1. Introduction and Data Controller

Lake Analytics Ltd ("NovaMynd", "we", "us") is committed to protecting your personal data in compliance with the UK Data Protection Act and the EU General Data Protection Regulation (GDPR).

Data Controller:
Lake Analytics Ltd.
Level 1, Suite 4, Birkirkara Road,
Birkirkara BKR9049, Malta
Email: info@novamynd.com

2. Data We Collect

In addition to basic account information (Name, Email, Phone), NovaMynd v2 collects the following specific data types:

• 2.1 Professional & Billing Data: To comply with international tax regulations and facilitate the "Space + Energy" model, we collect full billing addresses and VAT/GST identifiers where applicable.
• 2.2 EEG & Performance Data: We process EEG-related data and system usage metrics to provide feedback, recommendations, and brain training insights. This data is processed on a contractual basis to deliver the core service.
• 2.3 Creator & Marketplace Data: For users in our Creator Economy, we collect payment disbursement information (e.g., Stripe Connect details) to facilitate MyndPoints cash-outs and tax reporting.
• 2.4 Media & Storage: We host media files uploaded by practitioners. While we do not actively monitor this content, it is stored on our secure cloud infrastructure and subject to the storage limits of your subscription tier.

3. Lawful Basis for Processing

• Contractual Necessity: To provide the brain training platform, manage your "Space" (subscription), and process "Energy" (NovaUnit) transactions.
• Legal Obligation: For tax compliance and financial reporting related to marketplace earnings.
• Legitimate Interests: To improve our neuro-acoustic algorithms and platform security.

4. Data Sharing and Third Parties

We share data with trusted partners only when necessary:

• Payment Processors (Stripe): For subscriptions, NovaUnit purchases, and Creator payouts
• Cloud Infrastructure: For secure data storage and media hosting.
• EEG Hardware Partners: To ensure compatibility with supported sensors.

5. Data Retention

• Active Accounts: Data is retained for the duration of your subscription.
• Closed Accounts: We retain financial and contractual records for six (6) years following account closure for legal and tax compliance.
• EEG Data: Users may request the deletion of their EEG history at any time via the dashboard.

6. Your Rights (GDPR/UK DPA)

You have the right to:

• Access: Request a copy of your personal data.
• Rectification: Correct inaccurate data.
• Erasure: Request the "Right to be Forgotten."
• Portability: Request a machine-readable export of your data.
• Object: Opt-out of direct marketing at any time.

7. International Transfers

As a Malta-based entity, your data is primarily stored within the EU. Where third-party services require transfers outside the EEA, we ensure Standard Contractual Clauses (SCCs) are in place to maintain data protection standards.

8. Security

We implement industry-standard encryption and security protocols to protect your data. However, no system is 100% secure, and users are responsible for maintaining the confidentiality of their account credentials.

9. Changes to this Policy

We may update this policy to reflect changes in our services or legal requirements. Material changes will be communicated via email or platform notification.

10. Cookies

NovaMynd uses cookies to make our website work properly and to help us understand how you use it. Cookies we use:

• Necessary cookies: Essential for site security and core functionality. These cannot be disabled.
• Preferences cookies: Used to remember your site preferences, such as currency, to provide a consistent experience across visits.
• Analytics cookies: Provided by Google Analytics, these help us measure site performance and usage patterns.

Preferences and analytics cookies are only enabled if you select "Accept All" on our consent banner.

You can manage your choices or withdraw consent at any time by clicking here .