MentationPrivacy Policy
Effective date: July 9, 2026 Last updated: July 9, 2026
1. Introduction
This Privacy Policy explains how AIVORY COMPANY LIMITED ("we", "us", "our") collects, uses, and shares information when you use the Mentation mobile application (the "App"). We are the data controller for the personal data described here.
By using the App, you agree to this Policy. If you do not agree, do not use the App.
2. Eligibility
Mentation is intended for users aged 13 and older. If you are under 18, you may use the App only with the consent of a parent or legal guardian. We do not knowingly collect personal data from children under 13. See §11.
3. How the App is built and Data Storage
Mentation is a brain-training app offering cognitive exercises, training games, and self-assessment tests.
- Guest mode (no account): You can use the app freely without signing in. In Guest mode, your results are stored only on your device.
- Signed-in mode: If you choose to sign in, your results and settings are securely synced to our cloud servers so you never lose your data across devices or reinstalls.
Sign-in is optional and only prompted when you want to save your data. We practice data minimization: we collect no phone number, no password, no contacts, no location, and no advertising identifiers.
4. Information we collect
(a) Account information (only if you sign in)
- Sign-in is via Sign in with Apple or Sign in with Google only. The provider gives us a unique identifier, your name, and your email address (with Apple you may use "Hide My Email"; our emails are delivered through Apple's private relay). We never see or store a password.
(b) Onboarding answers
- The goals, focus areas, motivation, gender, and age range you select during onboarding, and your goal commitment. Used only to personalize your experience.
(c) Activity and results data
- Your exercise and game results (e.g. reaction times, memory scores), baselines, progress charts, daily quests, and streaks.
- Your self-assessment test results (e.g. cognitive, personality, chronotype, career-interest tests). ❗ These are not medical data and not diagnoses — they are self-assessments for educational purposes only. We use them solely to show you your own results and progress. We do not sell them, use them for advertising, or share them with third parties.
- In Guest mode, all of the above stays on your device. When you choose to sign in, all data is securely synced to our cloud servers, associated with your account.
(d) Subscription & purchase information
- Your subscription plan, status, and renewal dates, processed via Apple and Superwall. Payments are handled by Apple through App Store in-app purchase — we do not receive your payment card details.
(e) Technical, analytics & diagnostic data
- Anonymous usage events (e.g. session completed, checkout started) to operate and improve the App, and paywall/subscription interaction and conversion data via Superwall. Analytics events contain no personally identifiable information and no raw test or health-related results.
- Crash and diagnostic data via Firebase (Analytics & Crashlytics — e.g. device model, OS version, app interactions, crash/error data) to operate, secure, and improve the App.
(f) Emails we send (signed-in users only)
- We send transactional emails (welcome, trial reminders, payment confirmations/failures) to the address from your sign-in provider. Non-transactional emails include a working unsubscribe link. Guests receive no emails.
5. Third-party services (processors)
We share limited data with the following providers strictly to operate the App. Each processes data under its own privacy policy:
| Provider | Purpose | Policy |
|---|---|---|
| Apple | App Store, in-app purchases & subscription billing, Sign in with Apple | apple.com/legal/privacy |
| Sign in with Google | policies.google.com/privacy | |
| Superwall | Paywall presentation, subscription management & conversion analytics | superwall.com/privacy |
| Google (Firebase) | Analytics, Crashlytics (crash reporting) | firebase.google.com/support/privacy |
We do not use advertising, attribution, or cross-app tracking SDKs. We are not responsible for the independent practices of these providers; review their policies.
6. How we use your information & legal bases (GDPR)
| Purpose | Examples | Legal basis (GDPR) |
|---|---|---|
| Provide the service | accounts, sync, exercises, results, quests/streaks | Performance of a contract |
| Personalization | tailor content to your goals and answers | Contract / legitimate interests |
| Manage subscriptions | checkout, trial, renewals, restore access | Contract |
| Transactional emails | trial reminders, payment confirmations | Contract / legal obligation |
| Other emails | tips, feature news (with unsubscribe) | Legitimate interests / consent |
| Analytics & improvement | anonymous usage, performance, errors | Legitimate interests |
| Security & fraud prevention | protect accounts and subscription integrity | Legitimate interests / legal obligation |
7. We do not sell your personal information
We do not sell your personal information for money, and we do not use your data for third-party advertising.
8. Data retention & deletion
- Guest data stays on your device; remove it by deleting the App from your device.
- Account data is kept while your account is active. You can use Delete Account (in Profile) to permanently delete your entire account together with your measurement history, baselines, quests, and streaks, from your device and our servers; this cannot be undone.
- You can also request account deletion by emailing us (§14). Losing or cancelling a subscription does not delete your data.
- Data held by our processors (e.g. billing records, invoices) is retained according to their policies and our legal, accounting, and security obligations.
9. International data transfers
Your data may be processed in countries where we and our service providers operate, which may be outside your country. Where required, we rely on appropriate safeguards (e.g. Standard Contractual Clauses) for such transfers.
10. Your privacy rights & how to exercise them
- In the App: use Delete Account to permanently erase your account and its data, and Sign Out to end your session. You can manage or revoke Sign in with Apple/Google in your Apple ID or Google account settings.
- Requests: to access, correct, or delete data we or our processors hold, email [email protected].
- If you are in the EU/EEA/UK (GDPR): you have the right to access, rectify, erase, restrict, and port your data, to object to processing, and to withdraw consent at any time. You may lodge a complaint with your local data protection authority.
- If you are in California (CCPA/CPRA): you have the right to know, delete, and correct your personal information. We do not sell or "share" your personal information for cross-context behavioral advertising. You will not be discriminated against for exercising your rights.
11. Children
Mentation is not directed to children under 13, and we do not knowingly collect personal data from them. Users under 18 should use the App with parental consent. If you believe a child under 13 has provided us data, contact [email protected] and we will delete it.
12. Security
We use industry-standard measures (encryption in transit, platform security controls). No method is 100% secure; we cannot guarantee absolute security.
13. Changes to this Policy
We may update this Policy. Material changes will be notified in-app or on https://aivoryvn.com. Continued use after changes means you accept the updated Policy.
14. Contact
AIVORY COMPANY LIMITED Privacy & Support: [email protected] · Website: https://aivoryvn.com