Privacy policy

Principles of data protection

The collection of personal data will be carried out only for the specified, explicit and legitimate purposes (presented in point 8.4)
The data will NOT be processed by third parties in a manner incompatible with these purposes;
Personal data will be accurate and up to date (if necessary);
The processing of personal data will be done in a legal, fair and transparent manner;
All personal data will be kept confidential and stored in a highly secure manner;
Personal data will not be shared with third parties unless this is necessary in order to provide services in accordance with existing agreements between the parties;
The persons to whom the data are processed have the right to request access to personal data, to rectify and delete them, to oppose or restrict the processing of data, as well as the right to data portability.

Personal data

Personal data means any information that may be linked to an identified or identifiable person.
Personal data includes all types of direct or indirect information (ie used in connection with other data) relating to the subject person, such as name, surname, address, e-mail address, telephone number, etc.

Collection of personal data

The data we collect may include the following:
Name and contact details (your first and last name, e-mail address, postal address for courier tickets, telephone number)
Data about your device and about the way you and the device interact with our products.
We collect data about the features you use, the products you purchase, and the web pages you visit.
Data about the device and network you use to connect to our products. These include data about operating systems and software applications installed on your device, including product keys. They also include IP address, language settings, and regional settings

The purpose of collecting personal data

Informing customers about the validation and shipment of orders, resolving cancellations or problems of any kind regarding an order, the products and / or services purchased
Sending newsletters and / or periodic alerts, using e-mail (e-mail), only if the data subject (the buyer) has explicitly agreed.
Market research, tracking and monitoring of sales / customer / buyer behavior.
In addition, Ticketing Nation Srl may provide the purchaser’s personal data to other partner companies, but only subject to a confidentiality agreement on their part and solely for the purposes mentioned above, whereby they guarantee that this data is kept secure and that the disclosure of this personal information is carried out in accordance with applicable law, as follows: payment/banking service providers, courier service providers, marketing service providers, or other service providers with whom we may develop joint promotional programs for our goods and services.
The personal information of the buyer can also be provided to the Police, the General Prosecutor’s Office, the courts and other competent state bodies, based on and within the limits of the legal provisions and as a result of expressly formulated requests.

Use of personal data

We will use personal data only for the purpose for which it was collected and will store the data only to the extent necessary for the purposes mentioned above (point 8.4).
We will keep the customer’s information for the period in which his account is active, for any of the purposes mentioned above (point 8.4).
Access to personal data is strictly limited to the staff and associates of Brain Agency SRL, Cluj, Cluj-Napoca
, 26 Edgar Quinet Street, Ap 45, RO29906968, J12/686/2012, who hold the necessary authorization and have a clearly defined need to use the data.
If users do not wish to disclose personal data to these companies, they are asked to contact the DPO at the email address CONTACT@THEINNER.RO

Recordings of the event

By purchasing a ticket and attending the Event, the Product Buyer agrees to be photographed, filmed or recorded by Brain Agency SRL, venue management or any third party operating on behalf of Brain Agency SRL at the Event or in the immediate vicinity of the entrance to the venue. In addition, by purchasing a Product, the Product Buyer consents to photographs, video or audio recordings with you. at the Event or in the immediate vicinity of the entrance to the venue (“Recorded Material”) made by Brain Agency SRL, the management of the venue or any third party operating on behalf of Brain Agency SRL. You hereby agree that Brain Agency SRL, the management of the venue or any third party operating on behalf of Brain Agency SRL may use the Recorded Material in any way it sees fit, without restriction, approval or compensation to do so.
Brain Agency SRL has the image rights over the entire Event and may use the photo and video images, taken both by its own staff and by participants, in various materials produced during the Event.
Participants acknowledge that Brain Agency SRL, its contracted partners authorized by Brain Agency SRL, associates, members of the press, other visitors, and other third parties may produce audio recordings and images of the Event. Therefore, by purchasing a Product and by virtue of their participation in the Event, Participants grant Brain Agency SRL permission to record and publish their image, appearance, and actions as described in the first paragraph.
Brain Agency SRL and persons authorized by Brain Agency SRL have the unrestricted right to derive profit from, use (in particular for the purpose of promoting the Event), copy, publish, publicly broadcast, and distribute such recordings of Visitors, without being required to pay the Visitors for doing so.
Visitors expressly note that Brain Agency SRL may record the Event, concerts and programs, copy the recordings and distribute them by image-carrying means, broadcast or otherwise make them public and may do so repeatedly, including by informing the public about the Event, concerts and programs, by cable data transmission or by any other means (e.g. YouTube), so that members of the public may individually choose the place and time of access.
Visitors are not entitled, within the limits of the law, to make any claims against Brain Agency SRL regarding the recording and publication of their information as described above.
Visitors may not, without the prior consent of Brain Agency SRL, sell, use in exchange for a price or use free of charge for commercial purposes, the image and voice recordings they have made, identify the Visitors appearing in those recordings without their consent, or infringe the personal rights of other Visitors.
Brain Agency SRL reserves the right to establish areas / locations with prohibited photography / filming. In case of non-compliance, Brain Agency SRL has the right to delete those records.

Security of processing

Personal data will be processed securely, and appropriate technical measures will be implemented and maintained to protect it against accidental or unlawful destruction or loss, alteration, disclosure, or unauthorized access, particularly when the processing involves the transmission of data over a network, as well as against any other form of unlawful processing.
Questions regarding the security of personal data can be sent to contact@theinner.ro

Access and rectification or deletion of personal data

Customers have the right to request at any time access to: rectification, portability, deletion or restriction of the processing of data collected.
To keep personal data up to date, we recommend that users inform us of any changes or discrepancies.
To view or modify personal data or to obtain information about personal data, please contact the DPO at the email address: contact@theinner.ro Signed and dated request.
Subscribing to our newsletter gives you the opportunity to be up to date with the latest promotions, loyalty programs, access to the order history, vouchers / discount codes and personalized offers by e-mail
If a subscriber to our newsletter does not open our submissions within a period of 5 months, we reserve the right not to send any more to the respective e-mail address, in addition it will be permanently deleted from the subscriber database.

The Inner App (Mobile and Web) — Privacy Notice

This section describes how we process personal data in connection with the “Inner” mindfulness app for mobile and web (referred to as the “App”), accessible at app.theinner.ro and through the Inner mobile apps for iOS and Android. This section supplements the General Privacy Policy above and applies specifically to the use of the App.

What Data We Collect

We collect only the data necessary to provide, secure, and improve the App.

Account information, depending on the authentication method you choose:

Registration with email and password: email address; the password is managed by our authentication provider using industry-standard hashing functions and is never visible to us.
Sign in with Google: your email address, full name (if you have made it available to Google), and your unique Google account identifier (“Google user ID”). We do not import or store your Google profile photo.
Sign in with Apple: your email address (either your actual email address or a private Apple relay address, whichever you prefer), your name, and your unique Apple ID.

In-App Activity:

Favorites, progress trackers, daily streaks, and the content you open;
The free-form text you provide to the AI-based recommendation feature (see “AI Feature” below);
A device identifier (UUID) generated upon first launch and stored locally on your device, used to enforce the limit of one free sample per device;
Reports of crashes and errors.

We do not collect:

Browsing history outside the app;
Analysis based on IP addresses, advertising identifiers, or tracking data for marketing purposes;
Voice, microphone, camera, or contact data;
Profile photos from Google or Apple.

The app does not include third-party ads and does not share data with ad networks.

Purposes and Legal Bases

Creating and securing your account, authenticating you, and identifying you during subsequent visits — performance of the contract with the user (Art. 6(1)(b) of the GDPR);
Providing content, saving favorites and progress — performance of the contract with the user;
Providing the AI-based recommendation feature — performance of the contract with the user;
Detecting abuse of the AI feature and enforcing rate limits — legitimate interest in protecting the service and other users (Art. 6(1)(f) of the GDPR);
Sending account-related emails (registration confirmation, password reset) — performance of the contract with the user;
Diagnosing errors and improving reliability — legitimate interest (Art. 6(1)(f) of the GDPR);
Where applicable in the future, processing subscription payments through the Apple App Store or Google Play — fulfillment of the contract with the user.

Subprocessors

To operate the App, we rely on a limited number of trusted service providers, each of whom is bound by a data processing agreement in accordance with Article 28 of the GDPR. These providers act in accordance with our instructions and exclusively for the purposes outlined above. Specifically:

Account and login information is held by Supabase, our authentication and database provider. If you sign in with Google or Apple, the identity information we receive from these providers is stored in Supabase.
The requests you submit to the AI-powered recommendation feature are sent to OpenAI solely for the purpose of generating a response. We do not store the text of the request. See “AI Feature” below.

We also work with the following categories of suppliers, none of whom receive data from us for marketing or advertising purposes:

European providers of cloud infrastructure and hosting;
A content distribution network for streaming video and audio meditation materials;
A transactional email provider for registration confirmations and password resets;
An error and crash reporting service configured to exclude users’ email addresses and IP addresses from reports.

If subscription features or push notifications are introduced in future versions, additional providers will be involved (to verify subscription vouchers and to deliver push notifications, respectively). This note will be updated at that time.

AI Function

When you use the AI-powered recommendation feature, the emotional state you select and any free-form text prompt you enter are sent to OpenAI for processing. We do not send your name, email address, or account ID to OpenAI. The request text is ephemeral: we do not store the text of your request at any time.

For internal abuse detection and rate limiting, we retain only the following metadata for each interaction with the AI for 30 days: your user ID, the selected emotional state, the recommended lesson ID, and a category indicator (normal, safety redirect, irrelevant, or error). After 30 days, these records are deleted.

Storage

Account information, including email address, password, and OAuth credentials: retained for as long as your account exists.
Anonymous trial accounts created as guests that are not converted to registered accounts: deleted after 7 days.
Trial recordings on the device (used to limit the number of recordings to one per device): deleted after 90 days if not converted to a registered account.
Metadata from interactions with AI: 30 days, then deleted.
When you delete your account, your profile, favorites, progress, streaks, and device records are immediately deleted; certain operational and legal records may be retained where necessary.

Your Rights

Under the GDPR, you have the rights of access, rectification, erasure, restriction of processing, data portability, and objection. You may exercise these rights:

In the App: Profile -> Delete Account, to immediately delete your account via self-service (subject to any restrictions in the case of an active subscription, as described in the Terms and Conditions);
By email: contact@theinner.ro.

International Transfers

Some of the subprocessors listed above are based outside the European Economic Area. Where data is transferred outside the EEA, we rely on the European Commission’s Standard Contractual Clauses or an equivalent transfer mechanism under Chapter V of the GDPR.

Children

The app is intended for users 16 years of age and older. We do not knowingly collect data from children under 16.

Changes

We may update this Privacy Notice from time to time. The most recent version will always be available at this URL.

Contact

For questions regarding privacy or to exercise your rights: contact@theinner.ro.

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