Effective Date: November 1, 2024

1. Introduction

Empowered Mind LLC ("we," "us," or "our") operates the ReWire application ("App") accessible at app.getcopilot.pro. This Privacy Policy explains how we collect, use, disclose, and protect personal data provided by users ("you" or "your") of ReWire, including data gathered via Google, AWS, and other third-party services.

This Privacy Policy is intended to comply with relevant privacy laws and regulations, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and applicable federal laws of the United States. By using ReWire, you agree to this Privacy Policy. If you do not agree, please refrain from using our services.

2. Information We Collect

We may collect and process the following types of information:

a. Personal Information

Account Information: Name, email address, username, and password when you register or use our App.Profile Information: Profile photo, user preferences, and other details you voluntarily provide to personalize your experience.

b. Usage Data

App Activity: Details about how you use the App, including clicks, pages visited, features accessed, and in-app interactions.Log Data: Information such as IP addresses, browser type, operating system, and timestamps that may be collected automatically when you access our App.

c. Device Information

Device Identifiers: Data such as mobile device ID, model, and manufacturer.

Cookies and Tracking Technologies: Cookies, web beacons, and similar technologies to track user activity and gather usage data, in accordance with our [Cookie Policy].

d. Google User Data

Our App requests Google user data under Google’s OAuth API for secure authentication, personalized account setup, and enhanced user experience. See Section 4 for more details on Google User Data usage.

3. Legal Basis for Data Processing

For users located in the European Union, we process personal data based on the following lawful grounds as per GDPR:

Consent: By consenting to our terms, you agree to the processing of your personal data as described in this Privacy Policy.

Performance of Contract: We process data as necessary to fulfill our obligations in providing the App.

Legitimate Interests: We may process data based on legitimate business interests, such as improving the App, ensuring security, and analyzing usage trends.

Legal Compliance: Processing data as required to comply with legal obligations.

4. Use of Google User Data

ReWire integrates with Google services and may request access to certain Google user data, primarily for account setup, authentication, and personalization.

Google API Scopes: We request only the minimum necessary scopes, including profile information and email, to facilitate account creation and authentication securely.

Purpose of Google Data: Data obtained from Google APIs (e.g., name, email address) is used to simplify the user registration process, provide personalized content, and enhance user experience.

Data Storage and Retention: We store Google user data securely and retain it only as long as necessary for the purposes specified in this Privacy Policy or as required by law.

We comply with Google’s limited-use requirements, only using and storing Google data as permitted under Google’s Developer Policies.

5. Use of AWS Services

ReWire uses Amazon Web Services (AWS) for secure storage and data processing. AWS complies with industry-standard security protocols, ensuring that personal data is encrypted both in transit and at rest.

Data Storage: All user data is stored securely in AWS data centers in the United States.Access Control: We implement strict access controls, ensuring that only authorized personnel can access sensitive data.

Backup and Recovery: AWS enables regular backups, and data is retrievable in case of a system failure or data breach.

Compliance: AWS complies with various industry certifications, including SOC 2, ISO 27001, and others, helping us adhere to relevant data protection standards.

6. How We Use Your Information

The information we collect is used for the following purposes:

Account Management: Setting up and managing user accounts, authentication, and personalization.

Improving User Experience: Analyzing usage patterns to improve app functionality and user satisfaction.

Security and Fraud Prevention: Detecting and preventing unauthorized access, security threats, and fraud.

Customer Support: Responding to user queries, troubleshooting issues, and providing support.

Compliance: Ensuring compliance with legal obligations, including data security, privacy regulations, and audits.

7. Sharing of Your Information

We do not share, sell, or rent your personal data with third parties except as outlined below:

Service Providers: We may share information with trusted third-party service providers (e.g., AWS) who help us provide, analyze, and improve the App. These providers are bound by confidentiality agreements and may not use your data for any other

purposes.

Legal Compliance: We may disclose your information to comply with applicable laws, regulations, legal processes, or government

requests.

Business Transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred. We will provide notice before any such transfer occurs.

8. International Data Transfers

We store and process personal data in the United States. If you are accessing our App from outside the U.S., please be aware that your information may be transferred, stored, and processed in the United States. We take appropriate measures to protect your personal data in compliance with applicable data protection laws.

9. Data Security

We implement robust security measures to protect personal data from unauthorized access, alteration, disclosure, or destruction:

Encryption: Data is encrypted in transit and at rest.

Access Control: Access to data is limited to authorized personnel based on a need-to-know basis.

Monitoring and Auditing: We monitor systems for potential vulnerabilities and audit data access to ensure compliance with security policies.

10. Your Data Protection Rights

For users in the European Union, you have the following rights under GDPR:

Access: Request a copy of the data we hold about you.

Correction: Request corrections to any incorrect or incomplete information.Deletion: Request deletion of personal data, subject to certain legal

exceptions.

Data Portability: Request transfer of data to another service provider.

Objection: Object to data processing for certain purposes.

To exercise these rights, please contact us at [email protected]

11. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this Privacy Policy. Data may be retained to comply with legal obligations, resolve disputes, or enforce agreements. Data related to user accounts will be deleted upon account closure or after a defined period of inactivity.

12. Children's Privacy

ReWire is not intended for individuals under the age of 13, and we do not knowingly collect personal data from children. If we become aware that we have collected personal information from a child without parental consent, we will delete such information promptly.

13. Changes to Our Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We encourage you to review this Privacy Policy regularly for any updates. We will notify you of significant changes by posting the revised Privacy Policy on this page and updating the effective date.

14. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us: Email: [email protected]