Privacy Policy for Mindful Clinical Question Banks

Last updated: June 15, 2025

This Privacy Policy explains how Mindful Clinical Question Banks (“we,” “us,” or “our”), an initiative of Mindful Gaming UK, collects, uses, discloses, and protects your personal data when you use our website, products, and services (collectively, “our Site”).

We are committed to protecting your privacy and handling your personal data in a transparent and secure manner, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are and How to Contact Us

Mindful Clinical Question Banks is operated by Mindful Gaming UK, a registered charity in England and Wales. Our charity number is 1212285. Our registered office and main operational address are 5 Longmoor Road, Sutton Coldfield, B73 6UB.

To contact us regarding data protection or any other query, please use the appropriate email address:

• For general enquiries, charity information, or matters relating to Mindful Gaming UK’s broader services (therapy, advice network):
• info@mindfulgaminguk.org (Queries picked up by charity staff)
• For technical support related to the Mindful Clinical Question Banks website, feedback on questions, site improvements, or subscription issues:
• mindfulclinicalqbanks@mindfulgaminguk.org (Queries picked up by website development team)

Our Commitment to Data Protection

Mindful Gaming UK takes data protection seriously, especially given the potential for a large user base and the sensitive nature of some of the data processed. We ensure:

• Compliance: Our charity actively invests in and adheres to relevant data protection regulations, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA). We maintain a robust framework to ensure compliance at scale.
• Safeguarding: We maintain comprehensive safeguarding policies to protect all individuals, especially vulnerable users, interacting with our platforms, regardless of the number of users.
• Trained Personnel: All our team members receive regular and thorough training in data security, privacy governance, and compliance best practices. This training is integral to our operational protocols for handling a large volume of user data.

2. The Data We Collect About You

We collect information to provide and continuously improve our services to you and our growing community. This may include:

• Account Information: When you register for an account, we collect personal details such as your name, email address, and chosen password.
• Subscription & Payment Information: Through MemberPress, we process subscription details. Payment transactions are handled securely by our integrated third-party payment gateways (e.g., Stripe, PayPal). We do not store your full payment card details on our servers.
• Usage Data: We collect information about how you interact with our platform, including course progress, quiz attempts, scores, time spent on content, and features accessed. This extensive data helps us understand user behavior across our large user base and continually improve the learning experience for everyone.
• Content Interaction Data (AI-Powered Features): If you utilize AI-powered features (like explanation clarification, concept identification, or note summarization), the text you input or selected for these features, and the AI’s responses, may be processed to deliver the service and for continuous improvement of our AI models. This processing is conducted with strict confidentiality controls and, where possible, in an aggregated and anonymized manner to protect individual privacy while enhancing the service for all users.
• Group Study Data (if applicable): For collaborative group study sessions, this may include:

• Audio/Video Streams: Processed in real-time for communication. We do not typically record these sessions unless explicitly opted into by all participants for specific features (e.g., AI transcription or summarization of a study session). Any such recordings would be clearly indicated and subject to specific consent and robust retention policies, ensuring privacy for all participants.
• Transcriptions & Summaries: If you use AI transcription/summarization, the audio from the session may be converted to text, and subsequently summarized by AI. These derived texts are stored securely.
• Shared Notes/Chat: Content shared within the group study environment.

• Technical Data: Information about your device and internet connection, including IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site.
• Communications: Records of your correspondence with our customer support team or other charity representatives, which helps us provide effective support to our user community.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3. How We Collect Your Personal Data

We use different methods to collect data from and about you, including through:

• Direct interactions: You may give us your Identity, Contact, Financial, and Profile Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

• Subscribe to our services or digital content;
• Create an account on our Site;
• Request marketing to be sent to you;
• Give us feedback or contact us.

• Automated technologies or interactions: As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources: We may receive personal data about you from various third parties, for example:

• Technical Data from analytics providers such as Google Analytics.
• Financial and Transaction Data from payment gateway providers (e.g., Stripe, PayPal).

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (e.g., to provide you with access to subscription content, process payments).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., to improve our services, for fraud prevention).
• Where we need to comply with a legal obligation (e.g., for tax or regulatory purposes).
• Where we have your consent to do so.

We use your personal data for the following purposes:

• To register you as a new user: (Identity, Contact Data)
• To provide you with access to our subscription services and digital content: (Identity, Contact, Financial, Transaction, Usage Data)
• To process and manage payments and fees: (Financial, Transaction Data)
• To manage our relationship with you: (Identity, Contact, Profile, Marketing and Communications Data)

• Including notifying you about changes to our terms or privacy policy.
• Asking you to leave a review or take a survey.
• To improve our website, products/services, marketing, customer relationships, and experiences: (Technical, Usage, Profile Data)

• This includes analyzing your quiz performance to inform content updates and improvements (e.g., identifying commonly missed questions or areas needing more explanation).
• Understanding user engagement with new features (e.g., AI study, group study).

• AI-Powered Features: To process your requests for explanations, concept identification, and note summarization using the Gemini API, providing you with enhanced learning support.
• Group Study Functionality: To facilitate real-time collaboration, shared notes, and (if opted-in) provide AI-generated transcriptions and summaries of study sessions for groups of any size.
• To enable you to participate in a prize draw, competition, or survey: (Identity, Contact, Profile, Usage, Marketing and Communications Data)
• To administer and protect our business and our Site: (Technical, Usage, Identity Data)
• Including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data.

• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you: (Identity, Contact, Technical, Usage, Profile, Marketing and Communications Data)
• To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences: (Technical, Usage Data)
• To make suggestions and recommendations to you about products or services that may be of interest to you: (Identity, Contact, Technical, Usage, Profile Data)
• To ensure that all profits from Mindful Clinical Question Banks contribute to our charitable mission: Your subscription payments directly enable Mindful Gaming UK to provide therapy and support for individuals with gaming disorders. While we do not share your personal data for this specific purpose, the aggregated financial data underpins our charitable reporting.
• Customer Support: To respond to your inquiries, provide technical assistance, and resolve issues efficiently for a broad user base.
• Security & Fraud Prevention: To protect our platform and all users from unauthorized access, fraud, and other illegal activities, which is critical for a high-volume service.
• Compliance: To comply with legal obligations, enforce our terms and conditions, and protect our rights.
• Charitable Impact: To generate revenue that is directly reinvested into Mindful Gaming UK’s broader charitable activities and social impact initiatives.

5. Disclosure of Your Personal Data

We may share your personal data with the parties set out below for the purposes stated in Section 4:

• Internal Third Parties: Other companies within Mindful Gaming UK acting as joint controllers or processors, who provide IT and system administration services and undertake leadership reporting.
• External Third Parties:

• Service providers acting as processors who provide IT and system administration services (e.g., Kinsta for hosting, LearnDash/MemberPress developers for plugin support).
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Payment gateway providers (e.g., Stripe, PayPal) for processing transactions.
• Analytics providers (e.g., Google Analytics).
• AI Service Providers: For AI-powered features, relevant data (e.g., question text, user notes) may be sent to the Gemini API for processing. We ensure this is done securely and in compliance with data protection principles.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We do not transfer your personal data outside the UK or European Economic Area (EEA) as a matter of course. However, some of our external third-party service providers (e.g., cloud hosting providers like Google Cloud used by Kinsta, or certain payment processors) may process data outside the UK/EEA. Where this occurs, we ensure a similar degree of protection is afforded to your personal data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government.
• Where we use certain service providers, we may use specific contracts approved by the UK Government which give personal data the same protection it has in the UK.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

These measures are designed to be effective at scale and include:

• Secure Hosting: Our platform is hosted on Kinsta, which provides advanced security features and regular backups, crucial for high-traffic websites.
• Encryption: Data transmitted to and from our platform is encrypted using SSL/TLS.
• Access Controls: Strict access controls are in place to limit who can view or process your personal data, reinforcing security for all user accounts.
• Regular Security Audits: We conduct regular security audits and vulnerability assessments to continuously strengthen our defenses.
• Trained Staff: All our team members are rigorously trained in data security and governance, forming a crucial human layer of defense.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. When your data is no longer required, we will securely delete or anonymize it, particularly important when managing data from a large number of users over time.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

9. Your Data Protection Rights

Under data protection laws, you have rights concerning your personal data:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request that we correct any inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): You can request that we delete your personal data under certain circumstances.
• Right to Restrict Processing: You can request that we limit the way we use your personal data.
• Right to Object to Processing: You can object to our processing of your personal data in certain situations.
• Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

If you wish to exercise any of the rights set out above, please contact us using the appropriate email address provided in Section 1.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Cookies

Our website uses cookies to enhance your user experience, analyze site usage across our community, and support our marketing efforts. You can control cookie preferences through your browser settings.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements, especially as our platform grows and evolves. We will notify you of any significant changes by posting the new policy on this page and, where appropriate, through other communication channels. We encourage you to review this policy periodically.