Chinese Privacy Addendum V2.0

This Chinese Privacy Addendum (this “Addendum”) applies to individuals located in the People’s Republic of China (“China”) pursuant to China’s Personal Information Protection Law (“PIPL”). This Addendum supplements and forms an integral part of Unmind’s Global Privacy Policy. In case of any inconsistencies between this Addendum and the rest of Unmind’s Global Privacy Policy, this Addendum prevails with respect to the personal information of individuals located in China.

Your health-related information may be considered sensitive personal information under the PIPL. We will process such information when you choose to interact with the Unmind Mood and Wellbeing trackers, use Nova (Unmind’s AI Mental Health Agent), request Unmind Therapy & Coaching sessions or complete a ‘session prep’ questionnaire prior to a Therapy or Coaching session. Using the features described is optional. When you sign up, we will ask you if you consent to us collecting such sensitive personal information from you. We only process your sensitive personal information for purposes as described in Unmind’s Global Privacy Policy and take appropriate security measures to ensure the confidentiality and security of your sensitive personal information.

We may process your personal information without obtaining your consent under the following circumstances:

• It is necessary for the conclusion or performance of a contract to which you are a party;
• It is necessary for the fulfilment of our statutory obligations;
• It is necessary for coping with public health emergencies or for the protection of an individual’s life, health or property; and
• Your personal information is processed within a reasonable scope in accordance with applicable Chinese laws if such personal information has already been publicly disclosed by yourselves or through other legal sources.

We will never sell your personal data but we may need to share your personal data with third-party data processors so that we can use their technology to deliver and improve the Unmind experience for you. These processors may collect and process your personal information to assist us in services delivery and operation as described in Unmind’s Global Privacy Policy.

We are headquartered in the UK and our database is hosted by a cloud-based service provider, Amazon Web Services (AWS). This database is located in the European Union (EU) in the Republic of Ireland (RoI). Your personal information described in the ‘Types of Information we Collect’ section will be transferred to, stored, and processed by us for purposes described in the ‘How we use your personal data and why’ section. We will obtain your separate consent or rely on other legal basis available under the PIPL for the transfer of your personal information. To the extent required under the PIPL, we will also adopt an applicable lawful international transfer mechanism for such transfers and take measures to ensure the overseas recipient can provide the same level of protection as required under the PIPL.

As a Chinese user and resident, you have the following rights and choices in relation to your personal data:

• The right to request explanation: If you want to know more about how our processing activities work, or you have questions about anything contained in this Addendum, or our Global Privacy Policy, then you can ask us at privacy@unmind.com.
• Request access to your personal data: You have the right to access your information processed by us.
• Right to portability: You have rights to obtain and reuse your personal information for your own purposes across different services. If you ask us for your information in a portable format, then that means we will give it to you in an accessible and machine-readable format, for example as a csv file. You can also ask us to safely transfer it to another system for you.
• Request the rectification of your personal data: You have the right to ask us to update or correct the personal information that we hold about you if it is inaccurate, incomplete, or out of date. We have designed our platform so that you can make these changes yourself, but you can contact us if you are having trouble.
• Right to erasure: You can ask us to delete any information we hold about you. Be careful, this isn’t a general right to erasure, we can only process this request when: The purpose of the processing, as detailed in our Global Privacy Policy has been achieved, is impossible to achieve, or it is no longer necessary to achieve; The retention period ends; You have withdrawn your consent, if we rely on your consent to process your personal information; or Unmind violates laws or administrative regulations when processing your personal information.
• The right to object to processing: You may ask us to stop or restrict our processing of your personal information. This might be because you believe we do not hold accurate information about you or that our processing is unnecessary or different to the purpose identified in our Global Privacy Policy. This is not an absolute right, but we will always strive to meet it when we can.

If you have any questions or there are things you don’t understand in this Addendum or our Global Privacy Policy, or you would like to exercise one of the rights detailed above, then you can contact us at privacy@unmind.com. We will respond to your request within the timeframe required under the PIPL after your identity is verified.

Nothing in this Addendum shall limit the rights you should have as a personal information subject under Chinese law.