Et.2, 310001 Arad, Romania

You may also lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) at www.dataprotection.ro or your local data protection authority.