Privacy Policy – PCC Freemind Center

1. Privacy Policy for PCC Freemind

Last Updated: 1st of October 2025

PCC Freemind Privacy Policy

PCC Freemind (“we,” “our,” or “us”) is committed to protecting your privacy and providing a safe, secure environment for all users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the “App”), which connects youths with professional counselors for support in hygiene, mental health, and social well-being.

By using PCC Freemind, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use the App.

This Privacy Policy complies with:

Google Play Developer Program Policies
Apple App Store Review Guidelines
Cameroon Law No. 2010/012 relating to cybersecurity and cybercrime
General Data Protection principles

1. Information We Collect

We are transparent about the data we collect and how we use it. We collect only the information necessary to provide our services.

1.1 Personal Information You Provide

Account Information:

Full name
Email address
Date of birth (to verify age eligibility)
User type (youth or counselor)
Phone number (optional, for account recovery)

Profile Information:

Profile photo (optional)
Bio or introduction
Areas of interest or concern (e.g., mental health, hygiene, social issues)
Preferred counselor attributes
Location (city/region only, never precise geolocation)

Health and Counseling Information:

Mental health concerns and goals
Hygiene-related questions or issues
Social life challenges
Progress notes and session summaries
Self-assessment responses

Communications:

Text messages exchanged with counselors
Voice messages (if feature is used)
Chat history and conversation logs
Appointment scheduling details
Support tickets and inquiries

Payment Information (for Premium Features):

We use secure third-party payment processors (Stripe, PayPal, Mobile Money)
We DO NOT store complete credit card numbers, CVV codes, or full banking details
We only store: payment method type, last 4 digits (for reference), transaction IDs, and billing email
All payment processing is PCI-DSS compliant

Counselor-Specific Information (for verified counselors only):

Professional credentials and certifications
License numbers and verification documents
Specialization areas
Availability schedule
Professional background

1.2 Information Collected Automatically

Usage Data:

Features accessed and frequency of use
Session duration and timestamps
Navigation patterns within the App
Button clicks and user interactions
Search queries within the App
Appointment booking and cancellation history

Device Information:

Device type and model
Operating system and version
Unique device identifiers (anonymized)
App version
Mobile network information (carrier name)
IP address (for security and fraud prevention only)
Time zone and language settings

Performance and Diagnostic Data:

Crash reports and error logs
Performance metrics (app load time, response times)
Network connectivity status
Battery usage (to optimize app performance)

1.3 Information We Do NOT Collect

We explicitly DO NOT collect:

❌ Precise geolocation or GPS coordinates
❌ Access to your contacts without permission
❌ Access to your photo gallery without permission
❌ Microphone access outside of voice messaging feature
❌ SMS or phone call logs
❌ Data from other apps on your device
❌ Clipboard data
❌ Information from children under 13 years old

2. How We Use Your Information

We use collected information for the following specific purposes:

2.1 Service Delivery

Create and manage your account
Match you with appropriate qualified counselors based on your needs and preferences
Facilitate secure counseling sessions (chat, voice, video)
Store conversation history for continuity of care
Send appointment reminders and notifications
Process payments for premium services
Provide customer support

2.2 Service Improvement

Analyze usage patterns to improve app features
Identify and fix bugs or technical issues
Optimize app performance and user experience
Develop new features based on user needs
Conduct internal research and analytics

2.3 Safety and Security

Prevent fraud, abuse, and unauthorized access
Detect and prevent harmful or illegal activities
Verify counselor credentials and qualifications
Monitor for crisis situations requiring intervention
Enforce our Terms of Service
Comply with legal obligations

2.4 Communications

Send important service updates and announcements
Respond to your inquiries and support requests
Send optional promotional messages (only if you opt-in)
Notify you of policy changes

We DO NOT sell, rent, or trade your personal information to third parties for marketing purposes.

3.1 With Your Counselor

Your profile information, health concerns, and chat history are shared with your matched counselor(s) to provide effective support
Counselors are bound by strict confidentiality agreements and professional ethics codes
You can request to switch counselors at any time

3.2 With Service Providers (Third-Party Processors)

We share limited data with trusted vendors who help us operate the App:

Cloud Hosting & Storage:

Firebase (Google) – for database and authentication
AWS or similar – for file storage
Data is encrypted both in transit and at rest

Payment Processing:

Stripe, PayPal, or Mobile Money providers
They have their own privacy policies and security measures

Analytics & Performance:

Firebase Analytics (anonymized usage data only)
Crashlytics (error reporting)
No personally identifiable information (PII) is shared with analytics providers

Communication Services:

Push notification providers (for appointment reminders)
Email service providers (for account emails only)

All third-party service providers:

Are contractually obligated to protect your data
May only use data to perform services for us
Cannot use your data for their own purposes
Must comply with applicable data protection laws

3.3 For Legal Compliance

We may disclose information when required by law:

In response to valid legal requests from Cameroonian authorities under Law No. 2010/012
To comply with court orders, subpoenas, or legal processes
To protect our rights, property, or safety
To protect the rights, property, or safety of our users or the public
To detect, prevent, or address fraud, security, or technical issues

3.4 In Emergency Situations

If we have reasonable grounds to believe there is:

Imminent risk of serious harm to yourself or others
Evidence of child abuse or neglect
Threat of violence

We may disclose necessary information to:

Emergency services (police, ambulance)
Mental health crisis teams
Designated emergency contacts (if provided by you)

Our counselors are trained to recognize crisis situations and follow established emergency protocols.

3.5 Business Transfers

In the event of a merger, acquisition, or sale of assets:

We will notify you via email and/or prominent notice in the App
Your data will be transferred only under the same privacy protections
You will have the option to delete your account before the transfer

We may share information in other circumstances with your explicit consent.

4. Data Security Measures

We implement industry-standard security measures to protect your data:

4.1 Technical Security

Encryption:

All data transmitted between your device and our servers uses TLS 1.3 encryption (HTTPS)
All sensitive data at rest is encrypted using AES-256 encryption
Chat messages and health information are end-to-end encrypted where technically feasible

Password Security:

Passwords are one-way hashed using bcrypt/Argon2 algorithms
We CANNOT see, retrieve, or access your password
Even our administrators cannot log into your account without your password
Password reset requires email verification
Minimum password requirements enforced (8+ characters, mix of types)

Authentication:

Secure session management with automatic timeout
Two-factor authentication available (optional)
Biometric authentication support (fingerprint, Face ID)

Infrastructure Security:

Secure, certified cloud hosting providers
Regular security audits and penetration testing
Automated backup systems with encryption
DDoS protection and firewall systems

4.2 Organizational Security

Limited employee access to personal data (need-to-know basis only)
All staff sign confidentiality agreements
Regular security training for all team members
Counselors undergo background checks and credential verification
Incident response plan for data breaches

4.3 Your Role in Security

To keep your account secure:

✅ Use a strong, unique password
✅ Enable two-factor authentication
✅ Never share your password with anyone
✅ Log out after using shared devices
✅ Keep your app updated to the latest version
✅ Report suspicious activity immediately

Important: While we implement robust security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, but we continuously work to protect your information.

5. Your Data Rights and Choices

Under Cameroonian law and international data protection principles, you have the following rights:

5.1 Access and Portability

Access: Request a copy of all personal data we hold about you
Portability: Receive your data in a structured, commonly-used, machine-readable format (JSON, CSV)
Timeline: We will respond within 30 days

5.2 Correction and Update

Update your profile information anytime in the App settings
Request correction of inaccurate or incomplete data
We will update your information within 7 days of verification

5.3 Deletion (Right to be Forgotten)

Request account deletion at any time via App settings or email
What gets deleted:
- Account credentials
- Profile information
- Personal health data
- Chat history
- Payment records (except as required for legal/accounting purposes)
Timeline: Deletion completed within 30 days
Note: Some data may be retained for legal compliance (e.g., financial records for 7 years)

5.4 Restriction and Objection

Object to certain data processing activities
Restrict processing of your data under specific circumstances
Opt-out of marketing communications (you’ll still receive service-related messages)

5.5 Data Retention Control

You can request early deletion of specific data (e.g., old chat logs)
You can download your data before deletion

5.6 How to Exercise Your Rights

To exercise any of these rights:

Email: privacy@pccfreemind.com
In-App: Settings → Privacy → Data Rights
Mail: PCC Freemind, Buea, Southwest Region, Cameroon

We will verify your identity before processing requests.

6. Data Retention

We retain your personal information only as long as necessary:

Data Type	Retention Period	Reason
Account Information	Until account deletion	Service provision
Chat/Session History	Until account deletion or 3 years	Continuity of care
Payment Records	7 years after transaction	Legal/tax requirements
Usage Analytics	2 years (anonymized)	Service improvement
Crash Logs	90 days	Technical debugging
Deleted Account Data	30 days (backup retention)	Recovery window

After deletion:

Data is permanently removed from active systems within 30 days
Backup copies are overwritten within 90 days
Some anonymized, aggregated data may be retained indefinitely for research (cannot identify you)

7. Permissions and APIs We Use

We request only necessary permissions and are transparent about their use:

7.1 Required Permissions

Camera (iOS & Android):

Purpose: Profile photo upload, sharing images with counselor
When used: Only when you tap “Take Photo” or “Video Call”
Can be denied: Yes, you can still use the app without camera access

Microphone (iOS & Android):

Purpose: Voice messages, audio/video calls with counselors
When used: Only during calls or when recording voice messages
Can be denied: Yes, text chat will still work

Photo Library (iOS & Android):

Purpose: Upload existing photos to profile or share with counselor
When used: Only when you tap “Choose from Gallery”
Can be denied: Yes, you can use camera instead or skip

Notifications (iOS & Android):

Purpose: Appointment reminders, new messages from counselor
When used: For time-sensitive communications
Can be denied: Yes, but you may miss important updates

Internet Access (Android):

Purpose: Connect to our servers for all app functionality
When used: Always (app requires internet)
Can be denied: No, app requires internet to function

7.2 Optional Permissions

Biometric (Fingerprint/Face ID):

Purpose: Quick, secure login
When used: Login screen (if enabled in settings)
Can be denied: Yes, use password instead

Calendar (Optional feature):

Purpose: Add counseling appointments to your calendar
When used: Only if you choose “Add to Calendar”
Can be denied: Yes

7.3 Permissions We NEVER Request

❌ Phone calls or SMS
❌ Contacts access
❌ Location (GPS)
❌ Other apps’ data
❌ Background location
❌ Device admin privileges

7.4 API Usage

We use Google Play Services for push notifications (Android)
We use Apple Push Notification Service (iOS)
We use Firebase Authentication for secure login
All API usage complies with provider policies

8. Children’s Privacy (COPPA and Age Requirements)

8.1 Age Restrictions

Minimum Age: 13 years old globally, 16 in some regions
Users Under 18: Encouraged to use app with parent/guardian knowledge
We do NOT knowingly collect data from children under 13

While we strongly encourage parental involvement, we do not require parental consent for ages 13-17 as our service provides important mental health support
Parents/guardians can contact us to request account deletion for minors
We provide age-appropriate counseling with trained youth specialists

8.3 If We Discover Underage Users

If we learn we’ve collected data from a child under 13:

We will delete the account immediately
We will erase all associated data within 30 days
We will not use the data for any purpose

Parents: If you believe your child under 13 has created an account, contact us immediately at privacy@pccfreemind.com.

9. International Data Transfers

Primary Data Location: Our servers are located in [specify region, e.g., Europe, USA]

Cross-Border Transfers:

Some service providers may process data outside Cameroon
All transfers are protected by:
- Standard Contractual Clauses (EU-approved)
- Privacy Shield or equivalent frameworks
- Encryption in transit and at rest

Your data is protected regardless of where it’s processed.

10. Google Play and App Store Compliance

10.1 Google Play Target API Level Policy

Our app targets Android API Level 34 (Android 14) or higher
We comply with the latest Google Play security and privacy requirements
We regularly update our app to meet new policy requirements

10.2 Deceptive Behavior – We Commit To:

❌ NO misleading app descriptions or features
❌ NO impersonation of other apps or entities
❌ NO false claims about app functionality
✅ Transparent about what our app does and doesn’t do
✅ Honest marketing and app listings

10.3 Device and Network Abuse – We Will NOT:

❌ Interfere with other apps or device functionality
❌ Alter device settings without user permission
❌ Use excessive data, battery, or system resources
❌ Display ads outside our app
✅ Optimize for performance and battery efficiency

10.4 User Data Protection – We Guarantee:

✅ Transparent data collection practices (this policy)
✅ Secure data transmission and storage
✅ Limited data collection (only what’s necessary)
✅ User control over their data
✅ No selling of user data
✅ Prominent disclosure of sensitive data access

10.5 Sensitive Permissions Handling

We handle sensitive permissions responsibly:

Request permissions only when needed (runtime permissions)
Explain why each permission is needed (in-app messages)
Allow users to deny permissions and still use core features
Never request permissions deceptively

11. Third-Party Links and Services

The App may contain links to third-party websites or services (e.g., educational resources, crisis hotlines).

Important:

We are NOT responsible for the privacy practices of third-party sites
Third-party sites have their own privacy policies
We encourage you to review their policies before providing any information
Leaving our App to visit third-party sites is at your own risk

12. Marketing and Communications

12.1 Types of Communications

Service Communications (Cannot opt-out):

Account verification emails
Appointment confirmations and reminders
Security alerts
Policy updates
Payment receipts

Marketing Communications (Can opt-out):

New features and updates
Special offers or promotions
Wellness tips and resources
Surveys and feedback requests

12.2 How to Opt-Out

Click “Unsubscribe” in any marketing email
Adjust notification preferences in App settings
Email preferences@pccfreemind.com
You’ll still receive essential service communications

13. Analytics and Cookies

13.1 Mobile App Analytics

We use Firebase Analytics to understand app usage:

Data collected: Session duration, features used, user flows (anonymized)
Purpose: Improve app performance and user experience
NO personal identifiers are sent to analytics
You can opt-out in App settings → Privacy → Analytics

13.2 Cookies (Web Version Only)

If we launch a web version:

Essential cookies for functionality (cannot be disabled)
Analytics cookies (can be disabled)
No advertising or tracking cookies
Cookie consent banner will be displayed

14. Data Breach Notification

In the unlikely event of a data breach:

Our Response:

Immediate investigation and containment
Assessment of affected data and users
Notification to affected users within 72 hours via email
Notification to relevant authorities as required by law
Detailed explanation of what happened and what data was affected
Steps we’re taking to prevent future breaches
Recommendations for protecting yourself

Your Actions:

Change your password immediately
Monitor your accounts for suspicious activity
Enable two-factor authentication
Contact us with any concerns

15. California Privacy Rights (CCPA)

If you’re a California resident, you have additional rights:

Right to know what personal information is collected
Right to know if personal information is sold (we DON’T sell data)
Right to delete personal information
Right to opt-out of sale (not applicable as we don’t sell)
Right to non-discrimination for exercising rights

Contact for CCPA requests: privacy@pccfreemind.com with “CCPA Request” in subject line.

If you’re in the EU/EEA, you have additional rights under GDPR:

Right to data portability
Right to restriction of processing
Right to object to processing
Right to lodge a complaint with your local Data Protection Authority

Legal Basis for Processing:

Consent (for optional features)
Contract performance (to provide services)
Legal obligation (to comply with laws)
Legitimate interests (to improve services, prevent fraud)

Data Protection Officer: dpo@pccfreemind.com

17. Updates to This Privacy Policy

17.1 How We Notify You

We may update this Privacy Policy periodically:

Minor changes: Updated on this page with new “Last Updated” date
Material changes: Email notification + in-app alert
You’ll be asked to review and accept major changes

17.2 Version History

We maintain previous versions of this policy:

Current version: 1.0 (January 10, 2025)
Access previous versions: privacy@pccfreemind.com

17.3 Continued Use

Continued use of the App after changes means you accept the updated policy.

18. Contact Us

We’re committed to addressing your privacy concerns:

For Privacy Questions or Requests:

Email: privacy@pccfreemind.com
Support: support@pccfreemind.com
Mail: PCC Freemind Privacy Team
Buea, Southwest Region
Cameroon

Response Time: Within 5 business days for initial response, 30 days for full resolution

For Counselor-Related Issues:

Email: counselors@pccfreemind.com

For Data Breaches or Security Issues:

Emergency Email: security@pccfreemind.com

19. Governing Law

This Privacy Policy is governed by the laws of Cameroon, including:

Law No. 2010/012 of 21 December 2010 relating to cybersecurity and cybercrime in Cameroon
Any applicable international data protection agreements

Disputes shall be resolved under Cameroonian jurisdiction.

By using PCC Freemind, you consent to:

This Privacy Policy
Our collection and use of information as described
Transfer of data as described in this policy

If you do not agree, please do not use the App.

Summary of Key Points

✅ We protect your privacy: Your data is encrypted and secure
✅ We don’t sell data: Your information is never sold to third parties
✅ You have control: Access, correct, or delete your data anytime
✅ Passwords are secure: We can’t see your password (one-way hashed)
✅ Transparent practices: We’re clear about what data we collect and why
✅ Counselor confidentiality: Your sessions are private and secure
✅ Minimal permissions: We only request necessary access
✅ You can delete your account: Full data deletion within 30 days

Thank you for trusting PCC Freemind with your mental health journey. Your privacy and security are our top priorities.

This Privacy Policy is effective as of January 10, 2025. Last updated: January 10, 2025.

Version 1.0