Privacy Policy

1. Introduction

Envisioning LLC-FZ ("Company", "we", "us", or "our") is a Free Zone limited liability company registered in the Emirate of Dubai, United Arab Emirates. We are committed to protecting your privacy and handling your personal data responsibly.

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, and what rights you have in relation to your data when you use Finerminds — a community and networking platform that enables members to connect, collaborate, attend events, and grow together ("Platform" or "Services").

Finerminds is operated by Envisioning LLC-FZ. Access to the platform may be granted through partner organisations that license our technology to provide community experiences for their users. Where a partner organisation facilitates your access, certain account or enrollment information may be shared with us as described in this Policy.

This Policy is designed to comply with applicable privacy and data protection laws, including:

• EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679)
• UK General Data Protection Regulation (UK GDPR)
• U.S. State Privacy Laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) and other applicable state laws
• UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL)

Please read this Policy carefully before using our Services.

2. Data Controller

Envisioning LLC-FZ is the data controller responsible for your personal data processed through Finerminds. We determine the purposes and means of processing your personal data.

We aim to respond to all privacy-related enquiries within 30 days of receipt, or within the shorter timeframe required by applicable law.

3. Information We Collect

We collect different categories of data depending on how you access and use Finerminds, which features you use, and the consents you provide. Rows marked ‘Your consent’ are never collected by default — they only apply if you actively enable that feature.

3.1 Consent

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent, email us at privacy@envisioning.group with the subject line "Withdraw Consent" or use the toggle controls in your account settings.

3.2 Mobile Application Data

When you use the Finerminds mobile application, we may collect additional data depending on the device permissions you grant. We only request permissions that are necessary to deliver a specific feature of the application. All permissions are optional except where noted, and can be granted or revoked at any time through your device's operating system settings.

Revoking a permission will disable the relevant feature but will not delete any data you have already chosen to share with the Platform. You will not lose access to unrelated Platform features for declining any optional permission.

Mobile Analytics and Diagnostics: We may collect technical and diagnostic data through the mobile application using mobile analytics SDKs ("software development kits"). This data may include crash logs, error reports, app performance metrics, operating system version, app version, device model, and — where permitted by applicable law and your device privacy settings — advertising identifiers. This data is used solely to monitor application stability, diagnose technical issues, and improve application performance. Where required by applicable law or your device's privacy framework (including Apple's App Tracking Transparency ("ATT") framework and Android's advertising identifier settings), collection of advertising identifiers and cross-app tracking will only occur with your explicit permission. We will respect any system-level privacy signal you have enabled, including opt-outs from ad tracking.

Third-Party App Store Data: When you download or update the Finerminds application through the Apple App Store or Google Play Store, those platforms may independently collect data about your download activity and device in accordance with their own privacy policies. That data collection is outside our control and is not governed by this Privacy Policy. We encourage you to review Apple's and Google's privacy policies separately.

4. How We Use Your Information

We use your personal data only for the purposes described in this Privacy Policy, including:

4.1 We Do not Sell your Personal Information

Finerminds does not sell your personal information to third parties for monetary compensation.

We do not share your personal information with third parties for their own independent advertising or marketing purposes without your consent.

Where we use service providers, analytics providers, hosting partners, payment processors, communication tools, or AI service providers to operate and improve the platform, they process personal information only on our behalf and under appropriate contractual and security safeguards.

Any sharing of personal information across Envision products will occur only where clearly disclosed and, where required by applicable law, based on your consent.

Users may exercise their applicable privacy rights, including rights relating to access, correction, deletion, objection, restriction, portability, or withdrawal of consent, by contacting us using the details provided in this Privacy Policy.

5. Community Visibility and Your Content

Finerminds is a community platform. Information you share — including your profile, posts, messages, event activity, and resources — may be visible to other members depending on your privacy settings and where you share it.

Groups & Subgroups privacy tiers: Groups and subgroups operate under three tiers: Public (discoverable and open to join), Private (discoverable, invite-only — the default), and Secret (not discoverable, invite-only). Content shared in a group is visible to members of that group according to these settings.

Direct Messages: 1:1 direct messages are private between you and the recipient and are not visible to other members or admins in normal circumstances, except where required for safety, legal obligations, or enforcement of our Community Guidelines.

Data isolation: Where you participate in multiple community instances on Finerminds, your data and interactions in one instance are not shared with or visible in another instance without your consent, except where you hold active access to both.

6. Who We Share Your Information With

We do not sell or rent your personal data. We share your information only in the circumstances described below.

6.1 Service Providers (Data Processors)

We share data with the service providers listed below, each acting as a data processor on our behalf under a Data Processing Agreement (DPA) or equivalent contractual obligations.

6.2 Partner Organisations

Where you access Finerminds through a partner organisation that licenses our platform, that organisation may share limited account and enrollment information with us to enable your access. This is disclosed clearly during onboarding. The partner organisation and Envisioning LLC-FZ maintain a Data Processing Agreement governing this arrangement. Your use of Finerminds is governed by this Privacy Policy in addition to any applicable terms of the partner organisation.

6.3 Legal and Regulatory Authorities

We may disclose your personal data if required by law, regulation, legal process, or a valid governmental request, including court orders and requests from law enforcement. We may also disclose information where necessary to protect the rights, property, or safety of our users or others, or to prevent fraud or abuse.

6.4 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of assets, your data may be transferred to the acquiring entity. We will notify you by email before your data becomes subject to a materially different privacy policy.

6.5 Other Community Members

Your profile information and community activity are visible to other members within your network and group, subject to the privacy tier settings described in Section 5. We do not share your personal data with other members beyond what you choose to make visible through your profile and community participation.

7. External Profile Import

Finerminds offers an optional feature that allows you to import selected profile information from a third-party professional network to pre-populate your Finerminds profile. This feature:

• Is entirely optional and requires your explicit consent before any data is imported.
• Only imports the specific fields you authorise via the third-party platform's authorisation flow.
• Allows you to review and edit all imported information before it is saved to your profile.
• Is governed by the third-party platform's terms of service, including restrictions on how profile data may be stored and used.
• Does not grant Finerminds ongoing access to your external profile — import is a one-time transfer.

We store only the profile fields you choose to import and use them solely to populate your Finerminds profile. We do not share imported data with third parties beyond what is described in Section 6.

8. AI Features

8.1 AI-Assisted Profile and Content Tools

Finerminds includes AI-powered tools to help you set up your profile and organise content. These include:

• Profile bio generation — AI drafts a bio based on your profile fields. You review and edit before saving.
• Auto tag creation — AI suggests tags for resources and groups to assist discovery.
• Resource URL analysis — AI analyses shared URLs to auto-fill titles and descriptions.
• Event cover image suggestions — AI-assisted image suggestions for event cover images.

No AI-generated content is published without your explicit action. You retain full control to review, edit, or discard any suggestion.

8.2 AI Personalisation (Consent-Based)

Finerminds may use AI-powered matching and personalisation features that analyse your interests, activity patterns, and engagement behaviour to suggest relevant connections and content. These features:

• Are only activated if you enable the AI Personalisation toggle in your account settings.
• Are clearly described at the point of consent, including what data is used.
• Are reversible — you may disable the toggle at any time.

8.3 AI Moderation

Finerminds uses and may expand AI-assisted content moderation to help maintain a safe and respectful community. Where AI moderation tools are active or introduced:

• AI is used to flag potentially violating content for human review — not to take automated final decisions.
• A human review layer and an appeals process are available to users.
• Users are informed transparently that AI is involved in moderation decisions.

We do not use automated processing to make decisions that produce legal or similarly significant effects without appropriate safeguards and, where required, your consent.

9. International Data Transfers

Envisioning LLC-FZ is based in Dubai, UAE. Your personal data may be transferred to and processed in the United Arab Emirates, the United States, or other countries where our service providers (including Google Cloud Platform and GetStream) operate infrastructure.

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, these countries may not provide an equivalent level of data protection. We protect your data by relying on:

• Standard Contractual Clauses (SCCs) approved by the European Commission, incorporated into our agreements with service providers.
• Supplementary technical measures such as encryption of data in transit (TLS/HTTPS) and at rest.

You may request a copy of the relevant safeguards by contacting privacy@envisioning.group.

10. Data Retention

We retain your personal data only for as long as necessary to provide the Service and fulfil the purposes described in this Policy, or as required by law. When we have no ongoing legitimate business need to process your information, we will either delete it or anonymise it. In particular:

• Account data is retained for the duration of your active account.
• Community content (posts, messages, resources) you have shared may persist after your account is closed where it forms part of a shared conversation or group record, unless you specifically request deletion of that content.
• Chat messages are subject to the retention settings of our messaging infrastructure provider and will be specified here as they are finalised.
• Technical and usage logs are retained for a rolling period sufficient for security and platform improvement purposes.
• Access and enrollment data received from partner organisations is retained for the duration of your access and a reasonable period thereafter for legal and audit purposes.
• Consent-based data will cease to be processed upon withdrawal of consent and will be deleted upon request.

Uninstalling the Finerminds mobile application from your device does not constitute an account deletion request and does not result in the deletion of your personal data. If you wish to delete your account and associated data, you must submit a deletion request through the platform or by contacting us at privacy@envisioning.group. Deletion is then processed in accordance with this Section.

11. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction, including:

• Encryption: Personal data is encrypted in transit using TLS/HTTPS and at rest through our cloud infrastructure provider.
• Access controls: Access to personal data is restricted on a need-to-know basis with role-based access controls and authentication requirements.
• Monitoring: We maintain logging and monitoring across our infrastructure to detect unauthorised access or anomalous activity.
• Authentication: JWT-based authentication with token refresh mechanisms and rate limiting to protect against abuse.

No method of electronic transmission or storage is completely secure. We will promptly notify affected individuals and relevant authorities in the event of a data breach, in accordance with applicable law.

12. Your Rights

12.1 Rights Under the GDPR (EEA, UK, and Switzerland)

If you are located in the EEA, UK, or Switzerland, you have the following rights:

To exercise your rights, contact us at privacy@envisioning.group.

12.2 Rights Under U.S. State Privacy Laws

If you are a resident of a U.S. state with an applicable privacy law, you may have certain rights regarding your personal information. These rights vary depending on your state of residence. The following reflects the broadest set of rights that may be available:

• Right to know / access: request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to delete: request deletion of personal information we hold about you, subject to applicable legal exceptions.
• Right to correct: request correction of inaccurate personal information.
• Right to portability: request a copy of your personal information in a portable and readily usable format.
• Right to opt out of sale and sharing: opt out of the sale of personal information and the sharing of personal information for cross-context behavioural advertising. We do not sell your personal information.
• Right to opt out of profiling: opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• Right to limit use of sensitive personal information: request limitations on how certain sensitive personal information is used.
• Right to non-discrimination: you will not be discriminated against for exercising your privacy rights.

To exercise your rights, contact us at privacy@envisioning.group. We will respond within the timeframes required by applicable law, which may be up to 45 days. You may designate an authorised agent to make a request on your behalf.

12.3 Additional Information for California Residents

We do not sell personal information for monetary consideration. We do not share personal information for cross-context behavioural advertising. We do not knowingly sell or share personal information of individuals under 18 years of age.

You may also exercise your rights by emailing us at privacy@envisioning.group or using the controls in your account settings.

12.4 Additional Rights for UAE Residents (PDPL)

Under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), you have the right to access, correct, and delete your personal data, and to withdraw consent at any time. To exercise these rights, contact us at privacy@envisioning.group.

12.5 How to Exercise Your Rights

Email: privacy@envisioning.group

Please include your full name and the email address associated with your account so we can verify your identity and locate your records. We will not require you to create an account to submit a privacy request.

13. Cookies and Tracking Technologies

Finerminds uses cookies and similar technologies to operate, secure, and improve the platform.

We use strictly necessary cookies required for core platform functionality, such as authentication, security, session management, and keeping users logged in. These cookies do not require consent where permitted by applicable law because they are essential to providing the service.

We may also use analytics and performance technologies, including third-party analytics providers such as PostHog, to understand how users interact with the platform, improve features, monitor reliability, and enhance the user experience. Depending on your location and applicable law, these technologies may be used based on your consent.

In addition to browser-based cookies and tracking technologies, the Finerminds mobile application may use third-party mobile analytics and similar technologies. These may collect technical device information, crash reports, session activity data, app performance metrics, and — where permitted — advertising identifiers. Where your device's operating system provides privacy controls that limit app tracking or advertising identifiers (such as Apple's App Tracking Transparency ("ATT") framework on iOS, or the ability to reset or opt out of advertising identifiers on Android), we will honour those preferences in accordance with applicable law. We will not use your advertising identifier for cross-app behavioural advertising without your explicit consent via your device's privacy settings.

Where required by law, users will be presented with a cookie or consent banner allowing them to manage their preferences for non-essential cookies and analytics technologies.

We may update our use of cookies and tracking technologies over time. Additional details, including categories of cookies used, retention periods, and preference management options, may be provided in a separate Cookie Policy made available through the platform.

We recognise browser-based privacy preference signals, including Global Privacy Control (GPC), where required by applicable law.

14. Children's Privacy

Finerminds is not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at privacy@envisioning.group and we will take appropriate steps to delete it. California residents under 18 who are registered users may request removal of content they have publicly posted by contacting us at the email address associated with their account.

15. Links to Other Services

Our Platform may contain links to websites or services operated by third parties. We are not responsible for the privacy practices of those third parties, and this Policy does not apply to them. We encourage you to review the privacy policy of any third-party service you visit.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, features, or applicable law. We will notify you of material changes by posting the updated Policy on the platform and updating the effective date above. Where required by law or where changes significantly affect your rights, we will provide appropriate additional notice, which may include email notification. Continued use of Finerminds after the effective date of a revised Policy constitutes your acceptance of the changes.

17. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or have a complaint about how we handle your data, please contact us:

If you are not satisfied with our response:

• EU/EEA residents may file a complaint with their local supervisory authority (list available at edpb.europa.eu).
• UK residents may contact the Information Commissioner's Office at ico.org.uk.
• California residents may contact the California Attorney General at oag.ca.gov/privacy.
• UAE residents may contact the UAE Data Office.