Privacy Policy


Last updated: May 30, 2020


LuckyStart Technolohy Limited. (“LuckyStart Technolohy Limited.”, “us”, “we”, “Company”, ‘”LuckyStart’’ or “our”) is committed to protect and respect your privacy in connection with your use of our associated Mindfulness mobile application (the “App” and other application, services and features thereof (the Apps and such other application, services and features are collectively referred to herein as the “application”, which may be updated from time-to-time at the sole discretion of Mindfulness),  collects information when you use the App (the “Service”).. This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the application will be processed by us. It also explains how we use and disclose the information we collect from you, and your rights in relation to that information. By accessing, visiting or using the Service, you expressly consent to our collection, storage, use and disclosure of your information as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you must not use the Service. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use or disclose your personal data.


Any application and service related with the Privacy Policy is operated by LuckyStart Technolohy Limited. and its related company. The registered address of LuckyStart Technology Limited. is Morgan & Morgan Building, P.O. Box 958, Pasea Estate, Road Town, Tortola British Virgin Islands. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at




Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We will notify users of changes to this Privacy Policy by posting the amended terms on the popping out window in application in advance of the last updated date of the changes. If you do not agree to the changes, you should discontinue your use of the Service before the modified privacy policy takes effect. If you continue using the Service after the modified privacy policy takes effect, you will be bound by the modified privacy policy.




Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services.


The data we collect depends on the context of your interactions with us, the choices you make, including your privacy settings, and the application and features you use. The data we collect can include SDK/API/JS code version platform, timestamp, IP Address, application identifier, application version, application distribution channel, independent device identifier,the session start / stop time, operating system and device, the network state (Wifi or others), etc.


Usage InformationWhenever you use our Services after you accept the Terms of Service and Privacy Policy, we will collect your usage information, such as the sessions you use or music you listen to, what screens or features you access, and other similar types of usage information.


Account InformationIf you create an Account, we’ll collect certain information that can be used to identify you, such as your email address. If you create an Account using your Login credentials from one of your Social Networking Sites (the “SNS”) Accounts, we’ll be able to access and collect your name and other email address that your privacy settings on the SNS Account permit us to access. If you create an Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information that is not considered email address because it cannot be used by itself to identify you.


Information Related to Use of the ServicesOur servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, operating system. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance the Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to fight spam, malware and identity theft.


Information Sent by Your Mobile DeviceWe collect information about the mobile device you use to access our Services, including the operating system and version, device identifiers set by your device operating system, and mobile network information (like your connection type).


Third-Party Payment ProcessingWe may sell subscriptions or merchandise through our Services. When you make purchases through the Services, we process your payments through a third party application, including the Apple App Store, Google Play App Store (together with any similar applications, “App Stores”).


Data Collected for EventsIf you chose to have your account verified to confirm your status as a health-care provider, please contact us at We may collect your relevant identifier in connection with your email address in order to perform the verification.


Transactional InformationWhen you make a purchase or return, we collect information about the transaction, such as application description, price, subscription or free trial expiration date, and time and date of the transaction.




We will not share any email address that we have collected from or regarding you except as described below:


Information Shared with Our Services Providers: We may engage third-party services providers to work with us to administer and provide the Services. These third-party services providers have access to your email address only for the purpose of performing services on our behalf. We may also share your email address except with our marketing service providers to help us better market our application and services to you. Our marketing service providers may use your email address only for the purpose of helping us better market our application and services to you and are prohibited from transferring your email address to others. If you don’t want Mindfulness to use your information for these purposes, you can opt out by contacting us at


Information Shared with Other Systems, Such As HealthKit or Google Fit: You may instruct us to share certain of your information with systems such as Apple’s HealthKit or Google Fit, and to access information from those systems which we will use to improve the services we provide to you. Before you tell us to share your information with another system, however, you should review the applicable privacy policy of that system, since any information you have instructed us to share will become subject to those policies.In addition, in the event that you use one of those services, you should be careful about allowing other applications, services or people to access your information through that service. While much information collected by those services is innocuous, people who see Mindfulness data may be able to determine a variety of personal information.


· Mindfulness does not use or disclose to third parties user data or other information gained through the use of the HealthKit framework or Google Fit for advertising, other use-based data mining purposes or similar services, other than for purposes of improving health or for purposes of health or medical research.


· We do not write your data, including mindful minutes and sleep data, to the HealthKit store without your permission.


· We do not sell any of your information, including information gained through HealthKit or Google Fit, to advertising platforms, data brokers or information resellers.


· We do not use any of the information obtained through HealthKit or Google Fit for any purpose other than providing health and/or fitness services in connection with the Services.


Information Shared with Third Parties: To improve our application and provide you better service, we also share personal data with vendors, agents or research organizations working on our behalf for the purposes described in this privacy policy. For example, companies we may hire to provide data analytical services may need collect and access to personal data to provide those functions. Any third party with whom we may share user data will provide equal protection of user data as stated in this privacy policy. We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.


Information Disclosed in Connection with Business Transactions: Information that we collect from our users, including email address, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, some or all of our assets, including your email address, may be disclosed or transferred to a third-party acquirer in connection with the transaction.


Information Disclosed for Our Protection and the Protection of Others: We cooperate with government and law enforcement officials and/or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate:


·   If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Mindfulness or others;



·   to respond to claims or legal process (including subpoenas, warrants or court orders);In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;



· to protect our property, rights and safety, and to protect the rights, property and safety of a third party or the public in general


· to prevent or stop any activity we consider illegal, unethical or legally actionable activity.




We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our application and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).


In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services.




You may be able to log-in to our application using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form. Services like Facebook Connect give you to the option to post data about your activities on our application or to your profile page to share with others within your network.




Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. Requests should be submitted by contacting us through


If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.


We retain your Personal Data as long as needed to provide services or application to you, or as required or permitted by applicable laws, such as tax and accounting laws.


Modifying Your InformationYou can access and modify the email address associated with your Account through your Account settings or by contacting us at


You can request to export your data by contacting us at Before exporting your data, we will confirm information such as your identity, security status.




We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your email address) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.




The retention periods applied by Mindfulness comply with applicable legislation in effect on the date hereof, namely:



For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not Mindfulness.



For data collected based on your consent to receive our marketing communications: we will use such data until you withdraw consent or applicable law requires that such data is no longer used.



When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.



Other: Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.




Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to that owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.




You may use the Services only if you are 13 years or older and are not barred from using the Services under applicable law. To make a purchase via the Services (described in ‘’Purchases’’ in Terms of Use), you must be 18 years or older and capable of forming a binding contract.




We may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by posting the amended terms on the popping out window in application in advance of the last updated date of the changes. We encourage you to periodically review this page for the latest data on our privacy policy.




Please contact us at if you have any questions about our Privacy Policy.