TERMS OF SERVICE – MINDLIGHT

Effective Date: April 29, 2026

Welcome to MindLight,

These Terms of Service («Terms», «ToS» or «Agreement») govern your access to and use of the MindLight service, including our iOS application (available via the Apple App Store), our Android application (available via Google Play), our website at mindlight.ae («Website»), and all related services, features, and content (collectively, the «Service» or «Services»).

MindLight is a digital wellbeing, self-development, and personal growth platform that provides users with tools for mood tracking, journaling, productivity management, and personalized guidance through an AI-powered chat assistant.

The Services are provided by MINDLIGHT PROJECT – FZCO, a company registered in the United Arab Emirates («Company», «we», «us», or «our»).

By accessing, downloading, installing, or using the Service, you agree to be bound by these Terms. If you do not agree to these Terms, do not use the Service.

1.ACCEPTANCE OF TERMS

1.1.Binding Agreement. These Terms constitute a legally binding agreement between you («User», «you», or «your») and the Company. By creating an account, subscribing, making a purchase, or otherwise using the Service, you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy (available at https://mindlight-app.com/privacy/), which is incorporated herein by reference.

1.2.Additional Terms. Your use of the Service may also be subject to:

Apple App Store Terms of Service (for iOS users);
Google Play Terms of Service (for Android users);
Additional terms presented at the time of purchase or feature activation;
Our Privacy Policy, Refund Policy, and other policies referenced herein.

In the event of any conflict between these Terms and platform-specific terms (Apple, Google), the platform terms shall govern to the extent required by such platform and applicable law.

1.3.Consent Mechanism. You signify your explicit acceptance of these Terms by actively checking the unchecked box «I have read and agree to the Terms of Service and Privacy Policy» during the account registration or checkout process. Passive continued use of the Website does not constitute valid consent for the processing of sensitive personal data or the execution of paid Subscriptions.

2.DEFINITIONS

«AI Chat Assistant» means the artificial intelligence-powered conversational interface within the Service that provides personalized reflections, guidance, and dialogue based on User inputs. «AI Provider» means third-party providers of artificial intelligence technology, models, or APIs (including large language models) used by the Company to power the AI Chat Assistant and analytical features.

«Commercial Use» means use of the Service or Generated Content for any purpose related to marketing, advertising, promotion, monetization, sale of products or services, brand awareness, professional consulting services for third parties, or any other activity that benefits a business, brand, or generates revenue.

«Free Plan» means access to the Service without payment, with limited features as determined by the Company.

«Generated Content» means any text, insights, life sphere diagnostics, responses from the AI Chat Assistant, or other outputs created by the Service in response to your inputs.

«Personal Use» means use for private, non-commercial purposes with no commercial benefit or revenue generation.

«Practices» means audio or text-based wellbeing sessions (such as meditations, affirmations, breathing exercises, or guided reflections) provided through the Service.

«Productivity Tools» means features allowing Users to manage tasks (to-do lists), track habits, and set short-term or long-term goals.

«Profiling» means any form of automated processing of personal data to evaluate certain personal aspects relating to a natural person, including analyzing or predicting aspects concerning performance, emotional state, behavior, personal preferences, interests, or life sphere assessments.

«Sensitive Personal Data» means personal data revealing emotional state, mental health, psychological well-being, or other categories of special personal data as defined under UAE Federal Decree-Law No. 45 of 2021 and GDPR Article 9.

«Subscription» means a paid plan providing access to premium features of the Service for a specified period (monthly or annual) with automatic renewal unless cancelled.

«Third-Party Data» means personal information (such as names or details) of individuals other than the User, which the User may mention or input into the Service (e.g., in diary entries or AI Chat).

«User Content» means any content, including text, journal entries (diary), mood ratings, queries, prompts, names, dates of birth, or other materials that you upload, input, or submit to the Service.

«Wellbeing Features» means features designed to track the User’s emotional state, including mood evaluations (1-10 scale), life sphere diagnostics, and self-reflection logs.

3.ELIGIBILITY AND AGE REQUIREMENTS

3.1.Minimum Age. The Service is intended for users aged 18 years or older (or the age of legal majority in your jurisdiction, whichever is greater). By using the Service, you represent and warrant that:

(a) You are at least 18 years of age; and

(b) You have full legal capacity to enter into this Agreement under the laws of the United Arab Emirates and/or the laws of your country of residence.

If you are under 18, you must not use the Service.

3.2.No Use by Minors. We do not knowingly collect personal information from, or allow use of the Service by, individuals under 18. If you are under 18, you must not use the Service. If we become aware that a user is under 18, we will terminate the account and delete associated data.

3.3.Parental Responsibility. If you are a parent or guardian and discover that a minor under your care has used the Service, please contact us immediately at hello@mindlight-app.com.

3.4.Legal Capacity. You represent that you have the legal capacity to enter into this Agreement and are not prohibited from using the Service under applicable law.

4.DESCRIPTION OF SERVICE

4.1.Core Functionality. MindLight provides tools for self-care and personal productivity, including but not limited to:

mood tracking: Evaluating your emotional state and viewing historical dynamics;
Diary and Journaling: Creating and storing personal text notes and reflections;
AI Chat Assistant: Engaging in dialogues on personal topics, self-development, and reflection using AI technology;
Life Management: Task tracking (To-Do), habit building, and goal setting;
Life Diagnostics: Evaluating various life spheres (e.g., career, relationships) to generate derived insights (profiling);
Practices: Audio or text-based sessions (meditations, affirmations);

4.2.AI Technology and Esoteric Methodologies. The AI Chat Assistant and certain diagnostic features are powered by proprietary and third-party large language models (LLMs). Content generation involves processing through APIs provided by third-party AI Providers. You acknowledge that AI-generated responses are probabilistic, based on pattern recognition, and may not always be accurate, logically consistent, or contextually appropriate.

5.CRITICAL DISCLAIMERS (NOT MEDICAL OR PSYCHOLOGICAL ADVICE)

PLEASE READ CAREFULLY. THIS SECTION IS A FUNDAMENTAL BASIS OF THE BARGAIN.

5.1.NOT PROFESSIONAL THERAPY

The Service, including the AI Chat Assistant, Life Diagnostics, and diary features, does NOT provide, and is not intended to provide:

Medical, psychiatric, or professional psychological advice;
Mental health diagnoses, clinical therapy, or medical treatment;
Crisis intervention or suicide prevention counseling.

5.2.INFORMATIONAL PURPOSES ONLY

All Generated Content, AI responses, and practices provided by MindLight are for informational, self-exploration, and entertainment purposes only. They are not a substitute for face-to-face professional consultations with licensed healthcare providers, therapists, or psychiatrists.

5.3.EMERGENCIES AND CRISIS SITUATIONS

The Service is NOT designed to handle emergencies. If you are experiencing a medical emergency, a mental health crisis, severe distress, or having thoughts of self-harm or suicide, DO NOT USE THE SERVICE. Immediately call your local emergency services or a dedicated crisis hotline in your country.

5.4.AI LIMITATIONS AND «HALLUCINATIONS»

You acknowledge that the AI Chat Assistant may generate content that is:

Inaccurate, unhelpful, or factually incorrect («hallucinations»);
Inappropriate for your specific emotional or mental state;
Lacking human empathy, clinical judgment, or professional context.

The Company does not endorse, verify, or assume responsibility for any advice, guidance, or statements made by the AI Chat Assistant. You are solely responsible for evaluating the safety and appropriateness of any actions you take based on the Generated Content.

6.ACCOUNT REGISTRATION AND SECURITY

6.1.Account Creation. To access certain features (including paid Subscriptions and chat history), you must create an account. You may register via:

Email address and password;

6.2.Account Information. You agree to:

Provide accurate, current, and complete information;
Update your information promptly if it changes;
Not impersonate any person or entity or misrepresent your affiliation.

6.3.Account Security. You are responsible for:

Maintaining the confidentiality of your login credentials;
All activities that occur under your account;
Notifying us immediately of any unauthorized use or security breach.

We are not liable for any loss or damage arising from your failure to protect your account credentials.

6.4.One Account Per User. You may maintain only one active account. Creating multiple accounts to circumvent limitations, obtain multiple free trials, or abuse the Service is prohibited and may result in termination.

6.5.Account Termination. We reserve the right to suspend or terminate your account at any time, with or without notice, for:

Violation of these Terms;
Fraudulent, abusive, or illegal activity;
Non-payment of fees or chargebacks;
Prolonged inactivity (e.g., no login for 2+ years);
Risk to the security, integrity, or reputation of the Service;
Legal or regulatory requirements;
Any other reason at our sole discretion.

7.SUBSCRIPTIONS, PAYMENTS, AND BILLING

7.1.Free Plan. We may offer a Free Plan with limited features, including:

Limited number of mood tracking entries per day or week;
Limited access to the AI Chat Assistant;
No chat history retention or limited diary storage;
Restricted access to certain Practices or Life Diagnostics.

7.2.Paid Subscriptions. Paid Subscriptions unlock premium features of MindLight, including:

Unlimited AI Chat Assistant access with history retention;
Unlimited diary entries and advanced Life Diagnostics;
Full access to all audio and text Practices (meditations, affirmations);
Priority customer support.

7.3.Subscription Terms. Subscriptions are offered on the following basis:

Monthly: renews every month (30 or 31 days);
Annual: renews every year;
Other terms as specified at the time of purchase.

7.4.Pricing and Currency. Subscription prices are displayed in the applicable currency at the point of purchase (USD, EUR, GBP, AED, or other currencies). Prices may vary by region, platform (web, iOS, Android), promotional offers, or payment method. All prices are inclusive or exclusive of taxes (VAT, sales tax, etc.) as required by law.

7.5.Payment Methods. Payments are processed via:

Apple App Store (for iOS);
Google Play (for Android);

You authorize us (or the applicable platform and payment processor) to charge your selected payment method.

7.6.Automatic Renewal. Unless you cancel prior to the end of the current billing period, your Subscription will automatically renew for the same duration at the then-current price. You will be charged within 24 hours prior to the start of each new billing period.

7.7.Free Trials. We may offer free trials or discounted introductory periods. Terms of the trial (duration, price, features) will be clearly displayed at the time of sign-up.

Important: If you do not cancel before the trial ends, you will be automatically charged for the full Subscription price and your Subscription will begin. Trial eligibility may be limited (e.g., one trial per user, new users only). We may verify eligibility and deny trials if we detect abuse.

7.8.Cancellation. You may cancel your Subscription at any time:

iOS: via your Apple App Store account settings;
Android: via your Google Play account settings;

Cancellation takes effect at the end of the current billing period. You will retain access until that time. No refunds are provided for partial periods. To avoid being charged for the next billing period, you must cancel your Subscription at least 24 hours before the current billing period ends.

7.9.Refunds and Right of Withdrawal Waiver. Payments are generally non-refundable except:

As strictly required by applicable law;
As set forth in our Refund Policy;
In case of a technical error on our side preventing delivery of the Service.

Refund requests must be submitted in accordance with the Refund Policy and applicable platform rules (Apple, Google).

EU and UK Consumers (Waiver of Right of Withdrawal): In accordance with Article 16(m) of Directive 2011/83/EU and UK consumer protection laws, if you are a resident of the EU or UK, you acknowledge that by checking the designated consent box during the checkout process, you explicitly provide your prior express consent for the immediate supply of digital content and waive your 14-day statutory right of withdrawal and the right to request a refund.

7.10.Taxes. You are responsible for all applicable taxes. If we are required to collect or withhold taxes, they will be added to the total amount charged at checkout.

7.11.Price Changes. We may change Subscription prices at any time. Changes will apply to future billing periods and you will be notified in advance. Your continued use of the Service after price changes take effect constitutes your acceptance of the new price.

7.12. Chargebacks and Payment Disputes. We strongly encourage you to contact our Support team to resolve any billing issues before initiating a chargeback with your bank or credit card provider. If you initiate a chargeback or dispute a valid, authorized charge without contacting us first:

We reserve the right to immediately suspend or terminate your account to prevent further fraudulent activity;
We may provide the credit card company or bank with evidence of your purchase, usage logs, and your agreement to these Terms to contest the chargeback;
You may be permanently banned from using the Service;
We may pursue legal action to recover losses and costs associated with the fraudulent chargeback.

8.USER CONTENT – UPLOADS AND INPUTS

8.1.Your User Content. You may upload, input, or submit User Content to use with the Service, including but not limited to:

Text entries in your personal diary or journal;
Mood evaluations, ratings, and life sphere diagnostic inputs;
Task descriptions, habits, and goals;
Queries, questions, and prompts provided to the AI Chat Assistant;
Optional personal details (name, date of birth) if you choose to provide them.

You retain ownership of your original User Content (to the extent it is copyrightable or otherwise protectable).

8.2.License to Company. By submitting User Content, you grant the Company a limited, non-exclusive, royalty-free, worldwide, transferable, sublicensable license to use, reproduce, process, modify, analyze, display, and store your User Content solely for the purposes of:

Providing and operating the Service (e.g., storing your diary, processing your queries, providing AI chat responses);
Generating your requested insights and life diagnostics;
Providing customer support and troubleshooting technical issues;
Ensuring security, preventing fraud, and preventing abuse of the Service;
Complying with legal obligations and protecting our rights in disputes.

8.3.No AI Training on Personal Data. We strictly protect your privacy. The Company does NOT use your identifiable personal User Content (such as personal diary entries or intimate AI chat logs) to train our general AI models, nor do we permit our third-party AI Providers to use your data to train their models. Anonymized or aggregated data (which can no longer identify you) may be retained for analytics and system improvement.

8.4.Sensitive Information & Third-Party References. By using the diary and AI Chat Assistant, you may voluntarily input highly sensitive information (e.g., emotional struggles, relationship issues, health-related thoughts) or reference third parties. You acknowledge that:

(a) You do so entirely at your own risk;

(b) You represent that you are providing this data for purely personal or household activities;

(d) We strongly advise against inputting highly confidential information (e.g., specific medical diagnoses, financial passwords, or sensitive personal data of third parties) into the AI Chat Assistant.

8.5.Representations and Warranties. By uploading User Content, you represent and warrant that:

(a) You own or have all necessary rights, licenses, consents, and permissions to upload and use the User Content;

(b) User Content does not infringe any third-party intellectual property rights, privacy rights, publicity rights, or other rights;

(d) You will not upload User Content containing:

Illegal content, malware, viruses, or harmful code;
Content depicting minors in any inappropriate or sexualized manner;
Defamatory, obscene, pornographic, violent, or hateful content;
Content that violates Section 10 (Prohibited Uses).

8.6.Prohibited User Content. You may not upload User Content that violates Section 10 (Prohibited Uses).

9.OWNERSHIP OF AI-GENERATED CONTENT

9.1.Ownership of Generated Content (Paid Subscribers). Subject to Section 9.3, if you create Generated Content (AI Chat responses, insights, diagnostic reports) using the Service while you have an active paid Subscription, the Company relinquishes any claims of ownership over your Generated Content and grants you the broadest rights permitted by applicable law to use, reproduce, and display such Generated Content.

Important Limitations:

(a) No Copyright Guarantee: You acknowledge that AI-generated content may not be eligible for copyright protection under applicable law in many jurisdictions. You should not rely on copyright protection for Generated Content;

(b) No Guarantee of Uniqueness: AI-generated content may be similar or identical to content created by other users with similar inputs;

(c) License, Not Ownership: The Company does not transfer ownership of Generated Content to you, but grants you a broad license to use it as permitted.

9.2.Generated Content (Free Users). If you create Generated Content using the Free Plan, you are granted a non-exclusive, personal, revocable, non-transferable license to use the Generated Content solely for Personal Use. Free Plan users shall NOT use Generated Content for Commercial Use.

9.3.Company Retained Rights. Notwithstanding Sections 9.1 and 9.2, the Company retains all rights in:

(a) The underlying AI models, algorithms, diagnostic frameworks, and technology used to generate insights;

(b) The Service itself (software, code, databases, user interface, design);

(d) The right to use Generated Content (in strictly anonymized or aggregated form) for analytics, research, and improving algorithms.

9.4.No Guarantee of Uniqueness. AI-generated content may be similar or identical to content created by other users or third-party services. We do not guarantee uniqueness, originality, or that Generated Content is free from third-party claims.

9.5.User Responsibility. You are solely responsible for how you use or rely upon Generated Content, and for any consequences arising from your use of Generated Content, including any legal claims or emotional impacts.

9.6.Personal and Commercial Use Restrictions.

(a) Free Plan users may use Generated Content solely for Personal Use (private self-reflection, journaling, sharing with family/friends). Commercial Use is prohibited.

(b) Paid Subscribers may use Generated Content for Personal Use by default. Commercial Use (including professional coaching, consulting, therapy services, or reselling insights) is prohibited without separate written agreement.

9.7.Termination of Rights. Upon termination or expiration of your Subscription, you may retain Generated Content solely for your own private personal records and may not create new Generated Content or use existing content for any commercial purpose.

10.PROHIBITED USES

You agree not to use the Service or allow any third party to use the Service:

10.1.In any manner that violates any applicable law, regulation, or these Terms;

10.2.To generate, upload, or distribute content that:

Is illegal, fraudulent, defamatory, obscene, pornographic, or sexually explicit;
Depicts or exploits minors in any way;
Infringes intellectual property, privacy, publicity, or other rights of any person or entity;
Contains hate speech, harassment, threats, violence, or incitement to violence based on race, ethnicity, gender, religion, nationality, disability, sexual orientation, age, or other protected characteristics;
Spreads false information or misleading content intended to deceive or harm;
Violates any person’s dignity, honor, or reputation;

10.3.To impersonate any person or entity, or falsely state or misrepresent your affiliation;

10.4.For fully automated decision-making that produces legal effects or similarly significantly affects individuals (e.g., credit decisions, employment, law enforcement);

10.5.To discriminate against individuals or groups based on protected characteristics;

10.6.To provide medical, psychological, psychiatric, legal, financial, or other licensed professional services using the Service without proper licenses, qualifications, or credentials;

10.7.To harm, exploit, or endanger minors;

10.8.To stalk, harass, bully, intimidate, or abuse any person;

10.9.To reverse-engineer, decompile, disassemble, modify, or create derivative works of the Service or its underlying technology;

10.10.To circumvent, disable, or interfere with security features, usage limits, or access controls;

10.11.To use automated means (bots, scrapers, scripts) to access the Service without our express written permission;

10.12.To overload, attack, or interfere with the operation or availability of the Service (e.g., DDoS attacks);

10.13.To resell, sublicense, rent, lease, or otherwise commercialize access to the Service itself;

10.14.For any purpose that could expose the Company or any third party to liability or harm.

In compliance with UAE Federal Decree-Law No. 34 of 2021 on Countering Rumors and Cybercrimes, you additionally agree not to:

10.15.Create, upload, or distribute content that spreads false news, rumors, or misleading information that may disturb public peace, harm public interest, or violate public order (Article 52);

10.16.Create content that insults or offends the United Arab Emirates, its leadership, symbols, flag, national anthem, or reputation (Article 25);

10.17.Create content that promotes, incites, or facilitates any activities prohibited under UAE law, including but not limited to terrorism, violence, illegal drugs, gambling, or prostitution (Articles 29, 31, 33, 38);

10.18.Create or distribute obscene content or content that violates public morals as defined under UAE law (Article 34);

10.19.Insult any of the Islamic sanctities or rituals, or the sanctities of other recognized religions (Article 37);

10.20.Use the Service to modify or process any record with the intention of defaming, insulting, or causing distress to any person (Article 44);

10.21.Use the Service for Profiling or automated decision-making that produces legal effects on individuals, in violation of UAE Federal Decree-Law No. 45 of 2021, Article 18;

10.22.Process Sensitive Personal Data in violation of UAE Federal Decree-Law No. 45 of 2021.

Violation of this Section may result in immediate termination of your account, reporting to UAE authorities, and legal action.

11.THIRD-PARTY SERVICES AND AI PROVIDERS

11.1.Use of AI Providers. The Service may use third-party AI models, APIs, or services («AI Providers») to process your text inputs, diary entries, and queries.

11.2.Third-Party Terms. Use of AI Providers is subject to their respective terms of service and acceptable use policies. We are not responsible for the actions, policies, or content of AI Providers.

11.3.Data Processing. We implement reasonable technical and organizational safeguards when transmitting data to AI Providers via secure APIs, including contractual obligations requiring them to delete your data after processing and strictly prohibiting them from using your data to train their models. See our Privacy Policy for details.

11.4.Third-Party Links and Services. The Service may contain links to third-party websites, services, or content. We do not endorse, control, or assume responsibility for any third-party content. Your use of third-party services is at your own risk.

11.5.App Store / Google Play. If you download the Service via the Apple App Store or Google Play, you acknowledge and agree that:

Apple and Google are not a party to these Terms;
Apple and Google have no obligation to provide support;
You will comply with Apple and Google terms and policies;
In the event of any conflict, Apple and Google terms prevail with respect to app distribution.

12.INTELLECTUAL PROPERTY RIGHTS

12.1.Company Ownership. The Service, including all software, code, algorithms, AI integration frameworks, user interface, design, diagnostics logic, branding, trademarks, logos, and Content provided by the Company, are the exclusive property of the Company and its licensors, protected by copyright, trademark, trade secret, and other intellectual property laws, including:

Copyright (UAE Federal Decree-Law No. 38 of 2021, U.S. Copyright Act, international copyright treaties);
Trademark law;
Patent law (where applicable);
Trade secret and confidential information law;
Database rights;
Other intellectual property laws.

12.2.License to Use Service. Subject to your compliance with these Terms, the Company grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Service for your personal purposes in accordance with these Terms.

12.3.Restrictions. You may not:

Copy, modify, distribute, sell, or lease any part of the Service;
Reverse-engineer or attempt to extract source code;
Remove, alter, or obscure any proprietary notices (copyright, trademark);
Use our trademarks, logos, or branding without prior written consent.

12.4.Feedback. If you provide us with any suggestions, ideas, feedback, bug reports, or feature requests («Feedback»), you grant us an unrestricted, perpetual, irrevocable, royalty-free, worldwide, transferable, sublicensable license to use, reproduce, modify, distribute, and commercialize such Feedback for any purpose without compensation, attribution, or obligation to you.

You waive any moral rights or other rights of attribution in Feedback to the extent permitted by law.

12.5.Trademarks. «MindLight», the MindLight logo, and other trademarks, service marks, and logos used on the Service are trademarks or registered trademarks of the Company (whether registered or unregistered). You may not use our trademarks without our prior written permission. All other trademarks, product names, and company names mentioned on the Service are the property of their respective owners.

13.PRIVACY AND DATA PROTECTION

13.1.Privacy Policy. Our collection, use, and processing of your personal information is governed by our Privacy Policy (available at https://mindlight-app.com/privacy/), which is incorporated into these Terms by reference. The Privacy Policy complies with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. You must read and agree to the Privacy Policy before using the Service.

13.2.Legal Basis for Processing. We process your personal data on the following legal bases under UAE law:

(a) Performance of contract with you (Article 4(9) of Federal Decree-Law No. 45/2021);

(b) Your consent, where required (Articles 4 and 6 of Federal Decree-Law No. 45/2021);

(d) Legitimate interests pursued by the Company, provided such interests do not override your fundamental rights and freedoms (Article 4(7)). Consent to processing is obtained separately from acceptance of these Terms, through:

Checkboxes in the Service interface;
Cookie consent banners;
Explicit opt-in mechanisms.
Silence or inaction does not constitute consent.

You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

13.3.Third-Party Data Processing. By using the Service (specifically the diary, mood tracking, and AI Chat Assistant), you may input information regarding your emotional state, mental well-being, or personal struggles. You acknowledge that this information may constitute Sensitive Personal Data (e.g., data concerning health) under applicable laws (including GDPR Article 9 and UAE Federal Decree-Law No. 45/2021).

(a) We process this data strictly based on your explicit consent, obtained when you register for the Service and begin using these features;

(b) We do NOT process this data for medical diagnoses, clinical evaluations, or psychiatric assessments;

(c) Your Sensitive Personal Data is securely encrypted and is NOT used to train our general AI models, nor is it shared with third parties for marketing or advertising purposes.

13.4.Data Subject Rights. Under applicable data protection laws (UAE Federal Decree-Law No. 45/2021, GDPR, UK GDPR, CCPA/CPRA), you have the following rights regarding your personal data:

(a) Right to Access: Obtain confirmation of whether we process your personal data and access to such data;

(b) Right to Rectification: Correct inaccurate or incomplete personal data;

(c) Right to Erasure («Right to be Forgotten»): Request deletion of your personal data (e.g., diary entries, chat history);

(d) Right to Restrict Processing: Request restriction of your data in certain circumstances;

(e) Right to Data Portability: Receive your personal data in a structured, machine-readable format;

(f) Right to Object: Object to processing based on legitimate interests, direct marketing, or profiling;

(g) Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of processing before withdrawal;

(h) Right to Lodge a Complaint: Lodge a complaint with the UAE Data Office or other supervisory authority in your jurisdiction.

To exercise these rights, contact us at hello@mindlight-app.com. We will respond within 10 working days (extendable by 5 days) under UAE law, or 1 month under the GDPR.

13.5.Cross-Border Data Transfers. Your personal data may be transferred to, stored, and processed in countries outside the UAE or your country of residence, including the United States (for cloud infrastructure and AI Providers) and the European Union. Where we transfer personal data, we ensure compliance with Articles 22 and 23 of Federal Decree-Law No. 45/2021 and GDPR Chapter V, including through the use of Standard Contractual Clauses (SCCs), adequacy decisions, and additional technical safeguards (such as encryption in transit and at rest).

13.6.Data Retention

We retain personal data only for as long as necessary to:

Fulfill the purposes for which it was collected;
Comply with legal, tax, accounting, or regulatory obligations;
Resolve disputes and enforce our agreements;
Protect our legal rights.

Specific retention periods:

Data Category	Retention Period	Reason
Account Data (email, User ID, password)	Duration of account; deleted immediately upon account deletion	Provide Service, prevent abuse
User Content (Diary entries, Task lists, Goal descriptions)	Until you delete it; deleted immediately upon account deletion	Provide Service, user access, support
Wellbeing Data (Mood ratings, Life Sphere Diagnostics)	Until you delete it; deleted immediately upon account deletion	Generate historical dynamics, personal insights
AI Chat History	Up to 90 days (you may delete earlier via app settings); deleted immediately upon account deletion	Provide context for AI Assistant, improve conversational flow
Third-Party Data (Names/details mentioned in Diary or Chat)	Until you delete the entry; deleted immediately upon account deletion	Provide the requested service to the user
Transaction Data (Payments, subscriptions)	7 years from transaction date	Legal obligation (tax, accounting), fraud prevention
Support Communications (Emails, tickets)	3 years from last message	Customer support, legal claims
Usage and Analytics Data (Logs, sessions, clicks)	90 days to 2 years (depending on type)	Service improvement, security, fraud detection
Marketing Consent Records	3 years from withdrawal of consent	Legal obligation (proof of consent)
Cookies	See Cookie Policy (varies: session to 2 years)	Functionality, analytics, marketing

After retention periods expire, we permanently delete or anonymize your personal data in accordance with applicable law.

See Privacy Policy for detailed retention information.

13.7.Data Security. We implement appropriate technical and organizational measures to protect personal data against:

Unauthorized or unlawful access, use, disclosure, alteration, or destruction;
Accidental loss, damage, or theft;
Cyberattacks, hacking, malware, ransomware;
Data breaches.

Security measures include (but are not limited to):

(a) Encryption;

(b) Access controls;

(d) Application security;

(e) Organizational measures, including:

Employee training on data protection and security;
Confidentiality agreements;
Vendor management and audits;
Incident response plan.

However, no security system is impenetrable. While we strive to protect your data using industry-standard measures, we cannot guarantee absolute security. You acknowledge and accept the inherent risks of transmitting data over the internet.

See Privacy Policy for detailed security information.

13.8.Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authorities (including the UAE Data Office and/or EU authorities) without undue delay (e.g., within 72 hours under the GDPR), in accordance with applicable laws.

13.9.Automated Decision-Making and Profiling. The Service includes a «Life Diagnostics» feature that analyzes your inputs to evaluate various life spheres (e.g., career, relationships) and generate personalized insights. However, this processing does NOT constitute automated decision-making that produces legal effects or similarly significantly affects you within the meaning of Article 18 of UAE Federal Decree-Law No. 45/2021 or GDPR Article 22. The profiling is conducted solely to provide the entertainment and self-reflection features you requested. You have the right to object to this processing at any time.

13.10.Third-Party Data Processing. If you input personal data of other individuals (e.g., mentioning names in your diary or AI Chat), you represent that you are doing so for purely personal or household activities. The Company acts as a Data Controller and processes this Third-Party Data based on its legitimate interest (to provide the requested service to you). We implement strict data minimization: we do not use Third-Party Data to train AI models, we do not contact these third parties, and we delete this data when you delete your entries or account. You are solely responsible for ensuring you have a lawful basis to input their data into the Service.

13.11.Children’s Data. We do not knowingly collect or process personal data of individuals under 18 years of age. If we become aware of such processing, we will delete the data immediately and terminate the account. If you are a parent or guardian and discover your child has provided data to us, contact us at hello@mindlight-app.com.

13.12.Contact for Data Protection Matters. For questions, requests, or complaints regarding data processing, contact us at:

Email: hello@mindlight-app.com

Data Protection Officer: hello@mindlight-app.com

Address: Dubai Silicon Oasis DSO-IFZA, IFZA Properties, Dubai, PO Box 34, United Arab Emirates

You may also lodge a complaint with:

UAE Data Office

Website:

Phone: +971 2 611 8229

Or the supervisory authority in your jurisdiction.

14.DISCLAIMERS AND WARRANTIES

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

14.1.«As is» and «as available». The Service is provided on an «AS IS» and «AS AVAILABLE» basis, without warranties of any kind, whether express, implied, statutory, or otherwise.

14.2.No Warranties. The Company disclaims all warranties, including but not limited to:

Warranties of merchantability, fitness for a particular purpose, title, and non-infringement;
That the Service will be uninterrupted, error-free, secure, or free from viruses or harmful components;
That Generated Content (AI Chat responses, Life Diagnostics, insights) will meet your expectations, be accurate, reliable, psychologically appropriate, or suitable for any purpose;
That any errors or defects will be corrected;
That the Service will be compatible with your device, browser, or operating system;
That insights, recommendations, or life sphere evaluations will be accurate or applicable to your situation.

14.3.NOT PROFESSIONAL, MEDICAL, OR PSYCHOLOGICAL ADVICE

CRITICAL DISCLAIMER – PLEASE READ CAREFULLY:

The Service, including the AI Chat Assistant, Life Diagnostics, mood tracking, journaling features, and all Generated Content, does NOT provide, and is NOT intended to provide:

Medical, psychiatric, or professional psychological advice, diagnosis, or treatment;
Mental health diagnoses, clinical therapy, counseling, or psychotherapy;
Crisis intervention or suicide prevention services;
Professional coaching or licensed mental health services;
Financial, legal, or other professional advice.

All features, insights, and AI responses are for informational, self-exploration, and entertainment purposes only. They are not a substitute for face-to-face professional consultations with licensed healthcare providers, therapists, psychiatrists, or counselors.

14.4.Emergencies and crisis situations

The Service is NOT designed to handle emergencies or mental health crises.

If you are experiencing:

A medical or mental health emergency;
Severe psychological distress;
Thoughts of self-harm or suicide;
Harm to others;
Any life-threatening situation;

DO NOT USE THE SERVICE. Immediately:

Call your local emergency services;
Contact a crisis hotline in your country;
Go to the nearest emergency room;
Contact a licensed mental health professional.

14.5.AI limitations and «hallucinations»

You acknowledge and agree that the AI Chat Assistant may generate content that is:

Inaccurate, unhelpful, or factually incorrect («hallucinations» – fabricated information generated by the algorithm);
Inappropriate for your specific emotional, mental, or psychological state;
Lacking human empathy, clinical judgment, professional context, or therapeutic expertise;
Inconsistent, contradictory, or logically flawed;
Biased, stereotypical, or culturally insensitive;
Unexpected, offensive, or distressing despite our content filtering efforts.

The Company does not endorse, verify, or assume responsibility for:

Any advice, guidance, statements, or recommendations made by the AI Chat Assistant;
The semantic content, factual accuracy, psychological appropriateness, or safety of Generated Content;
Predictions, insights, or evaluations provided through Life Diagnostics.

You are solely responsible for evaluating the safety and appropriateness of any actions you take based on Generated Content.

14.6.Individual sensitivity and psychological considerations

Some individuals may be more sensitive or vulnerable to AI-generated reflections, mood tracking, or life diagnostics, particularly those:

With anxiety disorders, depression, PTSD, or other mental health conditions;
Experiencing life crises, grief, trauma, or major life transitions;
Prone to obsessive thinking, rumination, or catastrophic interpretations;
Highly suggestible or emotionally vulnerable;
In active treatment with a mental health professional.

You are solely responsible for assessing whether the Service is appropriate for you given your mental health, emotional state, and personal circumstances.

If you experience negative reactions (anxiety, distress, intrusive thoughts, worsening mood, depression, obsessive use) from using the Service:

Immediately discontinue use;
Delete triggering content from your diary or chat history;
Seek professional help from a licensed therapist or counselor;
Contact a crisis helpline if needed.

The Company is not liable for psychological, emotional, or mental health consequences arising from use of the Service.

14.7.Scope and limitations of Life Diagnostics

Life Diagnostics and life sphere evaluations (career, relationships, health, etc.) are:

Selective, algorithmic summaries based on your self-reported inputs;
NOT comprehensive professional assessments equivalent to consultations with career counselors, relationship therapists, or life coaches;
Entertainment and self-reflection tools, not scientific evaluations or clinical assessments;
Subject to the inherent limitations and biases of AI algorithms.

Claims based solely on features being:

«Too brief» or «insufficiently detailed»;
«Not covering all aspects I expected»;
«Using a different methodology than I prefer»;
«Not matching assessments I received elsewhere»;

do NOT constitute failure to provide the Service or grounds for refund, unless there is a technical error preventing delivery of the feature (see Refund Policy).

14.8.Third-Party Content and AI Providers. We disclaim all liability for:

Third-party content, services, AI Providers, or platforms accessed via the Service;
The accuracy, reliability, quality, or safety of third-party content or AI-generated responses;
Any loss or damage arising from your use of third-party services or reliance on AI Provider outputs.

14.9.User Responsibility. You are solely responsible for:

(a) Your use of the Service and how you interpret, apply, or act upon Generated Content;

(b) Compliance with applicable laws and third-party rights;

(d) Decisions you make or actions you take based on AI Chat responses, Life Diagnostics, or insights;

(e) Assessing the suitability of the Service for your mental health and emotional wellbeing;

(f) Discontinuing use if you experience negative psychological or emotional reactions.

You acknowledge and accept the inherent risks of using AI-powered wellbeing tools and agree not to hold the Company liable for any:

Psychological, emotional, or mental health harm;
Consequences of following or relying on AI Chat advice or Life Diagnostics;
Distress, anxiety, or negative emotional reactions caused by Generated Content;
Harm to third parties arising from your use of the Service.

14.10.Basis of the Bargain. You acknowledge that these disclaimers reflect a reasonable allocation of risk and are a fundamental basis of the bargain between you and the Company. Without these disclaimers, we could not offer the Service at current pricing.

15.LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

15.1.Exclusion of Damages. In no event shall the Company, its affiliates, parent companies, subsidiaries, officers, directors, employees, agents, contractors, licensors, or service providers be liable for:

(a) Any indirect, incidental, special, consequential, punitive, or exemplary damages, including but not limited to:

Loss of profits, revenue, business opportunities, goodwill, or reputation;
Loss of data or information (including diary entries, chat history, mood tracking data);
Emotional distress, psychological harm, anxiety, depression, or mental anguish;
Worsening of pre-existing mental health conditions;
Personal injury or property damage (except to the extent caused by our gross negligence or willful misconduct);

(b) Damages arising from:

Your use or inability to use the Service;
Unauthorized access to or alteration of your data or account;
Third-party conduct, content, or services (including AI Providers);
Errors, inaccuracies, harmful content, or psychologically inappropriate responses in AI Chat or Life Diagnostics;
Reliance on AI-generated advice, insights, or recommendations;
Decisions made or actions taken based on Generated Content;
Delays, interruptions, unavailability, or discontinuation of the Service;
Security breaches, data breaches, or cyberattacks (except to the extent we failed to implement legally required security measures);

(с) Any other matter relating to the Service;

EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

15.2.Cap on Liability. Our total aggregate liability for all claims arising out of or related to these Terms or the Service (whether in contract, tort, negligence, strict liability, or otherwise) shall NOT EXCEED the greater of:

(a) The amount you paid to the Company in the 12 months immediately preceding the claim; or

(b) USD $100 (or equivalent in your local currency).

15.3.Consumer Protection Exception. This limitation of liability does NOT apply where prohibited by mandatory consumer protection laws of your country of residence that cannot be waived by contract. For EU/UK/California/Canada consumers and consumers in other jurisdictions with mandatory consumer rights, nothing in this Section limits your statutory rights, including rights to:

Refunds for defective or non-conforming digital content;
Compensation for foreseeable losses caused by our breach of contract or negligence;
Other remedies provided by consumer protection laws.

However, to the extent permitted by law:

Liability for unforeseeable, indirect, or consequential losses is excluded;
Liability is capped as set forth in Section 15.2.

15.4.Exceptions to Liability Limitations. The limitations in this Section do NOT apply to:

(a) Death or personal injury caused by our gross negligence or willful misconduct;

(b) Fraud, fraudulent misrepresentation, or willful misconduct by the Company;

(d) Liability that cannot be excluded or limited under applicable law.

15.5.Basis of the Bargain. You acknowledge that the limitations in this Section reflect a reasonable allocation of risk and are a fundamental basis of the bargain between you and the Company.

Without these limitations, the Service would not be economically feasible at current pricing.

15.6.Jurisdictional Variations. Some jurisdictions do not allow exclusion or limitation of liability for consequential or incidental damages, or liability for personal injury or death. In such jurisdictions, our liability is limited to the maximum extent permitted by law.

16.INDEMNIFICATION

16.1.Your Indemnity. You agree to indemnify, defend, and hold harmless the Company, its affiliates, officers, directors, employees, agents, licensors, and service providers from and against any and all claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or related to:

(a) Your use or misuse of the Service;

(b) Your User Content (including diary entries, mood ratings, queries, Third-Party Data) or Generated Content;

(d) Your violation of any law, regulation, or third-party rights, including:

Intellectual property rights (copyright, trademark, patent, trade secret);
Privacy, publicity, or data protection rights;
Contractual rights or obligations;
Consumer protection laws;
Professional licensing or practice laws (e.g., unauthorized practice of medicine, psychology);

(e) Any claim that your User Content, Third-Party Data, or Generated Content:

Caused harm to a third party (emotional distress, reputational harm, financial loss);
Violated third-party rights;
Was defamatory, libelous, or slanderous;

(f) Your unauthorized or unlawful provision of Third-Party Data (Section 8), including:

Lack of consent from third parties;
Violation of data protection laws;
Claims by third parties whose data you provided without authorization;

(g) Your breach of representations and warranties in these Terms;

(h) Your negligence or willful misconduct.

16.2.Defense and Settlement. We reserve the right, at our own expense, to assume exclusive defense and control of any matter subject to indemnification by you. You agree to cooperate with our defense.

17.TERMINATION

17.1.Termination by You. You may terminate your account and these Terms at any time by:

(a) Canceling your Subscription (as described in Section 7.8); and

(b) Deleting your account by:

Accessing your account settings and selecting «Delete Account» (if available); or
Contacting our Support team at hello@mindlight-app.com with a deletion request.

Effect of Termination by You:

Your access to the Service will terminate immediately or at the end of your current billing period (depending on Subscription type and cancellation timing);
You will lose access to all Generated Content, AI chat history, diary entries, mood tracking data, and account data (unless you download or export it before termination);
No refunds will be provided for partial billing periods or unused time (except as required by law or Refund Policy).

17.2.Termination by Company. We may suspend, restrict, or terminate your access to the Service (in whole or in part), and/or delete your account, immediately and without prior notice, for any reason, including:

(a) Violation of these Terms, Privacy Policy, Refund Policy, or other policies;

(b) Fraudulent, abusive, or illegal activity, including:

Payment fraud, chargebacks, or unauthorized use of payment methods;
Creating multiple accounts to abuse free trials or circumvent limits;
Automated access (bots, scrapers) without authorization;
Hacking, security breaches, or attempts to compromise the Service;

(d) Prohibited Uses (Section 10), including:

Illegal content, hate speech, harassment, threats;
Infringement of third-party rights;
Violation of UAE law or other applicable laws;
Use for high-stakes automated decision-making without human review;

(e) Risk to the security, integrity, availability, or reputation of the Service or other users;

(f) Legal or regulatory requirements, including:

Court orders, subpoenas, or lawsuits;
Requests from law enforcement or government authorities;
Compliance with data protection, consumer protection, or other laws;

(g) Prolonged inactivity (e.g., no login or use for 2+ years);

(h) At our sole discretion, for any other reason or no reason.

17.3.Effect of Termination by Company:

(a) All licenses granted to you under these Terms terminate immediately;

(b) You must immediately cease all use of the Service and Generated Content;

(c) We may delete your account and data (including User Content, Generated Content, diary entries, AI chat history, mood tracking data, Third-Party Data), except:

As required by law (legal holds, regulatory requirements);
As necessary for dispute resolution, legal claims, or enforcement of these Terms;
For backup, caching, or archival purposes (typically deleted within 90 days);

(d) No refunds will be provided, except as required by law;

(e) Sections that by their nature should survive termination (including Sections 9, 10, 12, 13, 14, 15, 16, 21, 22, 23) shall survive.

17.4.No Liability for Termination. We are not liable for any loss, damage, or consequences arising from:

Termination or suspension of your account (by you or by us);
Deletion of your data;
Interruption or discontinuation of the Service.

17.5.Reinstatement. If your account is terminated by us for non-payment or technical issues (not for violations), you may request reinstatement by:

Contacting Support at hello@mindlight-app.com;
Resolving the outstanding issue (e.g., updating payment method);
Paying any outstanding fees.

We reserve the right to deny reinstatement in our sole discretion, especially if termination was due to violations of these Terms.

18.COPYRIGHT AND INTELLECTUAL PROPERTY INFRINGEMENT

18.1.Respect for Intellectual Property. We respect intellectual property rights and expect users to do the same.

18.2.DMCA Notices (U.S. Copyright Law). If you believe that content on the Service infringes your copyright under U.S. law (Digital Millennium Copyright Act, 17 U.S.C. § 512), you may submit a DMCA takedown notice to our designated Copyright Agent:

MINDLIGHT PROJECT – FZCO

Email: hello@mindlight-app.com

Address: Dubai Silicon Oasis DSO-IFZA, IFZA Properties, Dubai, PO Box 34, United Arab Emirates

Your DMCA notice must include:

(a) Your physical or electronic signature;

(b) Identification of the copyrighted work claimed to be infringed (or a representative list if multiple works);

(d) Your contact information (name, address, phone number, email);

(e) A statement of good faith belief that the use is not authorized by the copyright owner, agent, or law;

(f) A statement under penalty of perjury that:

The information in the notice is accurate; and
You are the copyright owner or authorized to act on behalf of the owner.

18.3.UAE Copyright Compliance. The Service and all content provided by the Company are protected under UAE Federal Decree-Law No. 38 of 2021 on Copyright and Neighboring Rights. Any person who believes that content on the Service infringes their rights under UAE copyright law may submit a notice to the Copyright Agent above, complying with the requirements of Articles 15 and 35 of Federal Decree-Law No. 38/2021.

Such notice should include:

(a) Identification of the copyrighted work claimed to be infringed;

(b) Identification of the infringing material and its location on the Service;

(d) A statement under penalty of law that the information is accurate and you are authorized to act on behalf of the copyright owner.

We will respond to valid notices in accordance with UAE law, which may include:

Removal or disabling access to the allegedly infringing content;
Suspension or termination of the infringing user’s account.

18.4.Counter-Notice (DMCA and UAE Law). If your content is removed or access is disabled due to a copyright notice (DMCA or UAE) and you believe it was removed in error or you have authorization to use the content, you may submit a counter-notice:

Counter-notice must include:

(a) Your physical or electronic signature;

(b) Identification of the material that was removed or disabled and its location before removal;

(c) A statement under penalty of perjury that you have a good faith belief the material was removed or disabled as a result of mistake or misidentification;

(d) Your name, address, phone number, and email;

(e) Consent to jurisdiction of:

The federal district court for the judicial district in which your address is located (for DMCA counter-notices); or
The courts of Dubai, UAE (for UAE law counter-notices);

(f) A statement that you will accept service of process from the person who submitted the original notice or their agent.

Upon receipt of a valid counter-notice, we will forward it to the original complainant. If the complainant does not file a lawsuit within 10-14 business days, we may restore the content.

18.5.Repeat Infringers

We reserve the right to terminate accounts of users who are repeat infringers of intellectual property rights, in accordance with DMCA (17 U.S.C. § 512(i)) and applicable law.

18.6.False Claims

Submitting a false, fraudulent, or bad faith copyright notice or counter-notice may result in:

Liability for damages, costs, and attorneys’ fees under DMCA § 512(f) or applicable law;
Termination of your account;
Legal action.

19.MODIFICATIONS TO TERMS

19.1.Right to Modify. We reserve the right to modify, update, or replace these Terms at any time, at our sole discretion, to:

Reflect changes in our data practices, features, or business model;
Comply with new legal or regulatory requirements;
Improve clarity, transparency, or user experience;
Address new risks or issues.

19.2.Notice of Changes. When we make material changes to these Terms, we will notify you by:

(a) Posting the updated Terms on the Website with a revised «Effective Date»;

(b) Sending email notification to the email address associated with your account (for material changes affecting your rights or obligations);

(d) Requiring re-acceptance (for significant changes, if required by law).

Material changes include (but are not limited to):

Expansion of permitted uses or data collection;
Reduction of user rights or increase in user obligations;
Changes to pricing, payment terms, or refund policies;
Changes to limitation of liability or indemnification;
Changes to governing law or dispute resolution.

19.3.Acceptance of Changes. By continuing to use the Service after the updated Terms become effective, you accept the changes.

If you do not agree to the updated Terms:

(a) Stop using the Service immediately;

(b) Cancel your Subscription and delete your account before the effective date of the changes (to avoid being bound);

19.4.Review Requirement. We encourage you to review these Terms periodically (at least every 6-12 months) to stay informed about your rights and obligations. The current version is always available at https://mindlight-app.com/terms/ with the «Effective Date» clearly displayed.

20.GOVERNING LAW AND DISPUTE RESOLUTION

20.1.Governing Law

(a) These Terms and your use of the Service shall be governed by and construed in accordance with the laws of the United Arab Emirates, including:

Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data;
Federal Decree-Law No. 46 of 2021 on Electronic Transactions and Trust Services;
Federal Decree-Law No. 34 of 2021 on Countering Rumors and Cybercrimes;
Federal Law No. 5 of 1985 (UAE Civil Transactions Law);
Other applicable UAE federal and emirate-level laws.

(b) Mandatory Consumer Protection Laws: Nothing in this Section limits any mandatory consumer protection rights you may have under the laws of your country of residence that cannot be waived by contract, including:

EU Directive 2011/83/EU (Consumer Rights Directive) and national consumer protection laws;
UK Consumer Rights Act 2015;
U.S. state consumer protection laws (including California, New York, etc.);
Canadian Consumer Protection Acts (federal and provincial);
Other jurisdictions’ mandatory consumer protection statutes.

(c) Where there is a conflict between UAE law and the mandatory consumer protection laws of your jurisdiction, the provision more favorable to you as a consumer shall apply to the extent required by law.

20.2.Jurisdiction

(a) Subject to Section 20.2(b) below, any disputes arising out of or relating to these Terms or the Service shall be subject to the exclusive jurisdiction of the competent courts of Dubai, United Arab Emirates.

(b) Consumer Jurisdiction Rights: If you are a consumer resident in the European Union, United Kingdom, California, Canada, Australia, or other jurisdiction with mandatory consumer jurisdiction rules, you may bring proceedings in either:

The courts of Dubai, UAE; OR
The courts of your country or state of residence, as permitted by applicable consumer protection law.

Nothing in this Section prevents you from bringing a claim in any other jurisdiction where the Company has assets or conducts business, if permitted by applicable law.

20.3.Pre-Dispute Resolution and Mandatory Negotiation. Before initiating any formal legal proceedings (lawsuit, arbitration, or regulatory complaint), the parties agree to attempt to resolve disputes amicably through good faith negotiations for a period of 30 days.

Mandatory Pre-Action Notice:

Any party intending to commence legal proceedings must first send a written notice to the other party describing:

The nature of the dispute;
The legal and factual basis for the claim;
The relief or resolution sought;
A good faith attempt to propose a resolution.

Notice to the Company:

MINDLIGHT PROJECT – FZCO

Email: hello@mindlight-app.com

Address: Dubai Silicon Oasis DSO-IFZA, IFZA Properties, Dubai, PO Box 34, United Arab Emirates

Notice to You:

To the email address associated with your account.

The recipient shall have 30 days to respond and attempt to resolve the dispute before legal proceedings may be commenced.

This requirement does NOT prevent:

Filing for injunctive or urgent relief (e.g., to prevent irreparable harm);
Filing within statutory limitation periods that would otherwise expire;
Reporting to regulatory authorities or consumer protection agencies.

20.4.Dispute Resolution for EU/UK/California/Canada Consumers

For consumers in the European Union, United Kingdom, California, Canada, and other jurisdictions with consumer Alternative Dispute Resolution (ADR) or Online Dispute Resolution (ODR) mechanisms:

(a) EU Online Dispute Resolution (ODR) Platform:

EU consumers may use the European Commission’s ODR platform:

https://ec.europa.eu/consumers/odr

(b) UK Alternative Dispute Resolution:

UK consumers may contact Citizens Advice or use an approved ADR entity for consumer disputes.

Сalifornia consumers may contact the California Department of Consumer Affairs or file a complaint with the Attorney General’s office.

(d) Canada:

Canadian consumers may contact provincial consumer protection offices or use federal/provincial dispute resolution services.

(e) We will participate in good faith in ADR or ODR proceedings initiated by consumers, to the extent required or encouraged by applicable law.

20.5.NO CLASS ACTIONS OR REPRESENTATIVE PROCEEDINGS

TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU AGREE THAT ANY DISPUTE SHALL BE BROUGHT IN YOUR INDIVIDUAL CAPACITY, AND NOT:

As a plaintiff or class member in any purported class action or class proceeding;
As a representative in any representative action or proceeding;
On behalf of the general public in any private attorney general action;
In any collective, consolidated, or mass arbitration or litigation.

Class Action Waiver:

You and the Company agree to waive any right to bring claims on a class or collective basis or to participate in a class, collective, or representative action as a class member.

Exceptions:

This waiver does NOT apply where prohibited by mandatory consumer protection laws (e.g., EU/UK consumers, some U.S. state laws);
You retain the right to bring claims in small claims court (if within jurisdictional limits and brought individually);
You retain the right to report to regulatory authorities (data protection authorities, consumer protection agencies, etc.).

20.6.Limitation Period. Any claim arising under these Terms must be brought within one (1) year from the date the cause of action arose, except where longer limitation periods are mandated by applicable consumer protection law (e.g., 6 years under UK Consumer Rights Act, varying periods under EU, U.S. or Canadian law).

After the applicable limitation period expires, the claim is forever barred.

20.7.Language of Proceedings. Any legal proceedings shall be conducted in English.

If conducted in the UAE, Arabic translations may be required in accordance with UAE procedural law.

20.8.Severability. If any provision of this Section 20 is found invalid, illegal, or unenforceable under applicable law (e.g., class action waiver prohibited in certain jurisdictions), it shall be severed and the remaining provisions shall continue in full force and effect.

21.GENERAL PROVISIONS

21.1.Entire Agreement. These Terms, together with our Privacy Policy, Refund Policy, Cookie Policy (if applicable), and any other policies referenced herein, constitute the entire agreement between you and the Company regarding the Service and supersede all prior agreements, understandings, negotiations, or communications (whether written or oral).

21.2.Severability. If any provision of these Terms is found invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect. The invalid provision shall be reformed or severed to the minimum extent necessary to make it valid and enforceable, while preserving the parties’ intent to the greatest extent possible.

21.3.No Waiver. Our failure to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision or any other right or provision. Any waiver must be in writing and signed by an authorized representative of the Company.

21.4.Assignment

(a) You shall NOT assign, transfer, sublicense, or delegate these Terms, your account, or any rights or obligations hereunder without our prior written consent;

(b) We may assign, transfer, or delegate these Terms and our rights and obligations hereunder (in whole or in part) to any affiliate, subsidiary, successor, or third party without your consent, including in connection with:

Merger, acquisition, reorganization, or sale of assets;
Change of control or ownership;
Outsourcing or subcontracting of services;

21.5.Force Majeure. We are not liable for delays, failures in performance, or inability to provide the Service due to causes beyond our reasonable control, including but not limited to:

Natural disasters (earthquakes, floods, hurricanes, pandemics);
War, terrorism, riots, civil unrest, government actions;
Strikes, labor disputes, or shortages;
Internet, telecommunications, or power outages;
Cyberattacks, hacking, DDoS attacks (if not caused by our gross negligence);
Failures of third-party service providers, AI Providers, or cloud infrastructure;
Legal or regulatory changes prohibiting or restricting the Service.

During force majeure events, our obligations are suspended for the duration of the event, and we will make reasonable efforts to resume Service as soon as practicable.

21.6.Language. These Terms are drafted in English. If we provide translations into other languages, they are for convenience only. In the event of any conflict or ambiguity between the English version and a translation, the English version shall prevail.

21.7.Notices

(a) Notices to You may be sent via:

Email to the address associated with your account;
In-app notification or message;
Posting on the Website or in the Service;
Push notification (if you have enabled them);

(b) Notices are deemed received:

Immediately upon sending (for email, in-app, or push notifications);
Immediately upon posting (for Website notices);

MINDLIGHT PROJECT – FZCO

Email: hello@mindlight-app.com

Address: Dubai Silicon Oasis DSO-IFZA, IFZA Properties, Dubai, PO Box 34, United Arab Emirates

Support: hello@mindlight-app.com

Notices to us are deemed received when we actually receive them (not when sent).

21.8.Third-Party Beneficiaries. There are no third-party beneficiaries to these Terms, except:

AI Providers and service providers are intended third-party beneficiaries of Sections 12, 14, 15, and 16 (Intellectual Property, Disclaimers, Limitation of Liability, and Indemnification) to the extent they limit liability for their conduct;
Nothing in these Terms creates any rights or benefits for any third party not expressly identified.

21.9.Export Control and Sanctions. You may not use or export the Service in violation of any applicable export control laws, sanctions, or embargoes, including:

U.S. export control laws (EAR, ITAR, OFAC sanctions);
EU export controls and sanctions;
UAE export controls and sanctions;
UN Security Council sanctions;

21.10.No Partnership or Agency. Nothing in these Terms creates a partnership, joint venture, agency, employment, or fiduciary relationship between you and the Company. You have no authority to bind the Company or make representations on our behalf.

21.11.Electronic Communications and Transactions

(a) You consent to receive communications from us electronically, including via email, in-app notifications, push notifications, or posting on the Website;

(b) You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing, in accordance with UAE Federal Decree-Law No. 46 of 2021 on Electronic Transactions and Trust Services and other relevant legislation in your country.

(c) Electronic documents, signatures (including click-through acceptance, checkboxes, typed names), and records used in connection with the Service shall have the same legal effect as their paper equivalents under applicable law;

(d) You have the right to withdraw consent to electronic communications (where applicable) by contacting us at hello@mindlight-app.com, but withdrawal may prevent us from providing the Service.

21.12.Headings and Interpretation

(a) Section headings and titles are for convenience only and do not limit or affect the interpretation of these Terms;

(b) «Including» means «including but not limited to»;

(d) «You» refers to the individual user; «we», «us», «our» refer to the Company;

(e) Any ambiguity or uncertainty in these Terms shall not be construed against the drafting party (Company), as these Terms are the result of negotiation and mutual agreement (contract of adhesion notwithstanding, to the extent permitted by law).

22.COMPLIANCE WITH UAE LAW AND REGULATORY OBLIGATIONS

22.1.General Compliance. The Company operates in compliance with all applicable laws of the United Arab Emirates, including federal decree-laws governing personal data protection, copyright, electronic transactions, and cybercrimes (as referenced throughout these Terms).

22.2.Content Moderation. In accordance with UAE Federal Decree-Law No. 34 of 2021 on Countering Rumors and Cybercrimes:

(a) We reserve the right to remove, disable access to, or refuse to host any content that:

Violates UAE law or these Terms;
Constitutes illegal content as defined under UAE law;
Spreads false news, rumors, or misleading information (Article 52);
Infringes intellectual property rights;
Violates privacy or data protection laws;
Violates public morals or public order (Article 34);
Insults the UAE, its leadership, symbols, or sanctities (Articles 25, 37);
Promotes illegal activities (Articles 29, 31, 33, 38);
Is otherwise objectionable in our sole discretion;

(b) We may comply with orders from UAE competent authorities to:

Correct, remove, or delete illegal content or false data;
Disable user access to specific content;
Block access to the Service or specific features;
Provide information or assistance in investigations (subject to applicable law and user privacy rights).

22.3.Cooperation with Authorities. We will cooperate fully with UAE government authorities, law enforcement, regulatory bodies, and courts, including by:

(a) Responding to lawful requests for information, assistance, or disclosure (subject to applicable legal process and data protection laws);

(b) Reporting illegal activity, content, or conduct that comes to our attention (where required by law);

(d) Implementing orders to remove content, suspend accounts, block access, or take other actions as required by competent authorities;

(e) Providing testimony or documentation in legal proceedings (subject to legal privilege and confidentiality obligations).

You acknowledge and consent to such cooperation and disclosure as required by UAE law and applicable legal process.

22.4.Reporting Illegal Content. If you become aware of content on the Service that violates UAE law (including false information, illegal content, intellectual property infringement, violations of public morals, or other prohibited content), you must report it to us immediately at:

Email: hello@mindlight-app.com

Please include:

Description of the illegal content and specific law violated;
Location of the content (URL or description);
Your contact information;
Any supporting evidence or documentation.

We will investigate and take appropriate action in accordance with UAE law, including:

Removing or disabling access to the content;
Suspending or terminating the user’s account;
Reporting to UAE authorities (if required or appropriate);
Implementing technical measures to prevent recurrence.

22.5.Data Localization and Sovereignty

(a) To the extent required by UAE law or regulation, personal data of UAE residents may be stored and processed on servers located within the UAE or in jurisdictions approved by UAE authorities;

(b) The Company will comply with any data localization requirements issued by:

UAE Data Office (Telecommunications and Digital Government Regulatory Authority – TDRA);
Central Bank of the UAE (for financial data);
Other UAE regulatory authorities;

22.6.User Responsibility for UAE Law Compliance. You are solely responsible for ensuring that your use of the Service, your User Content (including Third-Party Data), and your Generated Content comply with all applicable UAE laws, including but not limited to:

(a) Federal Decree-Law No. 34 of 2021 on Countering Rumors and Cybercrimes (prohibitions in Section 10.15-10.22);

(b) Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (privacy, consent, data subject rights);

(d) Federal Decree-Law No. 46 of 2021 on Electronic Transactions and Trust Services;

(e) Federal Law No. 5 of 1985 (UAE Civil Transactions Law);

(f) Penal Code (Federal Law No. 31 of 2021) (crimes and penalties);

(g) Cybercrime Law (Federal Decree-Law No. 34 of 2021);

(h) Other applicable UAE federal, emirate-level, and free zone laws and regulations.

You agree to indemnify and hold the Company harmless from any claims, fines, penalties, or liability arising from your violation of UAE law (Section 16).

22.7.Penalties for Violations. Violation of UAE law through use of the Service may result in:

(a) Immediate termination of your account without refund;

(b) Reporting to UAE authorities (police, public prosecution, regulatory agencies);

Compensation for damages;
Injunctions or court orders;
Legal costs and fees;

(d) Criminal liability under UAE law, including:

Fines (ranging from AED 50,000 to AED 3,000,000 or more, depending on offense);
Imprisonment (ranging from months to years, depending on offense);
Deportation (for non-UAE nationals);
Confiscation of devices or assets;

(e) Administrative penalties:

Website or account blocking;
Domain seizure;
Business license revocation (if applicable);

(f) Liability for Company’s losses:

Legal costs, fines, or penalties incurred by the Company;
Reputational damage;
Costs of investigation, remediation, or compliance.

23.CONTACT INFORMATION

If you have any questions, concerns, or requests regarding these Terms or the Service, please contact us:

MINDLIGHT PROJECT – FZCO

Registration Number: 64926

Registered Address: Dubai Silicon Oasis DSO-IFZA, IFZA Properties, Dubai, PO Box 34, United Arab Emirates

Email: hello@mindlight-app.com

Website: mindlight.ae

Support: hello@mindlight-app.com

By using MindLight, you acknowledge that you have read, understood, and agree to be bound by these Terms of Service.

Last Updated: April 29, 2026