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    Privacy Policy — Mindaura

    Last updated: October 30, 2025

    1. DEFINITIONS AND KEY TERMS

    1.1 Company and Service Terms

    • Mindaura (“we,” “us,” “our”): a service of Talent Draw LLC

    • Service: All features, functionalities, programs, and content available through Mindaura

    • Platform: Our website and related services accessible via any device

    • User: Any individual accessing or using our services (“you” or “your”)

    1.2 Data and Privacy Terms

    • Personal Data: Any information relating to an identified or identifiable natural person

    • Processing: Any operation performed on personal data

    • Data Controller: Mindaura (Talent Draw LLC), determining purposes and means of processing personal data

    • Data Processor: Third parties that process personal data on our behalf

    • Cookie: Small text file stored on your device containing data about your platform usage

    1.3 Security Terms

    • Authentication: Process of verifying user identity

    • Encryption: Process of encoding information to prevent unauthorized access

    • Token: Unique identifier used for secure authentication

    • SSL/TLS: Security protocols for encrypted data transmission


    2. INTRODUCTION AND SCOPE

    2.1 Policy Overview

    This privacy policy explains how Mindaura collects, uses, and protects your personal data and describes your privacy rights and how to exercise them.

    2.2 Policy Application

    This policy applies to:

    • All users of Mindaura globally

    • All data collection methods

    • All service features and functionalities

    • All platform versions and updates

    2.3 Policy Updates

    • We may update this policy at any time.

    • We will notify you of material changes via email.

    • Continued use after changes constitutes acceptance.


    3. PERSONAL DATA COLLECTION

    3.1 Account Information

    A. Essential Data

    • Email address (required for authentication)

    • Name (collected during payment processing)

    • Last sign-in timestamp

    • Unique account identifiers

    • IP addresses

    B. Optional Data

    • Phone number (if provided through payment processors)

    • User preferences and settings

    • Communication preferences

    3.2 Service Usage Data

    A. Test Results

    • Final IQ scores

    • Completion timestamps

    • Performance metrics

    Note: Individual test answers are processed in real time and are not stored.

    B. Interaction Data

    • Features accessed, time spent, navigation patterns

    • Device information (see §3.4)

    3.3 Payment Information and Processing

    3.3.1 Payment Data We Receive
    We only receive and store limited, tokenized payment information from PCI-compliant processors:

    • Tokenized payment method identifiers

    • Last four and first six digits of payment cards

    • Card expiration dates

    3.4 Technical and Device Data

    A. Device Information
    OS and version; browser type/version; screen resolution; device type/model; language preferences

    B. Connection Data
    IP address; network information; connection type; approximate geolocation derived from IP; time zone

    C. Performance Data
    Load times; error messages; system metrics; latency; application response times


    4. DATA PROCESSING AND USAGE

    4.1 Primary Processing Purposes

    A. Service Provision
    Account creation/management; authentication/security; feature access/customization; support; optimization

    B. Payment Processing
    Subscription management; authorization; fraud prevention; transaction records; billing support

    C. Communication
    Service updates/notifications; security alerts; product information; support responses; legal notices

    4.2 Secondary Processing Purposes

    A. Service Improvement
    Usage pattern analysis; feature optimization; performance monitoring; UX enhancement; bug resolution

    B. Analytics and Research
    Aggregate statistics; trend analysis; platform optimization; feature development; benchmarking

    4.3 Legal Bases for Processing

    • Contractual necessity (service provision, account, payments, support)

    • Legal obligations (tax, financial records, compliance)

    • Legitimate interests (improvement, fraud/security, technical ops, business development)

    • Consent (marketing, optional features, third-party integrations, certain analytics/experiments)


    5. DATA STORAGE AND SECURITY

    5.1 Storage Location and Data Transfers

    • Personal data is stored in secure European data centers.

    • Data may be transmitted globally using encrypted channels.

    • We implement appropriate safeguards for international transfers (e.g., SCCs), with ongoing compliance monitoring.

    5.2 Security Measures

    5.2.1 Infrastructure Security
    A. Authentication & Access: MFA capability; passwordless email sign-in; single-use codes; session management; RBAC; least privilege; access logging/monitoring; periodic reviews and automated revocation
    B. Data Protection: SOC 2 Type 2 controls; AES-256 at rest; TLS in transit; regular audits
    C. System Security: DDoS protection (e.g., Cloudflare); intrusion detection; patching; infrastructure monitoring

    5.2.2 Payment Security
    PCI DSS compliant processors; tokenization; no full card numbers accessible to us; encrypted transmission; incident response; regular compliance reviews

    5.2.3 Backup & Recovery
    Automated encrypted backups; disaster recovery and BCP; restoration procedures; geographic redundancy

    5.2.4 Organizational Security
    Incident response protocols; access control policies; security incident reporting; change management

    5.2.5 Monitoring & Maintenance
    Real-time monitoring and logging; performance tracking; periodic security reviews; continuous compliance; updates/patching; vulnerability assessments

    5.3 Data Breach Notification Procedures

    5.3.1 Definition: Unauthorized access, loss, destruction, or disclosure of personal data; any incident compromising confidentiality, integrity, or availability.
    5.3.2 Internal Response: Activate incident plan; assess scope; contain; document; risk-evaluate.
    5.3.3 User Notification: Notify affected users within 72 hours of breach confirmation via email.
    5.3.4 Content: Incident description; data types; potential impact; steps taken; user actions; contact info and resources.
    5.3.5 Regulatory Compliance: Notify authorities where required; cooperate; provide documentation; implement remedial measures.
    5.3.6 Post-Breach: Investigate; add controls; update procedures; provide updates; enhance security.


    6. ANALYTICS, ADVERTISING, AND THIRD-PARTY SERVICES

    6.1 Analytics and Infrastructure Partners

    6.1.1 Analytics Services
    Google Tag Manager; Google Analytics; Mixpanel; Google BigQuery; Sentry (errors/perf); Cloudflare (perf/security)

    6.1.2 Session Recording Details (Sentry)

    • Automatic masking of user inputs and exclusion of data entry fields

    • Designed to avoid collection of PII; however, incidental capture may occur in rare edge cases (e.g., if a field isn’t technically maskable). We apply safeguards and minimization, and prohibit use for profiling.

    • Used strictly for bug investigation and performance optimization.

    6.1.3 Data Collected by Analytics
    Usage patterns; feature interactions; performance metrics; error info; anonymized flows; aggregate stats

    6.2 Advertising Partners and Data Sharing

    6.2.1 Partners
    Facebook, Google, Snapchat, TikTok, Taboola, Outbrain, AppLovin, Pinterest

    6.2.2 Data Sharing Practices
    Anonymous identifiers; hashed email addresses (where permitted and subject to your consent/opt-out rights); usage and device data; interaction metrics

    6.2.3 Partner Usage
    Ad performance measurement; targeting optimization; audience segments; campaign analytics

    6.3 User Control Over Tracking

    6.3.1 Tracking Limitations
    Browser cookie controls; ad-blockers; device settings; platform-specific controls

    6.3.2 Opt-Out Options
    DAA/NAI opt-out tools; platform ad settings; partner-specific opt-outs; our in-product cookie preferences center (where available)

    6.3.3 Impact
    Limiting tracking may affect personalization or certain features; core functionality remains available.

    6.4 Do Not Sell or Share (US-CPRA)

    We provide mechanisms to opt out of “sale” or “sharing” of personal information for cross-context behavioral advertising where applicable. Use the site footer link “Do Not Sell or Share My Personal Information” or contact us (see §12).


    7. YOUR RIGHTS AND CHOICES

    7.1 Universal Rights

    Access; correction; deletion (see §8.2); objection; portability; withdraw consent.

    7.2 Regional Privacy Rights

    EU/UK (GDPR): Inform, access, rectify, erase, restrict, portability, object, automated decision-making rights.
    California (CCPA/CPRA): Know, access, correct, delete, opt-out of sale/share, limit sensitive data use (where applicable), non-discrimination, portability.
    Australia: Notice, access, correction, purpose specification, use limitation, disclosure transparency.
    Canada (PIPEDA): Access, accuracy, consent withdrawal, transparency, protection expectations.

    7.3 How to Exercise Rights

    7.3.1 Submission
    Email support@mindaura.co or use the Help Center (see §12). California users may also use the “Do Not Sell/Share” link.

    7.3.2 Verification
    Email verification; account auth; for sensitive requests/agents, government ID and proof of authority.

    7.3.3 Timelines
    Acknowledgment within 72 hours (California: 10 days for CCPA); standard response 30 days; up to 45 days with notice; appeals decided within 30 days.

    7.3.4 Delivery
    Machine-readable (CSV/JSON), complete data inventory, encrypted transfer.

    7.3.5 Appeals
    Appeal within 30 days; include reasons and any added information; decision within 30 days.


    8. DATA RETENTION AND DELETION

    8.1 Retention Periods

    • Account data: while account is active

    • Payment records: as required by law

    • Analytics data: for service improvement

    • Communication records: 2 years

    • Security logs: 13 months

    • Inactive accounts: deleted after 365 days of inactivity (see Terms)

    8.2 Deletion Procedures

    Account deletion: standard 30-day process; backup removal within 90 days; verification and completeness checks performed.


    9. INTERNATIONAL DATA TRANSFERS AND LEGAL JURISDICTION

    9.1 Transfers

    We use Standard Contractual Clauses and technical/organizational safeguards for transfers outside the EEA/UK, with regular assessments.

    9.2 Legal Jurisdiction and Dispute Resolution

    9.2.1 Escalation Process
    First-level: escalations-support@mindaura.co (include reference number). Response within 5 business days.
    Second-level: same address for senior review; final decision within 15 business days.
    Informal resolution: 30-day good-faith negotiation period after escalation.

    9.2.2 Formal Proceedings
    This Privacy Policy is governed by the laws of the State of Nevada, USA. Disputes are resolved via binding arbitration administered by the AAA as set out in Section 14 of our Terms & Conditions. You consent to the personal jurisdiction of courts in Clark County, Nevada for matters exempt from arbitration. Claims must be brought within six (6) months of the incident, unless a longer period is required by applicable law.


    10. CHILDREN’S PRIVACY

    Minimum age 18. We do not knowingly collect data from minors. We will terminate accounts and delete data if we learn a user is underage.


    11. CHANGES TO THIS POLICY

    11.1 Modification Rights

    We may modify this policy at any time.

    11.2 Types of Changes

    Material: Significant changes to processing purposes, data sharing, or user rights.
    Non-Material: Clarifications, formatting, contact updates, security enhancements, analytics/partners updates, regional compliance updates, and other changes that don’t substantially affect rights.

    11.3 Notice Requirements

    Material Changes: Email notice 5 days before implementation; effective on notice date.
    Non-Material Changes: May be implemented immediately; updated policy posted on website.

    11.4 Your Options

    Review the current policy; discontinue use if you disagree; continued use indicates acceptance.


    12. LEGAL INFORMATION AND CONTACT DETAILS

    12.1 Company Information

    Talent Draw LLC
    2550 E Desert Inn Rd #260
    Las Vegas, NV 89121, United States
    Phone: 702-913-3871
    Email: support@mindaura.co
    Help Center: https://mindaura.co/help

    All inquiries will be handled according to the response timelines detailed in §7.3.3.