Privacy Policy

Effective Date: April 27, 2026

Last Updated: April 27, 2026

XpMind Inc. ("we", "us", or "our") operates the SmartNetworker mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the App.

By using the App, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the App.

1. Information We Collect

We strive to collect only what is necessary to provide and improve the App. We do not require you to create an account or provide any personal information to use the core features of the App.

1.1 Information Collected Automatically

When the App encounters an error or crash, the following information may be collected automatically by our third-party error-reporting service (PostHog) for the sole purpose of diagnosing and fixing issues:

• Crash and Error Data: Anonymized stack traces, error messages, and app performance metrics. Stack traces are stripped of personally identifiable information on your device before being transmitted to our error-reporting service.
• Basic Device Context: Device model, operating system version, and app version — collected alongside crash reports to help us reproduce and resolve issues. This information is not used to identify you.
• IP Address: Your IP address may be incidentally collected by PostHog's servers when crash data is transmitted. We do not use IP addresses to identify you personally.

Additionally, our subscription management service (RevenueCat) generates an anonymous user identifier on your device to manage your purchase and subscription status. This identifier is not linked to your name, email, Apple ID, or any other personally identifiable information.

We do not collect general usage analytics, session data, screen views, feature usage patterns, or behavioral data of any kind. Crash data collection occurs only when the App encounters an error.

1.2 Information You Provide

We do not require you to create an account or provide any personal information to use the core features of the App. If you contact us for support via email, we will receive your email address and any information you choose to include in your message.

1.3 Information from Purchases

The App offers optional in-app purchases and subscriptions. All purchases are processed entirely by Apple through the App Store. We do not collect or store your payment card information, billing address, or Apple ID. We receive a transaction confirmation from Apple that includes the product purchased and the transaction date, which we use to unlock your purchased content.

1.4 Information We Do NOT Collect

We do not collect: usage analytics, session data, screen views, behavioral data, your name, email address (unless you contact us), contacts, photos, camera or microphone data, precise location, health data, financial information, advertising identifiers (IDFA), or any biometric data.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To provide and maintain the App: Ensuring the App functions correctly and delivering the features you use.
• To diagnose and fix issues: Using anonymized crash and error reports to identify bugs and improve App stability.
• To manage subscriptions: Verifying your subscription status and providing access to premium features.
• To communicate with you: Responding to support requests or inquiries you initiate.
• To ensure security: Detecting and preventing fraud, abuse, or security incidents.
• To comply with legal obligations: Meeting our obligations under applicable law.

We do not use your information for automated decision-making or profiling that produces legal or similarly significant effects.

3. Legal Basis for Processing

Depending on your location, we process your personal data under the following legal bases:

• Consent: Where you have given consent by choosing to use the App. You may withdraw consent at any time by ceasing to use the App.
• Contract Performance: Processing necessary to provide the App and its features to you.
• Legitimate Interests: Improving the App, ensuring security, and preventing abuse, where these interests are not overridden by your rights.
• Legal Obligation: Where processing is required to comply with applicable law.

4. Third-Party Services

The App uses the following third-party services that may collect information as described in their respective privacy policies:

These third-party services operate as independent data controllers or processors. We encourage you to review their privacy policies.

5. Data Sharing and Disclosure

We do not sell your personal information. We do not share your personal information with third parties except in the following limited circumstances:

• Third-party service providers: As listed in Section 4, solely for the purposes described.
• Legal requirements: If required to do so by law, regulation, legal process, or governmental request.
• Protection of rights: To protect the rights, property, or safety of XpMind Inc., our users, or the public.
• Business transfers: In connection with a merger, acquisition, or sale of assets, in which case your information would be transferred as part of that transaction. We will notify you of any such change.

6. Data Storage and International Transfers

We do not operate our own servers for storing user data. The only data transmitted from the App is anonymized crash and error reports, which are processed and stored by our third-party service provider, PostHog, on their cloud infrastructure hosted in the United States (AWS).

For Canadian users: Your personal information may be transferred to and processed in the United States, which may have different data protection laws than Canada. By using the App, you consent to this transfer. We ensure that appropriate safeguards are in place, including contractual protections with our service providers, to protect your information in accordance with PIPEDA.

For EEA/UK users: Your personal information may be transferred outside the EEA/UK. Where such transfers occur, we rely on appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission, or adequacy decisions, to ensure your data is protected.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law.

• Crash and error data: Retained for 90 days, then deleted. Stack traces are anonymized before transmission and contain no personally identifiable information.
• Purchase records: Retained for the duration required by applicable tax and accounting law (typically 7 years in Canada).

Retention periods for data held by PostHog are governed by our configuration of their service and their own data retention policies.

8. Your Rights

8.1 All Users

Regardless of your location, you may:

• Request access to the personal information we hold about you.
• Request correction of inaccurate information.
• Request deletion of your personal information.
• Withdraw consent for any processing based on consent.

To exercise any of these rights, contact us at apps@xpmind.com. We will respond within 30 days.

8.2 Canadian Users (PIPEDA)

Under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), you have the right to:

• Access your personal information held by us.
• Challenge the accuracy and completeness of your information and have it amended.
• Withdraw consent for the collection, use, or disclosure of your information, subject to legal or contractual restrictions.
• File a complaint with the Office of the Privacy Commissioner of Canada if you believe we have not handled your information appropriately.

8.3 EEA/UK Users (GDPR)

Under the General Data Protection Regulation, you additionally have the right to:

• Data portability: Receive your data in a structured, commonly used, machine-readable format.
• Restriction of processing: Request that we limit how we use your data.
• Object to processing: Object to processing based on legitimate interests.
• Lodge a complaint: With your local data protection authority.

If you wish to exercise these rights, contact us at apps@xpmind.com.

8.4 California Users (CCPA/CPRA)

Under the California Consumer Privacy Act and California Privacy Rights Act, California residents have the right to:

• Know what personal information we collect, use, and disclose.
• Delete your personal information.
• Opt out of the sale or sharing of your personal information. Note: we do not sell your personal information.
• Non-discrimination: We will not discriminate against you for exercising your rights.

To submit a request, contact us at apps@xpmind.com.

8.5 Brazilian Users (LGPD)

Under Brazil's Lei Geral de Proteção de Dados (LGPD), you have the right to confirmation of processing, access, correction, anonymization, portability, deletion, and information about third parties with whom your data is shared. To exercise these rights, contact us at apps@xpmind.com.

9. Children's Privacy

The App is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13.

If we become aware that we have inadvertently collected personal information from a child under 13, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at apps@xpmind.com so that we can take appropriate action.

10. Security

We implement commercially reasonable technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS/SSL) and reliance on reputable third-party service providers with their own security programs.

No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

11. Links to Other Services

The App may contain links to third-party websites or services that are not owned or controlled by XpMind Inc. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party services. We encourage you to review the privacy policy of any third-party service you access.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will:

• Update the "Last Updated" date at the top of this policy.
• Post the revised policy within the App or on our website.
• For material changes, notify you through an in-app notification.

Your continued use of the App after any changes indicates your acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at:

XpMind Inc.
Email: apps@xpmind.com

For GDPR-related inquiries, you may also contact your local data protection authority.

For Canadian privacy complaints, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.