This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the MindField mobile application and related services. It applies to all users regardless of the role(s) you hold on the platform — Seeker, Instructor, Space Owner, or any combination (MindField's fluid identity model: one account, three roles).
MindField is operated by MagPulse Labs ("MindField", "we", "us", "our"), incorporated in {{OWNER_INPUT:jurisdiction_of_incorporation}}, company number {{OWNER_INPUT:company_registration_number}}, with registered address at {{OWNER_INPUT:registered_business_address}}.
Data Controller: MagPulse Labs
Contact: privacy@mindfieldapp.com
Supervisory Authority: Comissão Nacional de Proteção de Dados (CNPD), Portugal — cnpd.pt
This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the MindField mobile application and related services.
| Category | Examples | Who It Applies To |
|---|---|---|
| Account information | Email address, phone number, display name, profile photo | All users |
| Date of birth | Collected at registration for age verification (18+ requirement); not displayed publicly | All users |
| Role-specific information | Instructor certifications, discipline, bio; Space Owner space details, address, photos | Instructors, Space Owners |
| Payment information | Payment card details (tokenised by Stripe; we do not store raw card numbers), payout bank account (via Stripe Connect) | All users who transact |
| Communications | Messages sent within the platform, booking enquiries | All users |
| Identity verification | KYC documents submitted for Instructor/Space Owner verification (processed by Stripe for connected accounts) | Instructors, Space Owners |
| User-generated content | Reviews and ratings you submit | All users |
| Support communications | Correspondence with our support or moderation team | All users |
| Category | Examples |
|---|---|
| Device and usage data | Device type, operating system, app version, session duration, feature interactions |
| Location data | Approximate location (home area — a fuzzed centroid, ≥300m from your actual location) derived from GPS with your permission, or from manual input. Raw GPS is never stored beyond 7 days and is never returned via any API. |
| Push notification tokens | Device tokens for APNS (iOS) or FCM (Android) to deliver notifications |
| Analytics data | Anonymised usage patterns, crash reports (PII stripped before transmission to Sentry) |
| Source | Data received |
|---|---|
| Stripe | Payment status, payout status, KYC verification outcome |
| Mapbox | Reverse-geocoded neighbourhood and city names (we send fuzzed coordinates; Mapbox returns place names) |
| Purpose | Lawful basis |
|---|---|
| Account creation and authentication | Contract (GDPR Art. 6(1)(b)) |
| Enabling bookings between Seekers and Instructors | Contract |
| Processing payments and payouts | Contract |
| Displaying your public profile | Contract |
| Proximity-based session discovery | Contract |
| Trust and safety — moderation and fraud prevention | Legitimate interest (Art. 6(1)(f)) |
| Sending service notifications | Contract |
| Sending marketing communications | Consent (Art. 6(1)(a)) — you may withdraw at any time |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
| Improving the platform (aggregated, anonymised analytics) | Legitimate interest |
We do not sell your personal data. We share data only as described below.
| Shared data | Shared with | When |
|---|---|---|
| Display name, photo, role, rating | Other platform users | On your public profile |
| Fuzzed session/space location | Seekers browsing map | Always fuzzed; exact address shared only post-booking confirmation |
| Reviews and ratings | Public | After booking completion |
| Provider | Purpose |
|---|---|
| Stripe | Payment processing, KYC for payouts |
| Amazon Web Services (S3) | File storage (photos, avatars) |
| Mapbox | Map rendering, reverse geocoding |
| Sentry | Error monitoring (PII-scrubbed) |
| Expo / EAS | App build and update infrastructure |
| Apple (APNS) | iOS push notifications |
| Google (FCM) | Android push notifications |
| Supabase (eu-central-1, Frankfurt) | Primary PostgreSQL database hosting |
We may disclose personal data to law enforcement, regulators, or courts where required by law or where necessary to protect the safety of users or the public.
| Data category | Retention |
|---|---|
| Account and profile data | Life of account; anonymised within 30 days of deletion request |
| Raw GPS | Maximum 7 days; hard deleted |
| Booking and payment records | 7 years (Portuguese financial record obligations) |
| Messages | 2 years after last message; content nulled on erasure |
| Trust & Safety records | 5 years |
| Notification log | 90 days |
| Auth tokens | Until expiry or revocation |
Account deletion timing note: see Account Deletion —
the immediate-vs-grace-period reconciliation (blueprint RK-EL-30) is pending an owner decision recorded in
facts/decisions.md.
Under GDPR, you have the right of access, erasure, portability, rectification, restriction of processing, and to object to processing (including marketing). Full details of each right and how to exercise it are available via Settings → Privacy → Manage My Data in the app, or by emailing privacy@mindfieldapp.com.
We will respond within 30 days. If your request is complex, we may extend this by up to 2 months with notice. If you are not satisfied with our response, you have the right to lodge a complaint with the CNPD (cnpd.pt) or the supervisory authority in your country of residence.
MindField is based in the EU. Some of our service providers process data outside the EU (Stripe, Mapbox, Expo/EAS, FCM/Google — all US-based). Where this occurs, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) and applicable EU adequacy decisions.
We implement technical and organisational measures to protect your personal data, including encryption in transit (TLS 1.2+) and at rest, hashed password and refresh-token storage, PII scrubbing before error-log transmission, server-side location fuzzing, and access controls limiting staff data access to the minimum necessary. In the event of a data breach affecting your rights and freedoms, we will notify the CNPD within 72 hours and you without undue delay where required by GDPR Art. 34.
MindField does not use data for third-party advertising tracking. An App Tracking Transparency (ATT) prompt is shown after your first booking, and analytics collection is gated on that permission. The exact scope of granted-state analytics (first-party user-ID-level vs. anonymised) is pending final counsel confirmation (S-01) and will be updated here once resolved.
MindField is intended for users aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe a minor has created an account, please contact us at privacy@mindfieldapp.com and we will delete the account promptly.
We may update this policy from time to time. Material changes will be notified via in-app notice and email at least 30 days before taking effect. Continued use of MindField after the effective date constitutes acceptance of the updated policy.
Data Controller: MagPulse Labs
Email: privacy@mindfieldapp.com
Address: {{OWNER_INPUT:registered_business_address}}
Supervisory Authority: CNPD — cnpd.pt