Privacy Policy

Last updated: 11 December 2025

Welcome to HeadUp! We build digital wellbeing and productivity applications (“Apps”) to help you reduce distractions and use your devices more intentionally. Your privacy and peace of mind are central to that mission.

This Privacy Policy explains how we collect, use, store, and share your information when you use our Apps or interact with us. Please read it carefully. By downloading, installing, or using our Apps, you agree to this Privacy Policy. If you do not agree with any part of it, please do not use the Apps.



1. Who We Are

The HeadUp mobile and desktop applications (“HeadUp”, the “Apps”, “we”, “us”, or “our”) are operated by:

MIRRORHUB MCHJ
100000, Republic of Uzbekistan,
Tashkent, Mirzo-Ulugbek district,
Okibat MGS, Mustakillik lane, house 7

For the purposes of applicable data protection laws (including the General Data Protection Regulation – “GDPR”), we are the data controller for the personal data we process in connection with the Apps.

You can contact us about privacy at:
Email: nimesapp@gmail.com



2. What This Policy Covers

This Privacy Policy applies to:

• your use of our Apps (mobile, desktop, or other platforms where HeadUp is available);
• related online interfaces or forms that link to this Privacy Policy;
• your interactions with us via email or support channels relating to the Apps.

This Policy does not apply to third-party applications, websites, or services that may be linked from our Apps. Those services are governed by their own privacy policies.



3. Information We Collect

We collect only the data we need to operate the Apps, provide our features, keep them secure, and improve your experience. Depending on how you use the Apps, we may process the following categories of data.


3.1 Information You Provide to Us

• Account and profile information

When you create an account or sign in, we may collect your email address and basic profile details (for example, display name).

• Preferences and settings

Information about your preferences inside the Apps, such as language, notification settings, schedules, block lists, and other configuration choices.

• Support and communications

Content of messages you send us (for example, bug reports, feature requests, or questions), including your contact details and any information you voluntarily include.

• Payment-related information (indirect)

When you purchase a subscription or paid feature, Payment Providers may share with us limited information related to the transaction (for example, payment status, product purchased, and a transaction ID). We do not collect or store your full card details.

• Other information you choose to provide

Any other information you voluntarily submit to us through forms, surveys, or communication channels.


3.2 Information Collected Automatically

When you use the Apps, certain information is collected automatically from your device:

• Device information

Device model, operating system and version, device language, time zone, and general device identifiers (for example, app instance identifiers or push notification tokens).

• Log and diagnostic data

Crash logs, performance events, error codes, and technical diagnostic information, which help us identify problems and improve stability.

• Usage data

Information about how you interact with the Apps, such as which screens you open, which features you use (for example, schedules, instant blocking), and the time and date of your sessions.

• Approximate location

We may process information such as IP address or device locale to determine an approximate location (for example, country or region) for language, legal compliance, and security purposes. We do not use GPS or precise location for HeadUp’s core features.


3.3 Screen Time and Digital Wellbeing Data

To provide HeadUp’s core digital wellbeing functionality, we may process information related to how you use your device and apps. Depending on your platform and settings, this can include:

• categories of apps or specific apps you choose to block or monitor;
• approximate duration and timing of app usage or device usage;
• triggers and events related to blocking, schedules, and limits (for example, when a session starts/ends, when a block is activated, or when a limit is reached).

Where possible and supported by the platform:

• many of these calculations are performed locally on your device;
• we store only the minimum necessary aggregated or summarised data (for example, total time spent per day or category) needed to provide features such as statistics, progress tracking, or sync between your devices (if you enable such functionality).

We do not access the content of what you view or type inside other apps (such as messages, emails, or websites) through HeadUp.


3.4 Payment and Subscription Data

For purchases and subscriptions, Payment Providers (such as app stores or online payment processors) may share with us:

• an internal user or account identifier;
• subscription plan and status (active, cancelled, expired);
• dates of purchase, renewal, or cancellation;
• country or currency of the transaction (where relevant).

We use this to:

• confirm your entitlement to paid features;
• manage subscription status inside the Apps;
• perform internal accounting and comply with legal obligations.

We do not collect or store your full credit card number or CVV; these are handled by Payment Providers.



4. How We Use Your Information (Purposes)

We process your information for the following purposes:

1. To provide and operate the Apps

• Creating and managing your account;
• Delivering core features, including screen time tracking, blocking, schedules, and usage insights;
• Enabling sync of settings or data across devices if such functionality is available and you choose to use it.

2. To improve and develop the Apps

• Analysing usage patterns and app performance;
• Identifying trends, bugs, and areas for improvement;
• Developing new features and user experiences.

3. To personalise your experience

• Remembering your settings and preferences;
• Adapting the Apps to your device, language, region, and usage;
• Providing relevant in-app messages (for example, tips or onboarding).

4. To process purchases and manage subscriptions

• Activating and managing your access to paid features;
• Verifying payment status with Payment Providers;
• Sending you information about your purchases or changes to your subscription.

5. To communicate with you

• Responding to your support requests, questions, or feedback;
• Sending service-related communications (for example, security alerts, changes to terms or policies);
• If permitted by law and your preferences, sending occasional updates about new features or important product changes.

6. To ensure security and prevent misuse

• Detecting and preventing fraud, abuse, or security incidents;
• Protecting our Apps, infrastructure, and users.

7. To comply with legal obligations

• Keeping appropriate business and financial records;
• Responding to lawful requests from public authorities;
• Enforcing our Terms of Use and protecting our legal rights.

5. Legal Bases for Processing (EEA/UK Users)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data on the following legal bases:

• Performance of a contract

When processing is necessary to provide the Apps and fulfil our agreement with you (for example, account creation, delivering core features, processing subscription status).

• Legitimate interests

When we process data for our legitimate business interests, such as improving the Apps, preventing fraud and misuse, and securing our systems, provided that your interests and fundamental rights do not override those interests.

• Consent

Where required by law (for example, certain analytics or marketing communications), we will rely on your consent. You may withdraw your consent at any time through the mechanisms provided (such as app settings or unsubscribe options in emails), without affecting the lawfulness of processing before withdrawal.

• Legal obligations

When we need to process data to comply with legal obligations (for example, accounting, tax, or responding to lawful requests).



6. Payments, Payment Providers and Use of Payment Information

When you make a purchase or subscribe to paid features, your payment is processed by Payment Providers, which may include:

• app stores (for example, the Apple App Store or other distribution platforms);
• online payment processors or subscription billing platforms.

We may use the information you provide about yourself in connection with a payment only to:

• process and fulfil your order;
• provide access to the purchased features;
• manage your subscription status;
• communicate with you about your purchase;
• comply with legal, accounting, and anti-fraud obligations.

We do not share payment-related information with outside parties except where it is:

• necessary to complete the transaction and provide access to paid features;
• required by law or by a competent authority;
• necessary to protect our rights or the rights of others (for example, in case of suspected fraud or abuse).

For purchases made through app stores, that app store’s privacy policy and terms will also apply.



7. How We Share Your Information

We do not sell your personal data.

We may share your information with the following categories of recipients, strictly on a need-to-know basis:

• Service providers and processors

Third-party companies that help us operate the Apps, such as:

○ hosting and infrastructure providers;
○ analytics and crash reporting providers;
○ Payment Providers;
○ customer support tools and communication platforms.

These service providers are bound by contractual obligations to handle your data securely and to use it only for the specified purposes.

• Professional advisors

Lawyers, accountants, auditors, or other professional advisors, where necessary for the services they provide to us and subject to confidentiality obligations.

• Public authorities and legal requests

Where required by law, regulation, legal process, or governmental request, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

• Business transfers

In connection with a merger, acquisition, sale of assets, or similar transaction involving our company, your data may be transferred as part of the transaction. We will take reasonable steps to ensure that the recipient continues to protect your data in line with this Policy.

We may also share aggregated or de-identified data that cannot reasonably be used to identify you, for example to publish general usage statistics or performance metrics.



8. International Transfers

Our infrastructure and service providers may be located in countries other than your own, including countries that may not provide the same level of data protection as your home jurisdiction.

Where we transfer personal data from the EEA/UK to countries outside of those regions, we will take appropriate safeguards, such as:

• using Standard Contractual Clauses approved by the European Commission or the UK authorities; and/or
• relying on adequacy decisions, where applicable; and/or
• implementing other safeguards required by law.

You can contact us if you would like more information about the safeguards we use for international transfers.



9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

In general:

• Account-related data is kept while your account is active and for a reasonable period thereafter (for example, to allow reactivation or to fulfil legal obligations).
• Subscription and payment records are retained for the period required by tax, accounting, and financial regulations.
• Support communications and logs may be retained for a reasonable period to help us manage your requests, improve the Apps, and maintain security.
• Analytics and diagnostic data may be retained in aggregated or pseudonymised form for longer periods for trend analysis and product improvement.

When data is no longer needed, we will delete it or anonymise it so that it can no longer be linked to you.



10. Your Rights

Your rights depend on your jurisdiction. We will respect and respond to rights requests in accordance with applicable law.


10.1 Rights under GDPR (EEA/UK)

If you are in the EEA or UK, you have the following rights in relation to your personal data:

• Right of access – to obtain confirmation as to whether we process your personal data and to receive a copy of it.

• Right to rectification – to request correction of inaccurate or incomplete data.

• Right to erasure (“right to be forgotten”) – to request deletion of your personal data in certain circumstances.

• Right to restriction of processing – to request that we limit the processing of your data in certain situations.

• Right to data portability – to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.

• Right to object – to object to processing based on our legitimate interests or for direct marketing.

• Right to withdraw consent – where processing is based on consent, you can withdraw that consent at any time.

You also have the right to lodge a complaint with a supervisory authority in the country where you live or work, or where you believe your rights have been infringed.

To exercise any of these rights, please contact us at nimesapp@gmail.com.


10.2 CCPA/CPRA (California Residents)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), as amended by the CPRA, including:

• the right to know what categories of personal information we collect, use, and disclose;
• the right to request access to and deletion of your personal information;
• the right to correct inaccurate personal information;
• the right to be free from discrimination for exercising your rights.

We do not “sell” or “share” your personal information as those terms are defined under the CCPA/CPRA (we do not exchange your personal information for money or for cross-context behavioural advertising).
You may contact us at nimesapp@gmail.com to submit a rights request. We may need to verify your identity before responding.



11. Children’s Privacy

Our Apps are not intended for children under:

• 16 years of age in the EEA/UK, or
• 13 years of age in the United States and other jurisdictions with similar thresholds,

and we do not knowingly collect personal data from such individuals.

If you are a parent or legal guardian and believe that your child has provided personal data to us without your consent, please contact us at nimesapp@gmail.com. We will take reasonable steps to delete the data and, if applicable, close the child’s account.

We may use age or date-of-birth checks and other measures to help prevent use by ineligible individuals, but we are not responsible for misrepresentation of age by users.



12. Security

We take reasonable technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised access, or disclosure.

These measures may include:

• using secure, industry-standard protocols to protect data in transit;
• using reputable cloud providers with appropriate security controls;
• access controls and restrictions for staff;
• regular monitoring and review of our systems and practices.

However, no system or transmission of data over the internet can be guaranteed to be completely secure. You are responsible for keeping your devices and account credentials secure.



13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. When we do, we will update the “Last updated” date at the top.

For material changes, we will provide a more prominent notice (for example, in the Apps or via email). Your continued use of the Apps after the updated Privacy Policy becomes effective constitutes your acceptance of the changes. If you do not agree with the updated Policy, you should stop using the Apps.



14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, you can contact us at:

Email: nimesapp@gmail.com

Postal address:
MIRRORHUB MCHJ
100000, Republic of Uzbekistan,
Tashkent, Mirzo-Ulugbek district,
Okibat MGS, Mustakillik lane, house 7