This Privacy Policy explains how one81 (Pty) Ltd (“one81”, “we”, “us”, or “our”) collects, uses, stores, and protects your personal information when you use the Mind-Pro digital service (“Service”).
By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
1. WHO WE ARE
Mind-Pro is a digital platform owned and operated by:
one81 (Pty) Ltd
Email: info@one81.com
The Service is distributed via Mobile Network Operators (“MNOs”), who may act as independent data controllers in relation to billing and subscriber data.
2. APPLICABLE LAWS
We process personal information in accordance with applicable data protection laws, including:
- Protection of Personal Information Act
- Zimbabwe data protection legislation
3. INFORMATION WE COLLECT
We collect limited, non-medical personal information, including:
3.1 Information You Provide
- Mobile phone number (via MNO integration)
- Responses to profiling questionnaires
- Goal selections and preferences
- User-generated inputs within the Service
3.2 Automatically Collected Information
- App or platform usage data
- Content engagement (e.g. views, clicks, interactions)
- Progress tracking data (goals, milestones, completion)
- Device and session data (e.g. device type, timestamps)
3.3 Information from MNOs
Where applicable, we may receive:
- Confirmation of subscription status
- Billing status (active/inactive)
We do not receive or store:
- Bank card details
- Financial account data
- Detailed billing records
4. WHAT WE DO NOT COLLECT
Mind-Pro does not collect or process:
- Medical or health records
- Clinical or diagnostic information
- Special personal information as defined under POPIA (unless explicitly stated and consented to in future updates)
5. HOW WE USE YOUR INFORMATION
We use your information to:
- Deliver and operate the Service
- Personalize content and recommendations
- Enable goal setting and progress tracking
- Improve user experience and platform performance
- Communicate important service updates (including via SMS where required)
- Comply with legal and regulatory obligations
We do not sell your personal information to third parties.
6. LEGAL BASIS FOR PROCESSING
We process your personal information based on:
- Consent (e.g. when you opt in to the Service)
- Contractual necessity (to provide the Service)
- Legitimate interests (e.g. improving the Service, preventing misuse)
- Legal obligations (where applicable)
7. SHARING OF INFORMATION
We may share your information with:
7.1 Mobile Network Operators (MNOs)
- For billing, subscription validation, and regulatory compliance
7.2 Service Providers
- Hosting, analytics, and technology partners supporting the Service
7.3 Legal & Regulatory Authorities
- Where required by law or to protect our legal rights
All third parties are required to handle your data securely and in accordance with applicable laws.
8. CROSS-BORDER DATA TRANSFERS
Your information may be stored or processed in countries outside your own.
Where this occurs, we ensure:
- Adequate data protection safeguards are in place
- Transfers comply with applicable laws, including POPIA requirements
9. DATA RETENTION
We retain your personal information:
- For as long as your subscription is active, and
- For a reasonable period thereafter for:
- Legal compliance
- Dispute resolution
- Service improvement
Data may be anonymized for analytical purposes.
10. DATA SECURITY
We implement appropriate technical and organizational measures to protect your personal information, including:
- Secure servers and encryption where applicable
- Access controls and authentication measures
- Monitoring for unauthorized access or misuse
However, no system is completely secure, and we cannot guarantee absolute security.
11. YOUR RIGHTS
Subject to applicable law, you have the right to:
- Access your personal information
- Correct or update inaccurate data
- Request deletion of your data
- Object to or restrict certain processing
- Withdraw consent at any time (this may affect your ability to use the Service)
To exercise your rights, contact: info@one81.com
12. COOKIES & TRACKING
Where the Service is accessed via web or app:
- We may use cookies or similar technologies to improve functionality and user experience
- You may manage cookie preferences through your device or browser settings
13. THIRD-PARTY SERVICES
The Service may rely on third-party infrastructure (e.g. MNOs, hosting providers).
We are not responsible for the privacy practices of third-party platforms not controlled by us.
14. CHILDREN’S PRIVACY
- The Service is intended for users 18 years and older
- We do not knowingly collect personal information from minors
15. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time.
- Updates will be made available via the Service or relevant channels
- Continued use of the Service constitutes acceptance of the updated policy
16. CONTACT US
If you have any questions or concerns about this Privacy Policy or your personal information:
one81 (Pty) Ltd
Email: info@one81.com