Mind Analyzer — Privacy Policy

1. Who We Are

Mind Analyzer is developed and operated by:

dataWorks GmbH
Seestrasse 59
8702 Zollikon
Switzerland
UID CHE-196.074.218
Email: support@data-works.ch

This policy covers the Mind Analyzer app for iPhone, iPad and Mac. It is written to meet both the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (nDSG). We have not appointed a Data Protection Officer, as we are not required to under Swiss or EU law.

2. The Short Version

• Mind Analyzer has no network access at all. The app contains no code that connects to the internet, so nothing you record can reach us or anyone else through the app.
• There are no user accounts, no sign-in and no in-app purchases.
• Your brain, heart and motion data stay on your device. They are read from your headband over Bluetooth, processed on the device and saved as files that only you can open, share or delete.
• We use no analytics, crash-reporting, advertising or tracking SDKs.

Because we receive no data from the app, we cannot see, export or delete anything you record. You stay in full control of it.

3. What Data the App Processes

3.1 Sensor data from your headband (on-device only)

With your permission to use Bluetooth, Mind Analyzer connects to your Muse headband and reads:

• EEG signals (brain activity) from the headband's electrodes,
• optical sensor data (PPG) from which the app derives pulse, heart-rate variability and, where the headband supports it, blood oxygenation trends,
• motion data from the accelerometer and gyroscope,
• device information: the headband's name, model, firmware version, battery level and signal quality.

From these the app computes band powers, spectra and the Calm, Focus and Drifting indices, and it compares them with a personal baseline you can record. EEG and heart data are health data, a special category of personal data under Art. 9 GDPR. All of this processing happens on your device, under your control, for your own use. It is never transmitted to us or to third parties.

You can withdraw Bluetooth access at any time in your device settings; the app then cannot read the headband.

3.2 Recordings, markers and meditation sessions

When you record, Mind Analyzer saves files in the app's own folder on your device (visible in the Files app on iPhone and iPad, and in the Documents folder on the Mac):

• recordings of the sensor data (CSV files) and, if you turn it on, a raw Bluetooth packet log,
• the markers and tags you add, and the notes and ratings you give a meditation session,
• per meditation: the sensor data, a timeline, your distraction taps and a summary.

These files leave your device only when you share or export them yourself, through the sharing target you pick (for example AirDrop, Mail or a cloud drive). The provider you share with is then responsible for the data under its own terms.

If you turn on iCloud or computer backups of your device, the operating system may include the app's files in those backups. That backup is a service between you and Apple (or your computer) and does not involve us.

3.3 Focus tracking on the Mac (optional, off by default)

On the Mac you can turn on automatic focus tagging. When it is on, the app notes which app is in front and, if you also allow it, the title of the front window (for example the name of a document or web page), and stores this as activity spans alongside your recording so you can see which work keeps you focused.

• Window titles are only available after you grant Screen Recording permission in System Settings. The app reads only the title text of the front window, never the content or pixels of your screen.
• Private browser windows are recorded as the browser only, without a title. You can exclude apps, and turn titles or the whole feature off at any time.
• The data is stored locally with your recordings and appears in your exports.

3.4 Live Activity, floating panel and notifications

On iPhone, Mind Analyzer can show your attention state in a Live Activity on the Lock Screen and in the Dynamic Island; on the Mac, in a floating panel and the menu bar. These are updated locally by the app. No push service is involved and no data leaves your device. You can turn the Live Activity off in the app or in your device settings.

3.5 Settings

Your settings (for example display preferences, the meditation recipe, the recorded baseline and your tag colours) are stored on your device and are removed when you delete the app.

3.6 Information Apple may share with us

If you have chosen in your device settings to share analytics or crash data with app developers, Apple may provide us with anonymised crash reports and aggregated usage statistics through App Store Connect. This is controlled by Apple and by your device settings, not by the app; we cannot identify you from it. Ratings and reviews you leave in the App Store are submitted to Apple.

4. Support Requests

If you email us, we receive your email address and the content of your message, plus anything you choose to attach (for example a recording). We use it only to answer you.

• Legal basis: our legitimate interest in handling support requests (Art. 6(1)(f) GDPR; Art. 31 nDSG); for health data you send us yourself, your explicit consent (Art. 9(2)(a) GDPR), which you can withdraw at any time
• Retention: until the request is settled, at most 24 months; attached recordings are deleted once the request is settled

5. What We Don't Do

• We do not collect, transmit or store your sensor data, recordings or focus data.
• We do not require or offer user accounts.
• We do not use analytics, crash-reporting, advertising or tracking SDKs.
• We do not show ads and do not sell or share personal data.
• We do not profile you or make automated decisions about you.
• We do not operate a user database that could be breached.

6. International Data Transfers

The app transfers no data. If you email us, your message is processed by our email provider; the app itself sends nothing anywhere. The App Store, its rating dialog and app delivery are subject to Apple's own terms.

7. Your Rights

Under the Swiss nDSG and, where applicable, the EU GDPR, you have the right to:

• access the personal data we hold about you,
• have inaccurate data corrected,
• have your data deleted,
• receive your data in a portable format,
• object to processing based on legitimate interest,
• withdraw a consent you have given,
• lodge a complaint with a supervisory authority.

Practical note: unless you have emailed us, we hold no data about you at all. Everything the app records stays on your device: you can export it at any time and delete it by deleting the files or the app.

To exercise your rights, contact us at the address in Section 1. We respond within 30 days.

Supervisory authorities:

• Switzerland: Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, CH-3003 Bern, https://www.edoeb.admin.ch
• EU: your national data protection authority

8. Not a Medical Device

Mind Analyzer is a general wellness and research tool. It is not a medical device and is not intended to diagnose, treat, cure or prevent any disease.

9. Children

Mind Analyzer is not directed at children under 13. We do not knowingly collect personal data from children; the app collects none from anyone.

10. Security

Your data is protected by your device's own security (passcode, encryption, app sandbox). Because the app has no network access and no account, there is no server on our side that holds your data or could be compromised.

11. Changes to This Policy

We may update this policy when the app's data processing changes. The current version is always available at this address; material changes will be highlighted in the app's release notes.

Muse is a trademark of Interaxon Inc. Mind Analyzer is an independent app and is not affiliated with Interaxon.