Privacy Policy

miratempo offers paid subscriptions. Web payments are processed by mono, app subscriptions by the App Store (iOS) and Google Play (Android). We do not store the full card number or CVV, and session payments between the specialist and the client stay direct and do not go through miratempo.

This Policy explains what personal data we process, why it is needed, who it may be shared with, how long it is kept, and how you can exercise your rights. The service is primarily governed by Ukrainian personal data protection law. If GDPR or ePrivacy rules apply to your situation, we also take those requirements into account.

1. Data controller

miratempo's operator and controller for account data is a sole proprietor (FOP) registered in Ukraine.

2. What data we process

3. Why we process data

Data is needed to create accounts, confirm email addresses, show booking pages, manage schedules, send service emails, give guests access to their own bookings, protect accounts, prevent abuse, comply with legal obligations, support integrations enabled by the user, and keep the service running reliably.

For GDPR situations, legal grounds may include performance of a contract or user request, legitimate interest in service security and stability, compliance with legal obligations, and consent where it is required, for example to connect an integration, receive push notifications, or store optional data.

4. Cookies, localStorage and similar technologies

We do not use advertising, marketing or analytical cookies. The browser uses only first-party technically necessary cookies: session cookies for sign-in and guest access, CSRF cookies for protected actions, mt_cookie_consent to remember the display of the cookie message and mt_app_access=coach as an optional hint for the marketing site to show the specialist a link back to the dashboard, mt_locale for the language preference, mt_timezone for the specialist profile's initial time zone, and mt_phone_country for the initial country code in empty phone fields. mt_app_access does not authorize access and does not replace a login session; mt_phone_country and mt_timezone are not used for authorization, identity, billing, eligibility, profiling, advertising, analytics, or legal/compliance decisions.

On miratempo domains, these technical marks may be shared by miratempo.com and app.miratempo.com. Preference cookies are generally kept for up to 12 months unless you change or clear them earlier. Cloudflare may provide a two-letter country code through CF-IPCountry or request.cf.country; miratempo uses this country-level hint only for first-visit language routing and the initial phone prefix. The browser time zone is used first, and request.cf.timezone is used only as a fallback hint for the booking page's initial time zone. miratempo does not request precise browser or device geolocation through navigator.geolocation. The product also uses localStorage for the frontend theme, side panel state, and referral code from the link ?ref=CODE. The referral code is stored for up to 30 days and is only used for prefilling registration or role activation.

In the mobile application, the login token is stored in secure storage when the native plugin is available, or in localStorage for test web shells. Push notifications are enabled only after the specialist takes action in the application settings.

5. Providers and data transfer

For the operation of the service, we use technical suppliers: Hetzner for backend hosting and database, Cloudflare for DNS, frontend/marketing delivery, Turnstile protection, R2 storage, and country/timezone request hints for language, time zone, and phone defaults, Resend for transactional emails, Sentry for error diagnostics only when DSN is enabled, Google API for Calendar/Meet integration, mono for web subscription payments, Apple App Store for iOS subscriptions, and Google Play for Android subscriptions.

Data may be accessible to clients or guests only within the specific booking or separately assigned form to which the specialist has granted access. Roles for form data are described in the forms section below. We may also disclose data where necessary for security, abuse investigations, compliance with law, or protection of the rights of miratempo, users or third parties.

User Google data is not sold, rented, or shared with advertising platforms, data brokers, or information vendors, and is not used for advertising, profiling, resale, or AI training. Use and transfer of information received through the Google API complies with Google API Services User Data Policy, including Limited Use requirements. Team access to Google data is possible only for security, bug fixes, user-requested support, or legal compliance.

6. Data protection

We use HTTPS in the production environment, secure cookie settings, CSRF protection for actions in the browser, email verification, role-based access control, rate limits for sensitive public requests and login requests, separate production secrets, encryption of private fields, and keyed hashes for exact lookup of private identifiers.

Private fields, including Google OAuth tokens, links to meetings, guest access codes, contacts, details, private specialist notes and assignments, push tokens, and payment tokens for subscriptions purchased on the site are encrypted in the database when stored. Email addresses and guest access codes are searched through keyed hashes, not through plaintext queries.

Encryption in the database is meant to protect the data in storage, but it is not a claim of end-to-end or zero-knowledge encryption. Private specialist work notes are not shown to clients or guests; assignments are a separate feature a specialist can intentionally share through protected booking access. Team access to production data is limited to operational need, security, support at the user's request, or legal compliance.

Google Calendar is requested only after the specialist takes action to connect the integration. Current Google scope: https://www.googleapis.com/auth/calendar.events.owned. After disabling Google Calendar, the integration becomes inactive, and the access token and refresh token are cleared.

7. Deletion, anonymization and storage periods

You can delete the account in settings after confirming the current password. For the client role, we anonymize related bookings and contact details. For the specialist role, we delete the workspace, including clients, bookings, services, notes, education documents, details, and profile photo. If the account has both roles, both actions apply.

Technical logs, backups, security records, billing events or records required for legal defense may be kept for a limited time after account deletion. Data that is no longer needed is deleted or anonymized.

8. Your rights

You can request access, correction, deletion, restriction, data transfer, withdrawal of consent where processing depends on consent, or object to processing. Some of the actions can be performed independently in account settings. For other inquiries, write to support@miratempo.com.

In Ukraine, a complaint regarding the protection of personal data can be filed with the Ukrainian Parliament Commissioner for Human Rights. If your situation is covered by the GDPR, you can also contact the supervisory authority in an EEA country.

Forms, questionnaires, and health information

When Forms is available, a practitioner may assign a custom form or a standardized questionnaire to a saved client. We process the exact question and language version, practitioner and recipient details, private server drafts, submitted answers, notice and consent records, access and delivery metadata, and retention decisions. Standardized PHQ-9/GAD-7 submissions also produce an encrypted numerical total and calculation version, or an incomplete result when scored answers are missing. Answers and totals may be health data or other sensitive personal data.

The practitioner determines the purpose, recipients, lawful basis, suitability of the form, and retention period for their practice records. For those records, the practitioner acts as controller and miratempo processes data on their documented instructions. miratempo is independently responsible as controller for account administration, subscriptions, security, and its own legal obligations. A general legal basis and an applicable condition for processing health data are both required where GDPR applies; a contract, a checked notice, or selecting a setting does not by itself satisfy the health-data condition.

Drafts are private to the answering client until submission. Submitted answers are accessible to the assigning practitioner and the authorized client or guest; calculated totals and compatible history appear in the practitioner workspace. Authorized operational access is limited to support, security, and legal needs. Forms are not monitored in real time, and answers do not trigger emergency intervention. Questionnaire answers and results are not used for advertising, tracking, resale, or AI training. Notification payloads omit answers and results; delivery providers receive only the information needed for invitations and service messages.

Drafts expire after 30 days of inactivity. Submitted answers and calculated results use the finite retention period selected by the practitioner and recorded when the form is assigned; the period runs from submission. A documented lawful retention hold can delay erasure and has a review date. Corrections use a separate linked record rather than overwriting submitted answers. Authorized erasure removes drafts, answers, calculated revisions, and associated private snapshots and access data. Backups expire under the backup schedule; erasure and retention cleanup must be reapplied after restoration before restored data is used.

You can contact the practitioner who assigned the form or support@miratempo.com to request access, correction, erasure, restriction, or withdrawal of consent where consent is the basis. Withdrawal does not affect the lawfulness of prior processing. The answer download is a copy of answers and form content, not a complete response to an access request: calculated results and other applicable personal data are handled through the access-request procedure. Account deletion and erasure of a practitioner-held record are separate requests where retention duties apply. We coordinate requests with the practitioner and identify any applicable retention exception.

The technical providers listed in this policy support the service; questionnaires are not sent to Pfizer when displayed or scored. Opening a source citation visits the publisher’s website. Any international transfer must have an applicable legal mechanism. The practitioner is responsible for recipient suitability, including age, capacity, and any required representative consent; assigning a questionnaire does not establish that it is appropriate for every age or situation.