Privacy Policy

Collection and Processing of Personal Data

We may collect and process the following categories of personal data:

Information about the Account Holder

• Name;
• Email address;
• Account login and security information;
• Language, timezone and notification preferences;
• Communications with our support team; and
• Feedback or survey responses that you choose to provide.

Information about Your Child

• Name or nickname;
• Date of birth;
• Sex or gender;
• Your relationship to the child;
• Developmental milestone records;
• Developmental screening questionnaire responses; and
• Observation notes entered through the App.

Information relating to your child's physical, behavioural or developmental condition may constitute sensitive personal data.

By providing personal data about a child, you confirm that you are the child's parent, legal guardian or otherwise have lawful authority to provide and manage that information.

Information Collected Automatically

We may also collect:

• Device model;
• Operating system and app version;
• Device identifiers;
• App usage information;
• Session and navigation information;
• Crash logs and diagnostic information;
• Approximate location derived from your device settings or IP address; and
• Cookies or similar technologies used through our website or in-app web pages.

Sources of Information

Your personal data may be obtained from:

• Information submitted by you when creating or managing an account;
• Information entered by you while using the App;
• Communications with our support team;
• Cookies and similar technologies;
• Device, usage and diagnostic information generated when you use the App; and
• Other information you voluntarily provide to us.

Please ensure that the personal data you provide is accurate and up to date.

Purpose of Processing Personal Data

We may process personal data for the following purposes:

• To create and manage your account;
• To verify your identity and maintain account security;
• To provide the App's milestone, screening and observation features;
• To present age-appropriate content based on your child's date of birth;
• To help you organise information for pediatric or physician visits;
• To communicate with you about the App and your account;
• To respond to enquiries, complaints and support requests;
• To maintain and improve the performance of the App;
• To diagnose technical issues and correct errors;
• To prevent fraud, misuse and unauthorised access;
• To comply with legal, regulatory or court requirements;
• To produce anonymised or aggregated reports and statistics;
• To conduct analytics and product improvement where permitted; and
• For any other purpose directly related to the purposes above.

We do not sell your personal data or your child's personal data.

We do not use your child's identifiable developmental, screening or observation information for third-party advertising.

Automated Processing

Evie Mind currently uses simple rules-based processing to provide relevant App content. For example, your child's date of birth may be used to determine which age-appropriate milestone checklists or screening questionnaires are displayed.

We do not currently use artificial intelligence or machine-learning models to analyse, summarise or generate content from your child's developmental, screening or observation data.

If we introduce an artificial intelligence or automated summarisation feature in the future, we will:

• Update this Privacy Policy; and
• Not use your child's identifiable personal data to train general-purpose artificial intelligence models;

Disclosure of Personal Data

Personal data will generally be kept confidential. We may disclose personal data to:

• Our related companies, or subsidiaries;
• Cloud hosting and data-storage providers;
• Analytics, crash-reporting and technical service providers;
• Customer-support service providers;
• Professional advisers, including lawyers, auditors and insurers;
• Contractors and vendors that assist us in operating the App;
• Regulators, law-enforcement agencies, government authorities or courts where required by law;
• A successor entity in connection with a merger, acquisition, restructuring or sale of assets; and
• Any other party where you have authorised the disclosure.

Third-party service providers that process personal data on our behalf are required to protect the information and use it only for the services they provide to us.

We do not disclose your child's identifiable developmental, screening or observation data to advertising networks or social-media platforms for advertising purposes.

Cross-Border Transfer and Storage

Your personal data may be stored or processed outside Malaysia where our service providers or technical infrastructure are located.

Where personal data is transferred outside Malaysia, we will take reasonable steps to ensure that it receives an appropriate level of protection in accordance with applicable data-protection requirements.

These steps may include contractual safeguards, appropriate security measures, reliance on applicable legal exceptions or obtaining consent where required.

Data Retention

We retain personal data only for as long as it is reasonably necessary for the purposes described in this Privacy Policy or as required by law.

Account information will generally be retained while your account remains active and for a reasonable period after account closure.

Your child's profile, milestone, screening and observation data will generally be retained while your account remains active. When you delete your account or request deletion, we will take reasonable steps to delete or permanently anonymise the information, unless it must be retained for legal, security or dispute-resolution purposes.

Consent records, support communications, security logs and other operational records may be retained for a reasonable period where necessary to demonstrate compliance, resolve disputes, prevent fraud or meet legal obligations.

When personal data is no longer required, we will take reasonable steps to securely delete, destroy or permanently anonymise it.

Security of Personal Data

We implement reasonable technical and organisational measures to protect personal data against:

• Loss;
• Misuse;
• Unauthorised access;
• Unauthorised disclosure;
• Alteration; and
• Destruction.

These measures may include encryption, access controls, account-security measures, staff confidentiality obligations, system monitoring and security testing.

No method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for protecting access to your device.

Data Breach Notification

If a personal data breach occurs, we will assess the incident and take appropriate steps in accordance with applicable law.

Where notification is legally required, we will notify the relevant authority and affected individuals within the applicable timeframes.

Your Rights of Access and Correction

Subject to applicable law, you may:

• Request access to personal data held about you or your child;
• Request correction of inaccurate, incomplete or outdated personal data;
• Withdraw consent previously provided;
• Request deletion of personal data where applicable;
• Request a copy or export of personal data where available;
• Object to direct-marketing communications; and
• Submit a complaint regarding our handling of personal data.

We may need to verify your identity or your authority to act for the child before processing a request.

We may refuse or limit a request where permitted or required by law.

Withdrawing consent may affect our ability to provide certain features or may require the closure of your account.

Children and Minors

An Evie Mind account may only be created and managed by a person who is at least 18 years old and who is the child's parent, legal guardian or otherwise has lawful authority to manage the child's information.

Children do not create their own accounts or directly submit information to Evie Mind.

If you believe that a child's personal data has been provided without proper authority or consent, please contact us. We will investigate and take appropriate action, which may include deleting the information.

Cookies and Similar Technologies

Our website and in-app web pages may use cookies, software development kits and similar technologies to:

• Keep services functioning;
• Maintain security;
• Remember preferences;
• Understand general usage patterns;
• Identify technical issues; and
• Improve performance.

You may manage browser cookies through your browser settings. Certain features may not function properly if cookies or similar technologies are disabled.

We do not use cookies or tracking technologies for third-party behavioural advertising.

Consent

By creating an account or submitting personal data, you acknowledge the collection and processing of personal data as described in this Privacy Policy.

Where required, we will request separate consent before processing sensitive personal data or enabling optional features.

You may withdraw your consent by using the available in-app privacy controls or by contacting us. Withdrawal will not affect processing that occurred lawfully before consent was withdrawn.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the App, our practices or applicable law.

Where changes are material, we will notify you through the App, by email or through another appropriate method. Where required, we will request fresh consent before applying a material change to sensitive personal data.

The effective date displayed at the beginning of this Privacy Policy indicates when it was last updated.

Privacy Policies of Other Services

The App may contain links to third-party websites, applications or services.

This Privacy Policy applies only to Evie Mind. You should review the privacy policies of third-party services before providing personal data to them.

Contact Us

If you have questions, requests, complaints or concerns regarding this Privacy Policy or the handling of personal data, please contact:

Transcend Psychology Centre Sdn Bhd
Petaling Jaya, Malaysia

Email: info@transcendpsychology.com