Privacy Policy

WIND METHOD, SRL (“WIND METHOD,” “we,” “us,” and/or “our”), respect your concerns about privacy and values its relationship with you. In this privacy policy (“Privacy Policy”) we describe the types of information we collect from and about you through our websites, thewindmethod.com, never-relapse-again.com, and our “Never Relapse Again” application (“Never Relapse Again app”), whether accessed via computer, mobile device or other technology (collectively, the “Services”). We also describe how that information may be used, with whom it may be shared, and how you can reach us to get answers to questions you may have about our privacy practices. Finally, we also set forth certain legal rights you may have, subject to applicable law, and how you can exercise them.

Please read this policy carefully, because by using the Services you are acknowledging that you understand and agree to the terms of this policy. In addition, please review our Terms of Service, which governs your use of the Services and any content you submit to the Services.

We encourage you to contact us with any questions.

For purposes of this Privacy Policy, when we say “Personal Information” we mean information that specifically identifies an individual (such as a name, address, telephone number, mobile number, email address, or photograph), or information about that individual that is directly linked to personally identifiable information. Personal Information includes “personal data” as defined by the European Union’s General Data Protection Regulation (“GDPR”) and “personal information” as defined by the Romanian applicable laws.

Personal Information does not include “aggregate information”, which is data we collect about the use of the Services or about a group or category of services or users from which individual identities or other Personal Information has been removed. Personal Information also does not include Usage Information (as defined below) or Device Identifier (as defined below) that is not connected to Personal Information.

Information You Provide to Us Directly

We collect information that you voluntarily provide in the following ways.

Information Collected When You Request a Trial or Sign In to the Never Relapse Again App. When you request a free trial or sign in to the Never Relapse Again app for the first time, we require that you provide us with your email address or Apple ID which we use to send you a 4-digit code to sign into the app.

Information Collected When You Set Up an Account and Populate Your Profile. If you create a Never Relapse Again account, we give you the option to populate your profile with your first and last name, the city in which you reside, and a profile photo or avatar. Doing so is entirely voluntarily and is simply offered as a way to personalize your account. We will not access your photos or the camera on your computer, tablet, mobile phone, or other device (“Device”) without first getting your explicit permission. If you give us permission to access photos or your Device camera, we will only use images that you specifically choose to share with us.

Information Collected When You Purchase a Subscription. If you choose to subscribe to the Never Relapse Again app, you will be required to provide your payment card information, which can include your name, card number, expiration date, security code, and billing address. If you subscribe from within our mobile app, your payment card information will be collected and stored by the third-party app store you use. If you subscribe through our website, your payment card information will be collected and stored by our third-party payment processor.

Information Collected When You Sign Up to Receive Newsletters or Other Email Communications from Us, Subscribe to Our Blog, or Complete a Survey. When you engage in one of these activities, we may collect your name, email address, and any additional information you choose to provide to us as part of that request (such as information about your satisfaction with our Services in response to a survey).

Information Collected When You Email Us to Ask a Question or Request Customer Service, or When You Communicate with Us Via a Third-Party Social Media Platform. When you contact us by email; through our branded social media accounts; or by telephone, SMS, or physical mail, we may collect your name, email address, phone number, physical address, and the contents of your communication which can include any information you choose to provide. We strictly use that information to provide the service or support you have requested.

Information Collected When You Send a Gift Card. Our Services allow you to send a gift card to another person. In these cases, we will use the recipient’s email address solely to deliver the necessary gift card activation code.

Information We Collect by Automated Means

We also collect certain information automatically as you navigate our Services or interact with our communications.

To collect this information, we, or our third-party service providers, may use cookies or similar technologies. A “cookie” is a small text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We, and our third-party service providers use cookies in order to do things such as recognize you when you return to our website, save your preferences (including your preferences regarding cookie handling), understand which sections and features of our Services you find most interesting, ensure our Services are working properly, and prevent fraud. We use both session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them or until they expire).

Certain pages on the Services may contain “web beacons” (also known as Internet tags, pixel tags, tracking beacons and clear GIFs). A web beacon is a transparent graphic image placed on a web page or in an email, which indicates that a page or email has been viewed or that an email has been forwarded. In addition, a web beacon allows third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. A web beacon may also tell your browser to get content from another server.

The information we collect automatically can include the following:

• Information About the Devices You Use to Access our Services. This can include your internet protocol (IP) address or other unique device identifier, hardware model, operating system, and browser type.

• Details About Your Interactions With our Services. This includes information such as the date, time, length of stay, specific pages or features accessed during your visit; and search terms used to reach our Services. We use this information to determine the popularity of certain content, to save your preferences and allow you to track your progress, and to improve the app.

• Usage Information. This includes the number and frequency of visitors to our Services; and

• Location Information. Specifically, our third-party service providers may collect general location information inferred from your IP address which is used for purposes such as verifying your time zone.

Analytics and Advertising. Never Relapse Again also uses third-party analytics and advertising tools to measure traffic and usage trends on our Services and to serve advertisements on our behalf across the internet. These tools assist us in improving our website and help us better understand which ads bring users to our Services.

Information We Collect from Other Sources

We may also obtain Personal Information from other sources. For instance, we may collect Personal Information about you from:

Payment Processors. In general, when you purchase a subscription from Never Relapse Again, your payment card information is provided directly to our third-party payment processor and Never Relapse Again does not collect or store that information. However, we may receive limited information about your payment card such as the last four digits of your card, the country of issuance, and the expiration date.

Another Never Relapse Again User. We may collect Personal Information from another Never Relapse Again user if that user provides us with your email address in order to gift you a monthly or annual subscription.

Third-Party App Stores. We may receive certain transaction information from third-party app stores such as Apple’s App Store and Google’s Play Store when you use those platforms to install our app or purchase a subscription. For instance, when you make a purchase or cancellation, we collect information about the transaction, such as the date and time of the transaction, the price paid, and the expiration date for the subscription or free trial.

We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.

We use the information described above to do the following:

• To provide the Services or information you request, including identifying you when you sign-in to your account;

• To provide notifications, including through push notifications;

• To provide recommendations to content and information we think will be of interest to you;

• To communicate with you about products, services, offers, promotions, and events we offer;

• To request feedback and to otherwise contact you about your use of the Services;

• To communicate with you and respond to your emails, submissions, questions, inquiries, comments, requests, and suggestions;

• To post testimonials;

• To monitor and analyze Services usage and trends and otherwise measure the effectiveness of the Services;

• To identify, fix, and troubleshoot bugs and service errors;

• To send you confirmations, updates, security alerts, and support and administrative messages,

• To protect against, identify, investigate, and respond to misuse of our Service or other unlawful behavior;

• To notify you about important changes to our Services; and

• To carry out any other purpose described to you at the time the information was collected.

We may share information about you with certain third parties in the following circumstances:

Companies under Common Control. We may share information between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with WIND METHOD.

Third Parties Providing Services on Our Behalf. In order to carry out your requests, to make various features, services, and materials available to you through the Services, and to respond to your inquiries, we may share your Personal Information or Usage Information with third parties that perform functions on our behalf, such as companies or individuals that host or operate our Services, analyze data, or provide customer service.

Other Third-Party Systems, Such as the Apple Health App and Google Fit. If you choose to connect the Never Relapse Again App to third-party systems such as Apple’s Health app or Google Fit, we will supply certain information, such as the amount of time you spend on mindfulness activities using our app to your Health app or Google Fit database. Please note that we only share information to and do not read any information from these databases. Before you tell us to share your information with another system, we encourage you to review the applicable privacy policy and terms of use for that system as any information you instruct us to share will become subject to those policies and we are not responsible for safeguarding any information stored within those systems.

Business Transfers. We may share Personal Information with another company in connection with or during negotiations of any merger, acquisition, financing, re-organization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.

Legal Disclosure. We may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Service or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Services, or the public.

Consent. We may share Personal Information with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information.

We may also share non-Personal Information, such as aggregate user statistics, demographic information, and Usage Information, which cannot reasonably be used to identify you for various purposes including compliance with various reporting obligations and for business or marketing purposes.

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to use or disclose your Personal Information. To the extent those laws apply, our legal grounds are as follows:

Legitimate Interest. In most cases, we handle Personal Information on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

• Providing the Service pursuant to our contract with our customers;

• Marketing our business;

• Protecting our customers, personnel, and property; and

• Analyzing and improving our business.

Legal Compliance. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.

To Honor Our Contractual Commitments to an Individual. Some of our processing of Personal Information is to meet our contractual obligations to the individual to whom the Personal Information pertains.

Consent. Where required by law, and in some other cases, we handle Personal Information on the basis of implied or express consent. For instance, in relation to direct marketing, we will obtain and rely on your consent in relation to the processing concerned.

Data Requests. Certain privacy laws, including the GDPR provide users with rights related to their Personal Information. Depending on your location, you may be eligible for a number of rights with respect to your information.

Right to Access & Portability: You may be able to access certain Personal Information associated with your account by visiting your account settings. You can also request a copy of your Personal Information in an easily accessible format along with information explaining how that data is used.

Right to Correction: You have the right to request that we correct information about you. You can correct and change certain Personal Information associated with your account in your account settings or by emailing us at thewindmethod@gmail.com.

Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your Personal Information.

Right to Deletion: In certain circumstances, you have the right to request the deletion of your Personal Information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of the Services.

Right to Object: If we process your Personal Information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will stop processing your Personal Information unless we have a compelling legitimate ground to continue processing or where it is legally necessary.

Right to Withdraw Consent: Where we rely on consent, you can withdraw your consent to our processing by using various means we offer such as an email unsubscribe link or your account settings. This is without prejudice to your right to permanently close your account and delete your Personal Information.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. Before responding to your request, we may require that you provide us with additional information to confirm your identity. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. We may verify the authenticity of the request directly with you. You also have the right to lodge a complaint with the authorities applicable to your situation. However, we invite you to contact us - thewindmethod@gmail.com - with any concern, as we would be happy to try to resolve it directly.

We may provide links to third-party websites, services, and applications that we do not own or operate. This Privacy Policy does not apply to the privacy practices of those third parties. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. We encourage you to review the privacy policies of any third-party service before providing any Personal Information to or through them.

We maintain certain administrative, technical, and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Services and provide us with your information at your own risk.

We only keep your Personal Information for so long as reasonably necessary for the purposes described in this Privacy Policy, as required by law, or as necessary to resolve disputes and enforce our rights and agreements. To dispose of Personal Information, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in Romania where we are based or in any country where we have operations or where we engage vendors or service providers. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to Romania and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside and/or are a citizen.

Our Services are directed at adults and we do not knowingly collect Personal Information from children. If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us Personal Information without your consent, please contact us at thewindmethod@gmail.com

We may change this Privacy Policy from time to time to reflect changes in our practices or in the law. If we make changes to this policy, we will post the updated Privacy Policy on our website and indicate when it was last revised. You are advised to review this policy periodically to stay informed of our practices. If we make material changes, we may provide you with additional notice, such as posting a statement on our homepage or sending you an email notification, if we have your email address on file. Your continued use of the Services after the revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Policy, to the extent permitted by law.

If you have any questions about our Privacy Policy or how we protect your Personal Information, please contact us at thewindmethod@gmail.com