🔐 Privacy Policy

ℹ️ What We Are

FaceofMind is an AI-powered emotional wellness tool designed to help users increase mental health awareness, track moods, and receive non-clinical insights. We do not provide medical diagnoses or treatment.

🏢 Data Controller (Philippines DPA)

For purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), the Personal Information Controller is:

📥 Data We Collect

We aim to minimize data collection, but may collect:

Camera frames for emotion analysis and voice input for consult features are processed only when you grant permission in the app. Sensitive personal information (including emotional and mental wellness-related data) requires your explicit consent at signup and through in-app privacy controls.

⚖️ Legal Basis for Processing

Under the Philippine Data Privacy Act, we process personal data based on:

• Consent — you agree to our Terms and Privacy Policy and grant permissions for emotion, mood, and wellness features.
• Contract — processing is necessary to provide the app features you request.
• Legal obligation — where required to comply with law, court orders, or regulator requests.
• Legitimate interests — security, fraud prevention, and service improvement, balanced against your rights.

🎯 Why We Collect Data

• To provide emotion insights, journaling support, and mood tracking features
• To maintain app performance, reliability, and feature improvements
• To protect account security, prevent abuse, and keep users safe

🔐 How Your Data is Handled

In the event of a data breach, we will notify affected users in accordance with applicable laws.

🤝 Data Sharing

We do not share personal data with third parties except as required to provide the service, comply with legal obligations, or protect users.

🧩 Third-Party Services

We use trusted processors to operate FaceofMind, including cloud hosting (Google Cloud Platform), AI and emotion analysis (including AWS), payment processing (Stripe), authentication, and analytics. They process data only for approved service purposes under contractual safeguards.

We do not sell personal data. We do not put clinical or wellness content in payment metadata.

🌏 International Data Transfers

Your data may be processed on servers in the Philippines, the United States, Singapore, and other regions where our cloud providers operate. Where personal data is transferred outside the Philippines, we implement appropriate safeguards under the Data Privacy Act, including data processing agreements and standard contractual clauses with processors.

🤖 Automated Decision-Making & AI

Our AI models generate mood insights, emotion estimates, and session summaries from your inputs. These outputs are non-clinical and for self-reflection only — not diagnosis or treatment. You may object to certain automated processing and control sharing through in-app privacy settings. Licensed professionals remain solely responsible for clinical decisions.

✅ Data Safety Disclosure

• We collect and process relevant user data to provide core app features
• Images and user content may be processed on secure servers
• We may use trusted third-party processors (for example cloud and AI services) only to operate the service
• Data is protected with encryption in transit and at rest
• Users can request deletion of eligible data
• We do not sell personal data

🚫 No Surveillance

FaceofMind never secretly records. Camera/mic access is explicitly requested and controlled by you.

🗂️ Data Retention

We retain data only as long as necessary for the purposes above, unless a longer period is required by law:

• Account information — until you request deletion or the account is closed.
• Mood entries and emotion-related wellness data — up to 24 months after last activity, or sooner upon deletion request.
• Session transcripts and consult content — up to 24 months, or until consent is withdrawn where applicable.
• Device and usage logs — up to 12 months for security and reliability.

You may request deletion at any time; we will process requests in accordance with applicable law.

🧒 Children's Privacy

FaceofMind is not intended for children under age 13 (or the minimum age required in your country). For users under 18, parental or guardian consent is required where applicable.

⚖️ Jurisdiction

This Privacy Policy is governed by the laws of the Republic of the Philippines, including the Data Privacy Act of 2012 (RA 10173), and other applicable data protection laws in jurisdictions where FaceofMind operates.

🛡️ Your Rights

You have the right to:

• Access your personal data
• Request data correction or deletion
• Export your data
• Withdraw consent at any time
• Contact us with privacy concerns

🇪🇺 Additional Information for Users in the European Union (GDPR)

If you are in the European Economic Area (EEA) or United Kingdom, the following applies in addition to the sections above, under the General Data Protection Regulation (GDPR) and UK GDPR where applicable.

• Legal bases include consent, contract performance, legal obligation, and legitimate interests (balanced against your rights).
• You have the right to access, rectify, erase, restrict, port, and object to processing of your personal data.
• You may withdraw consent at any time without affecting prior lawful processing.
• You may lodge a complaint with your local supervisory authority.
• International transfers use appropriate safeguards (e.g., standard contractual clauses) as described in International Data Transfers above.

Eligible business customers in the EU may request a Data Processing Agreement via our DPA page or legal@faceofmind.com.

🇺🇸 Additional Information for United States Users (HIPAA)

FaceofMind is a wellness and awareness tool, not a substitute for professional medical care. When we support HIPAA-regulated workflows for covered entities, we may provide a Business Associate Agreement and a Notice of Privacy Practices for patients. See our BAA information page for enterprise requests. A dedicated Notice of Privacy Practices will be published before US HIPAA patient workflows go live.

🇵🇭 Additional Information for Users in the Philippines

This policy complies with the Data Privacy Act of 2012 (Republic Act No. 10173). Sensitive personal information (including mental wellness-related data) is processed with your consent.

📢 Right to Complain (NPC — Philippines)

If you believe your data privacy rights have been violated, you may contact us first at dpo@faceofmind.com. You also have the right to file a complaint with the National Privacy Commission (NPC):

📞 Contact Us

Data Protection Officer: dpo@faceofmind.com
Privacy requests: privacy@faceofmind.com
General inquiries: info@faceofmind.com
Security reports: security@faceofmind.com

🔄 Updates to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes through the app or via email if you've provided one.