PRIVACY POLICY

Welcome to our Privacy Policy!

We are happy you want to know more about the information we collect about you. We have tried to keep this Policy as simple and self-explanatory as possible to help you understand what information we collect, how we use it, to tell you about your rights and how the law protects you.

We recommend you read this Policy in full. However, here is a summary of the main ideas we want you to remember from it:

• We don’t sell information that is related to you to third parties;
• We collect certain information about you such as:

• Information you provide us (ex.: name, age, e-mail address)
• we may collect Information related to the type of device used and your browser information, state, country and type of device;

• You may choose to receive our newsletters or not and change your account information at any moment;
• By visiting the website, you are accepting and consenting to this Privacy Policy.

Throughout this Policy, references to “The Attachment Project”, “we”, “us”, “our” or the “Company” refer to MindOnly Pty Ltd. When we refer to “you” or “your”, we mean you, the person visiting our website and holding personal data.

We are truly committed in protecting your personal data and we are determined to respect your privacy.

Definitions

“Anonymisation” means the processing of Personal Data in such a way as to ensure that the Data Subject is no longer identified or identifiable. To determine whether a Data Subject is identifiable, account should be taken of all the means reasonably likely to be used either by the Controller or by any other person to identify the said person.

“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Controller” means the legal entity which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“European Data Protection Law” means the EU General Data Protection Regulation 2016/679 (“GDPR”), and its national implementing legislations and data protection privacy laws applicable in the countries of the European Economic Area (“EEA”).

“Personal Data” means any information relating to an identified or identifiable (“Personally Identifiable Information” or “PII”) natural person (“Data Subject“) (“You“). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“Processor” means the legal entity which processes Personal Data on behalf of and under the instructions of the Controller.

“Retention Period” means the period of time for which Personal Data has to be or can be stored, considering legal requirements including privacy aspects as well as Company’s economic and business needs.

“Sensitive Personal Data” or “Sensitive Data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs; trade-union membership; genetic data, biometric data processed solely to identify a human being; health-related data; data concerning a person’s sex life or sexual orientation.

Legal framework

Your personal data is processed in a way to ensure compliance with the applicable legislation, including the GDPR, as well as Australian and other applicable privacy laws, as referred herein.

Who is responsible for this website?

MindOnly Pty Ltd., with registered office at 7/420 King William Street, Adelaide, SA, 5000, registered in South Australia, Australia with Australian Business Number 67 159 735 387, is responsible for this website attachmentproject.com (the “Website”) and this Privacy Policy applies to your use of the website and its sub-domains and related contents (“Products” or “Services”).

Who is responsible for the processing of your personal data?

MindOnly Pty Ltd. Is the Controller of the Personal Data we collect and further process about you on the Website.

What personal data do we collect?

Under the applicable data protection laws, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.

We will only process your Personal Data if at least one of the following legal basis applies:

• when necessary to perform the Terms and Conditions or to provide you with the services;
• where you have consented to the processing, which you may revoke at any time;
• when necessary for us to comply with a legal obligation, a court order, or to exercise and defend legal claims;
• when necessary to protect your vital interests, or those of others, such as in the case of an emergency;
• where you have made the information manifestly public;
• where necessary in the public interest; and
• where necessary for the purposes of our, your, or a third party’s legitimate interest.

When collecting Personal Data for sending promotional messages, including but not limited to information about new and additional products, services, and opportunities available to you, we will need your consent.

We only collect the personal data that we consider essential for you to access and enjoy our Website and related services and products.

Thus, the data we collect about you on our Website includes:

• Identifiable data: first name, last name, username or similar identifier, marital status, date of birth and gender;
• Contact details: billing address; delivery address, e-mail address and phone number;
• Financial data: bank account and credit card information if you purchase a product;
• Connection and location data: address; browser type and version, location, operating system and platform;
• Data related to your interaction with us: feedback given by you; your interests, preferences; and survey/quiz/test answers;
• Usage data: information about how you use our Website, products and services.

How do we collect your personal data?

We collect your Personal Data directly from you when:

• you visit and/or register on our Website;
• you interact with us electronically;
• you respond to our surveys and/or promotions, or
• you write us a message.

We may also collect your publicly available data and any information you decide to share with us in your messages and e-mails.

Please note that it is your responsibility to ensure that whenever you submit another person’s personal information on the Website, that person has given their consent for the disclosure and processing of their information in accordance with this policy.

For which purposes do we process your data?

We will process your Personal Data for the following purposes:

• Provision of our services/products and related content;
• Sending personality test results;
• Manage the functioning of the Website;
• Payment processing;
• Investigate any complaints;
• Improving our services;
• Sending promotional messages, including but not limited to information about new and additional products, services, and opportunities available to you;
• Research purposes intended to further develop and understand the attachment styles.

Please bear in mind that we will only collect this information when necessary for the purposes hereabove and upon the legal bases referred herein, or if you decide to provide the information.

How do we handle children’s data?

We care deeply about making sure children are safe online.

Regardless of local legislation, children under the age of 18 are not allowed to use our Website.

If you have reason to believe that a child has provided personal information to us, please contact us at team@attachmentproject.com. We will use commercially reasonable efforts to delete such personal information.

Cookies

We use cookies on our Website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site.

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

We may also use third-party cookies and Web beacons on our Site to deliver advertising displayed to you on third-party sites. We may also use cookie information to know when you return to our Site after visiting these third-party sites. Additionally, we may also use analytics services to help analyze how users use the Site.

Please be aware that blocking all or some cookies may affect the functionality of our Website.

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Whom do we share your data with?

We may also make use of service providers or intermediaries (processors) in the course of its business, which may involve access by these third parties to personal data of our employees and suppliers.

Our business is hosted on the MindOnly platform, (hereinafter “Controller” or Mindonly.com”). MindOnly provides with an online platform that enables us to sell products and services to you. Your Personal Data may be stored in the database of Mindonly.com. We will ensure that appropriate technical and organizational measures are taken to ensure that the sub-contractors meet the applicable legal requirements and provide adequate data protection safeguards.

We will sometimes have to use external providers (Processors), such as Amazon AWS, Stripe, PayPal, Auth0, SendinBlue, FastSpring, Brevo, Facebook (Meta), Google Analytics, Hotjar and Pressable.

Please remember that these providers will not be using your personal data for their own purposes, but solely to provide us with services we need and are part of the services we provide you, within the purposes detailed in this Privacy Policy. We only use entities that have implemented the adequate technical and organizational measures and that guarantee the fulfilment of the legislation in force.

These entities will only process Personal Data for the purposes expressly foreseen in this Privacy Policy, being bound to tight contracts which guarantee that they will only process your Personal Data, based on express and written indications provided by us.

International transfers

As a global business, we access and transfer information around the world. If you are based in the EU, this means that we access and transfer your Personal Data outside the EU, including in and to the United States. The privacy protections and the rights of authorities to access your Personal Data in some of these countries may not be the same as in your home country. We transfer your Personal Data in accordance with law and take steps to ensure that your information is appropriately protected.

In particular, where we transfer Personal Data to countries that are not viewed as providing adequate protections, we generally rely on approved safeguards under the GDPR to protect the Personal Data transferred.

California residents – California Privacy Rights Act

California residents may ask us to provide them with a list of the types of Personal Data that we have disclosed to third parties for direct marketing purposes, and the identity of those third parties. If you would like such a list, please contact us via the contact details herein with subject field: “California Privacy Rights Act”. If you exercise your rights, we will not charge you different prices or provide different quality of services. We don’t sell personal data to third-parties.

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you for additional information. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that the agent has valid written authority to submit requests to exercise rights on your behalf.

For how long will we retain (Retention Period) your Personal Data?

Our objective is that our users have a long-lasting relationship with our Website, even if visits are not very frequent. We will store your Personal Data and your account will continue to be active for 4 years following your last interaction with our Website for anyone that specifies a country inside of the European Union. Prior to closing your account, we will notify you asking whether you wish to maintain your account active.

After a deletion request, your Personal Data will be retained for up to 3 months as part of backup procedures.

We may also need to retain some of your Personal Data for a longer period to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our Terms of Service.

We also keep all anonymized data indefinitely for the purposes of studies and survey results.

What are your rights?

As a data subject, you have the following rights in respect of the Personal Data we hold about you:

• Right to be informed: you have the right to obtain clear, transparent, and easily understandable information about how we use your personal data.
• Data subject’s right of access: you can request a copy of the data we hold about you.
• Right of rectification: you have the right to rectify your personal data if it is incorrect or out of date and/or to complete it if it is incomplete.
• Right to erasure of data (“right to be forgotten”): you have the right to request the deletion of your data. This right is not absolute, as we may have legal or legitimate reasons to retain your personal data.
• Right to, at any time, object to the processing of data on the basis of consent: you may object to the processing of data where such processing is based on consent. Withdrawing consent does not affect the lawfulness of the consent previously given.
• Right to data portability: you have the right to receive personal data concerning you, in a structured, commonly used and machine-readable format, and the right to transmit this data to another organisation. This applies only to data you have provided whose processing is based on your consent or on a contract, and if the processing is carried out by automated means.
• Right to limit processing: you can ask us to limit the use of your data to storage only, to stop using it for all other purposes or to retain data that should be deleted.
• Lodging a complaint to the Supervisory Authority on Data Protection: you also have the right to lodge a complaint with the data protection supervisory authority when your rights have been violated or your personal information is or is being used in a way that you believe is not in accordance with applicable law.

How do we respect the security of your data?

We implement the technical and organizational measures that ensure the confidentiality of your Personal Data, protecting it from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access and against other unlawful forms of data processing.

We take the following measures:

• Pseudnonymisation of sensitive data (gender) in the quiz;
• Pseudonymisation and encryption of Personal Data;
• Anonymisation when we delete your personal identifiable information.

Any entity we outsource to will be bound by equivalent security measures, acting at all times under our duly documented instructions.

Reasonable Inferences and automated decisions

By opting in into our quizzes and by replying to our questionnaires we might be able to infer relationships, gender and relationship type, which can be addressed on the report alongside other personal data and/or other inferences. The information we collect and/or infer will be stored in our systems according to the terms of this Privacy Policy.

We do not anticipate that any decisions which have legal or other effects on you will be made using purely automated means; however, we will update this policy if this situation changes and notify you of such changes.

Eventual inferences and automated decisions based on your inputs that can be related to “sex orientation” or any other personal information considered as “sensitive data” (or “special category data”) will be automatically pseudonymized by default and by design, following best practices of technical and organizational measures to protect your personal information.

No sensitive information, including based on eventual inferences and automated decisions, will be collected, or disclosed to organizations or people without your express consent or out of the scope of our Services.

Our products and services, including our quiz, do not result in decisions being made or action taken against you in a way that could have a significant impact on you and will not be used to contact you in ways that may seem intrusive.

Changes to this privacy policy

As practices regarding the processing of personal data may change from time to time, this Privacy Policy will need to be updated accordingly and on a regular basis, so we advise you to check it periodically. If there is a significant change, we will inform you directly by e-mail.

Contact us

If you have any questions about this Privacy Policy or want to exercise your rights to access, update or correct any personal information, please contact us through the following contacts:

MindOnly Pty Ltd

7/420 King William St,

Adelaide SA 5000, Australia

E-mail: Contact Us Page