Minerva Privacy Policy

1. Contact and Legal Information

2. Categories of Information We Collect

We collect personal information necessary to provide and improve the App's reading experience and its AI-powered features. We collect information directly from you, automatically through your use of the App, and from third-party services (such as the Apple App Store).

3. How We Use Your Information

We process your personal information based on specific legal grounds as required by applicable law, particularly the General Data Protection Regulation (GDPR).

A. Performance of Contract

We use your data to fulfill our obligations to you under the Terms and Conditions, including:

• Providing the core functions of the App, including access to the public domain library and the integrated reader.
• Managing your Basic or Scholar subscription and providing the requested AI outputs.
• Synchronizing your reading progress, notes, and bookmarks across devices.

B. Legitimate Interests

We use certain data when it is necessary for our legitimate interests and when those interests do not override your fundamental rights, including:

• Maintaining and improving the security of the App and preventing fraudulent activity.
• Analyzing aggregated usage data (e.g., how often features are used) to optimize and improve the App's functionality and design.
• Responding to your support requests.

C. Consent

We rely on your consent for specific activities, particularly those related to the secondary use of user-generated content and AI inputs. Where consent is required, we provide you with a specific, explicit mechanism to grant or withdraw that consent.

4. AI-Specific Data Handling and Opt-Out Rights

Minerva is powered by generative Artificial Intelligence (AI) technology. You must be aware of how your interaction data with the AI features is handled.

Interaction with AI

When you use AI features (e.g., 'Ask a Question' or 'Imagine'), your inputs (prompts) are processed by our internal systems and may be securely transmitted to a third-party Large Language Model (LLM) vendor to generate the response.

Use for Model Training

We may retain and use the inputs (prompts) and outputs generated by your use of the AI features for the purpose of improving, training, and developing Minerva's AI models and associated technology.

Your Right to Opt Out of AI Training

You have the right to opt out of the use of your AI prompts, queries, and resulting content for the purpose of model training and development. You can exercise this right at any time through the Privacy Settings within the Minerva App. If you opt out, your data will not be used for future model training, but may still be retained for a limited period to provide the immediate service and for security purposes.

5. Disclosure and Sharing of Information

We share your information only as necessary to operate our service, process transactions, and comply with law. We do not share your personal data with third parties for their independent marketing purposes.

A. Service Providers and Third-Party Processors

We engage third-party companies and individuals to facilitate our services (e.g., cloud hosting, crash analytics, identity verification, and AI processing). These parties only have access to the personal data required to perform their tasks on our behalf and are obligated to comply with the same security and privacy standards we maintain.

• Payment Processing: All subscription payments are processed securely through the Apple App Store, which acts as the Merchant of Record.
• AI Processing: If we use an external LLM provider, your prompts will be shared with that provider to generate the requested output. This relationship is governed by a legally binding Data Processing Agreement (DPA) to ensure the provider adheres to strict data protection standards (GDPR, CCPA, etc.).

B. Legal and Compliance

We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of Minerva, or protect the personal safety of users or the public.

6. International Data Transfers

Minerva operates globally. If you access the App from the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), your personal data may be transferred to and processed in the United States or other countries outside of your home jurisdiction.

We ensure that such transfers comply with applicable data protection laws by relying on recognized legal transfer mechanisms, such as the use of Standard Contractual Clauses (SCCs) approved by the European Commission, or through adherence to the EU-U.S. Data Privacy Framework (DPF) (if applicable).

7. Your Privacy Rights (GDPR and CCPA/CPRA)

Depending on your location, you may have the following rights concerning your personal data:

A. GDPR Rights (EEA and UK Residents)

You have the right to:

• Right to Access: Request a copy of the personal data we hold about you. We must provide this information in a commonly used electronic format if the request is submitted electronically.
• Right to Rectification: Request that we correct any inaccurate or incomplete personal data.
• Right to Erasure (Right to Be Forgotten): Request the deletion of your personal data, subject to certain exceptions.
• Right to Restriction of Processing: Request that we limit the way we use your data.
• Right to Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: Object to the processing of your personal data based on our legitimate interests.

We will respond to Data Subject Access Requests (DSARs) within one month of receiving the request.

B. CCPA/CPRA Rights (California Residents)

If you are a California resident, you have the right to:

• Right to Know: Request information about the personal data we collect, use, and share (including the categories of data and the purposes for use).
• Right to Delete: Request the deletion of personal data collected from you (with some exceptions).
• Right to Correct: Request the correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: Minerva must conspicuously provide the right to opt out of the sale or sharing of your personal information.
• “Do Not Sell or Share My Personal Information”: We provide a mechanism to prevent the sale or sharing of your PI with third parties for cross-context behavioral advertising.
• Right to Limit Use of Sensitive Personal Information (SPI): Since the content of your AI prompts may inadvertently contain Sensitive Personal Information (e.g., data revealing philosophical beliefs or health status), you have the right to limit the use and disclosure of this SPI.

You can exercise these rights through the Privacy Settings within the App or by contacting us at the email address provided in Section 1.

8. Children's Privacy

The App is not intended for use by children under the age of 16. We do not knowingly collect personally identifiable information from children under 16.

If a parent or guardian becomes aware that their child has provided us with personal information without their consent, they should contact us immediately at the email provided in Section 1. If we become aware that we have collected Personal Data from a child without verification of parental consent, we will take steps to remove that information from our servers.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy within the App and/or on our website, and by updating the “Effective Date” at the top of this document. We encourage you to review this Privacy Policy periodically for any changes.