1. Introduction

Welcome to MindTime Digital B.V., the primary contracting entity for Clarissimo — a comprehensive suite of Software as a Service applications provided by the MindTime Group. Our suite includes the Dynamics dashboard for organizational development, the Audience Platform for audience measurement and content analysis, Clara AI agent services, and associated websites.

This Privacy Policy explains how we collect, use, and protect your personal data across all Clarissimo services. We are committed to safeguarding your privacy and complying with the General Data Protection Regulation (GDPR) and Dutch law.

Privacy by Default: MindTime Digital B.V. operates under a ‘Privacy by Default’ principle across all systems. Our personnel do not have access to client-specific content or data unless access is explicitly granted through controlled user accounts.

2. Who We Are

MindTime Digital B.V. is a company registered in the Netherlands at Groote Veen, Eelde, the Netherlands

Data Controller Roles:

• For Platform Accounts & Infrastructure: MindTime Digital B.V. is the Data Controller for account management, billing, and platform administration
• For Client Data: Your organization is typically the Data Controller for data you collect through our platforms, with MindTime Digital B.V. acting as Data Processor
• For Websites: MindTime Digital B.V. is the Data Controller for website interactions and communications

3. The Clarissimo Suite

Our platforms are designed for different purposes with no data crossover:

Dynamics Dashboard

Purpose: Organizational development (“inward-looking”)
Users: Facilitators, trainers, coaches, team leaders
Function: Team assessments, group dynamics analysis, organizational development

Audience Platform

Purpose: Audience measurement and content analysis (“outward-looking”)
Users: Marketers, content creators, researchers
Function: Survey creation, audience profiling, content optimization

Clara AI Agent

Purpose: Intelligent assistance across both platforms
Function: Platform guidance, result interpretation, thinking style coaching

4. What Data We Collect

Website Visitors

Information you provide:

• Name and email address through contact forms
• Account registration information
• Any additional information in communications

Information collected automatically:

• Browser and device data (IP address, device type, operating system, browser type)
• Usage data (pages visited, time spent, links clicked, referral sources)
• Cookies for website functionality and analytics

Dynamics Dashboard

Facilitator/Dashboard Owner accounts:

• Name and email address
• Organization information
• Account credentials and session management data

Session participants:

• Names: Real or fictitious (user’s choice based on organizational requirements)
• Email addresses: Used only for survey invitations, then automatically deleted once the survey key is used
• MindTime Survey results: Thinking Style assessments measuring Past, Present, and Future perspectives
• User keys: Unique identifiers for accessing individual results
• Individual reports: Detailed thinking patterns, intensities, and behavioral insights

Privacy commitment: Email addresses are deleted immediately after the survey key is used, ensuring minimal data retention.

Audience Platform

Organization accounts:

• Organization name and address
• Primary contact name and email address
• Billing contact information

Platform users:

• User credentials (name, email, role assignments)
• Permission levels and access rights
• Usage data and session metadata

Survey data (collected on behalf of clients):

• MindTime cognitive profiling responses
• Demographic information (as configured by clients)
• Custom poll responses (as configured by clients)
• Response metadata (date, time, duration, anonymized IP address)

Clara AI Agent

Conversation data:

• User queries and inputs within conversation sessions
• Clara’s responses and recommendations
• MindTime Survey results (to provide personalized coaching)
• Demographics collected (when relevant to assistance)
• Poll responses (coming soon – to enhance content guidance)

Important: Clara processes data within individual conversation sessions only – no data is shared between platforms or across different users’ sessions.

5. How We Use Personal Data

Platform Operations

Account Management (as Data Controller):

• Create and manage platform accounts
• Process billing and subscriptions
• Provide customer support and platform access
• Monitor system security and performance
• Comply with legal obligations

Client Services (as Data Processor):

• Process surveys and generate cognitive profiles per client instructions
• Create team composition maps and diagnostic reports
• Store and analyze data according to client configurations
• Generate insights and analytics as requested

Clara uses your data to:

General Assistance:

• Provide personalized assistance based on your thinking style
• Offer thinking style coaching including leveraging strengths and addressing blind spots
• Guide platform usage and feature navigation

For Dynamics Dashboard:

• Help interpret group results and team dynamics analysis
• Support session preparation for facilitators and coaches
• Analyze team composition and provide insights on group dynamics

For Audience Platform:

• Help interpret survey data and audience insights
• Assist with content analysis and audience profiling
• Guide content/creative iterations and audience targeting strategies
• Guide survey creation and optimization strategies
• Explain audience cognitive patterns and marketing implications

For Website Interactions:

• Demonstrate MindTime concepts and Clara’s capabilities
• Answer general questions about cognitive profiling and our services
• Help users understand how MindTime can benefit their work

Conversation boundaries: Clara maintains strict session boundaries – conversations and insights from one user or system are never shared with others.

6. Legal Basis for Processing

We process personal data based on:

• Contractual necessity – to provide Clarissimo services and fulfill agreements
• Legitimate interest – to improve services, ensure security, and operate our business
• Legal obligation – to comply with applicable laws and regulations
• Consent – for marketing communications and certain analytics

For survey respondents, the legal basis is determined by the client organization conducting the assessment.

7. Platform-Specific User Roles and Access

Dynamics Dashboard

Facilitator/Dashboard Owner:

• Creates and manages all sessions (Individual, Pair, Team)
• Invites participants and manages survey keys
• Accesses all diagnostic tools and participant reports
• Can participate in sessions to compare thinking styles
• Full control over session data and participant access

Audience Platform

Platform Admin (MindTime-Level):

• Creates organization accounts
• Monitors platform usage and subscriptions
• Cannot access project content unless explicitly granted access

Organization Admin:

• Manages all projects within organization
• Controls user access and permissions
• Accesses all survey data within organization

Project Admin:

• Manages specific project users and data
• Controls project-level access and reports

Team Member:

• Accesses assigned surveys and reports
• Downloads filtered data (excluding proprietary MindTime raw data)
• Accesses content analysis tool suite

8. How We Share Personal Data

We do not sell or rent personal data. Data sharing is limited to:

Service Providers

• Utilis (our database management and engineering partner) for cloud hosting on Microsoft Azure and AWS
• Google Workspace for communications
• Payment processors for billing services

All providers are contractually bound to protect data and process only as instructed.

Platform Separation

Important: The Dynamics Dashboard and Audience Platform operate independently with no data crossover. Clara AI assists both systems but maintains strict data boundaries between them.

Legal Requirements

We may disclose data when required by law or to protect rights and safety.

9. Data Security and Retention

General Retention Principle

We retain personal data only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Upon expiration of retention periods, data is securely deleted unless longer retention is required by applicable law.

Security Measures

• Encryption in transit and at rest across all platforms
• Role-based access controls and permission systems
• Regular security audits and penetration testing
• Multi-tenant architecture with logical data separation

Data Retention

Dynamics Dashboard:

• Email addresses: Deleted immediately after survey key usage
• Survey results and reports: Retained per facilitator requirements unless longer retention is required by law or legitimate
• Account data: Retained while account is active, then deleted within 90 days of account closure (or retained for up to 2 years for legal/dispute resolution purposes)

Audience Platform:

• Account data: Retained while account is active
• Survey data: Retained according to client instructions
• Project data: Per project retention policies

Clara AI Agent:

• Conversation history: Retained within session boundaries until account closure, then deleted within 90 days (or retained for up to 2 years in cases involving disputed account closure or terms of service violations)
• Survey results: As per respective platform policies
• User interaction data: Deleted according to the same schedule as conversation history
• No conversation data is shared between users or systems

Website data: Contact forms and analytics retained for 2 years or until deletion requested

10. Your Rights Under GDPR

You have the right to:

• Access your personal data
• Rectify inaccurate information
• Erase your data in certain circumstances
• Restrict processing
• Data portability where technically feasible
• Object to processing based on legitimate interests
• Withdraw consent for consent-based activities

Exercising Your Rights

For Dynamics Dashboard: Contact the facilitator who created your session, or contact us directly 

For Audience Platform: Contact your organization admin or us directly for account issues 

For Website/Marketing: Contact us directly 

For Clara conversations: Contact us to discuss conversation data management

We respond to requests within one month and may verify identity before processing.

11. Cookies and Tracking

We use essential cookies for:

• Platform authentication and session management
• Survey completion and progress tracking
• Website analytics (Google Analytics – 38 months retention)
• Clara AI conversation continuity within sessions

You can control cookies through browser settings, though this may affect platform functionality.

12. International Transfers

Our services are hosted in the European Union. Any future data transfers outside the EEA will include appropriate safeguards such as Standard Contractual Clauses.

13. Clara AI Agent – Specific Privacy Information

Conversation Scope: Clara processes data only within individual conversation sessions and never shares insights between users or platforms.

Data Access: Clara can access your MindTime Survey results and demographic information to provide personalized assistance and thinking style coaching.

Learning Boundaries: Clara learns within conversations to improve assistance, but does not retain learnings across sessions or users.

Cross-Platform Separation: While Clara serves both Dynamics and Audience platforms, she maintains strict data boundaries and never shares information between platforms.

14. Updates to This Policy

We may update this Privacy Policy to reflect service changes or legal requirements. Material changes will be communicated to users with an updated “last updated” date. Continued use constitutes acceptance of updates.

15. Children’s Privacy

Clarissimo services are not directed to individuals under 18. We do not knowingly collect children’s personal data. If you become aware that a child has provided data, contact us immediately.

16. Contact Us

For questions about this Privacy Policy or to exercise your rights:

MindTime Digital B.V.
Groote Veen, Eelde, the Netherlands
Email: digital@mindtime.com

If we cannot resolve your concerns, you may lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

This Privacy Policy covers the complete Clarissimo suite: Dynamics dashboard, Audience Platform, Clara AI agent services, and all associated websites operated by MindTime Digital B.V.