Privacy Policy

Effective Date: Aug 14, 2025 

This Privacy Policy explains how Mirror 360 (the “Company”, "we," "us," or "our") collects, uses, discloses, and protects the personal information of the user ("you" or "your") when using My Mirror 360 application (the "App" or “Platform”). We are committed to respecting your privacy and protecting your personal information. By using the App, you consent to the collection and processing of your personal information as described in this Privacy Policy.

1. Information We Collect

1.1  Personal Information: We may collect various types of personal information from you, including but not limited to:

·  Contact information (such as name, email address, and phone number) of you and your reflectors

·  Employment-related information (such as job title, department, company name, and employment date)

·  User-generated content, such as feedback, comments, and ratings.

1.2  Usage Information: We may automatically collect certain information about how you interact with and use our Services, including:

·  Login data (such as IP addresses, browser type, and operating system)

·  Device information (such as device type and unique device identifiers)

·  Usage metrics (such as pages visited, features used, and time spent on the Services)

2. How We Use Your Information

2.1 Provide and Improve Services: We use your personal information to deliver and enhance our services, personalize your user experience, and optimize our offerings.

2.2 Communication: We may use your contact information to send you administrative updates, service announcements, and promotional materials related to our Services. You can opt-out of receiving marketing communications at any time by unsubscribing to such communications using the links within.

2.3 Aggregated Data: We may aggregate and anonymize your personal information to generate statistical and analytical insights that help us improve our services and develop new features.

3.    Legal Basis for Processing

We process your personal information based on your consent and to fulfill our obligations in providing the Services. By using the App, you acknowledge that the processing of your personal information is necessary for the performance of the obligations between you and the Company, and for the purposes outlined in this Privacy Policy.

4. How We Share Your Information

4.1 Service Providers: We may engage trusted third-party service providers (such as cloud service providers) to assist us in delivering and improving our Services. These providers may have access to your personal information solely for the purpose of performing specific tasks on our behalf and are obligated to protect it and comply with applicable privacy regulations.

4.2 Compliance with Law: We may disclose your personal information if required to do so by law or if we believe such disclosure is necessary to comply with applicable legal obligations, protect our rights, investigate fraud, or respond to a government request.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your information, we will securely dispose of it in accordance with standard industry practices.

6. Security Measures

We are fully committed to ensuring the security of your data. Our application operates on a Kubernetes-based cloud infrastructure and all data processed and stored by our systems is protected using some of the latest and rigorous security protocols. These measures include, but are not limited to, secure server environments, encryption of sensitive data, and strict access controls. Please note that while we strive to protect your information to the best of our ability, no method of electronic storage can guarantee its absolute security.

7.     Data Transfer and International Users

Mirror 360 is a globally accessible platform, and your personal information may be transferred to and stored on servers located outside of your country or region, including servers located in the United States. By using the App, you acknowledge and consent to the transfer of your personal information to these servers. The data protection laws and regulations in the country or region where these servers are located may differ from those in your country of residence.

The Company takes appropriate measures to ensure that your personal information receives an adequate level of protection when it is transferred internationally. We implement appropriate safeguards and rely on legal mechanisms such as Standard Contractual Clauses, where necessary, to protect your personal information and comply with applicable data protection laws.

If you are accessing or using the App from the European Union or other regions with laws governing data collection and use, please note that you are consenting to the transfer of your personal information to the United States and other locations as necessary to provide our services to you. By providing your personal information, you consent to any transfer and processing in accordance with this Privacy Policy.

7. Your Choices and Rights

You have the right to access, correct, update, and delete your personal information. You can exercise these rights by contacting us using the contact information provided at the end of this Privacy Policy. Please note that we may need to verify your identity before processing certain requests.

8. Cookies and Tracking

We may use cookies and similar tracking technologies on the App to enhance your user experience and improve the functionality of our Services. These cookies help us recognize you and provide you with a more personalized experience. We use cookies for various purposes, including authentication, preferences, analytics, security, and advertising. 

Some cookies are set by third-party service providers, and you have the option to accept or decline cookies through your browser settings. Please note that disabling cookies may affect the functionality of the App. 

Additionally, we may use other tracking technologies like web beacons and pixels to collect information about your interactions with the App and improve our Services. The App does not currently respond to "Do Not Track" signals sent by your browser. For more details about our data collection and usage practices, please refer to our full Privacy Policy.

9. GDPR and CCPA Compliance

If you are located in the European Union or any other region with laws governing data protection, please be aware that the App is committed to complying with the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) as applicable.

• 9.1. Lawful Basis for Processing: We will only collect, use, and process your personal information where we have a lawful basis to do so. This may include situations where the processing is necessary to perform the Services to you, where we have obtained your consent, where the processing is necessary for our legitimate interests or the legitimate interests of third parties, or where we are required to do so to comply with legal obligations.
  

• 9.2.Your Rights under the GDPR: If you are located in the European Union, you have certain rights under the GDPR with respect to your personal information, including the right to:

• Access the personal information we hold about you and request details about how we process it.
• Rectify any inaccurate personal information we may have about you.
• Erase your personal information in certain circumstances.
• Restrict or object to the processing of your personal information.
• Data portability, which allows you to receive your personal information in a structured, commonly used, and machine-readable format.
  

• 9.3. Retention Period: We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and the Term of Use as required by law, or as otherwise communicated to you.
  

• 9.4.California Residents' Privacy Rights: If you are a resident of California, you may have additional privacy rights under the CCPA. You have the right to know what personal information we have collected about you and request its deletion, subject to certain exceptions. You may also opt-out of the sale of your personal information. To exercise your rights under the CCPA or for more information about our data practices and how to submit a verifiable consumer request, please contact us. Please note that we may need to verify your identity before processing your request. Additionally, we do not discriminate against you for exercising your CCPA rights.

10. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy from time to time. Any changes will be effective upon posting the revised policy. You will be notified of any material changes to the privacy policy, either through email or by displaying a prominent notice within the app.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy, you can contact us at privacy@mirror360.org