Last updated: 27 June 2019
Our Commitment to Privacy
- Personal Data we Collect
- How we Use Personal Data
- How we Disclose Personal Data
- Your Rights and Choices
- Security and Retention
- Use by Minors
- Links to Other Websites
- Contact Us
Stichting the MindTime Foundation (collectively “MindTime”, “we” and “us”) obtains Personal Data about you from various sources to provide our Services and to manage our Sites. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User” or “MindTime User”), or a customer of a User (“Customer”). If you are a Customer, MindTime will generally not collect your Personal Data directly from you. Your agreement with the relevant MindTime User should explain how the MindTime User shares your Personal Data with MindTime, and if you have questions about this sharing, then you should direct those questions to the MindTime User.
a. Site visitors
If you visit or use our Sites, we may collect Personal Data. For example, we collect Personal Data that you submit to us via online forms and surveys, and when you contact us by email.
b. Survey processing services (MindTime as a data processor)
c. Activities for offering a compliant and secure platform
The collection and use of Personal Data is critical in helping us to ensure that our platform and services are safe, secure, and compliant. In the context of monitoring Sites and Services for abuse, we may monitor insights and patterns to reduce the risk of harmful activity for ourselves, our Users, and their Customers.
2. Personal Data We Collect
a. Personal Data that we collect about you
Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites will be apparent from the context in which you provide the data. In particular:
- When you register for a mindtime.com account we collect your full name, email address, and account log-in credentials.
- When you fill-in our online contact form, we collect your full name, email, and anything else you tell us in the body of your message.
- When you complete the online Thinking Styles Profile we collect anonymised IP address information and your results.
When you respond to MindTime emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact Us by phone, we will collect the phone number you use to call. If you contact us by phone as a MindTime User, we may collect additional information in order to verify your identity.
If you are a MindTime User, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also receive financial and personal information about you, such as your date of birth and government identifiers associated with you and your organisation (such as your social security number, tax number, or Employer Identification Number).
If you are a Customer, when you use MindTime Services through a MindTime User’s website or application, we will receive your Profile information. Depending on how the MindTime User implements our Services, we may receive this information directly from you, or from the MindTime User or third parties. The information that we collect will include Profile responses, anonymised IP address, and date of submission.
You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program, or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows, conferences, or other events.
How do you get my consent?
When you provide us with personal information to complete a transaction, place an order, arrange for a delivery or return a purchase, we ask that you consent to our collecting it and using it for that specific reason only.
How do I withdraw my consent?
If you change your mind after opting-in, you may withdraw your consent for us to contact you, and for the continued collection or use of your information, at any time, by contacting us.
b. Information that we collect automatically on our Sites
- Browser and device data, such as anonymised IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
- Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
We use Google Analytics on our Sites to help us analyse Sites usage and diagnose technical issues.
3. How We Use Personal Data
a. Our products and services
We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests.
Contractual and pre-contractual business relationships. We use Personal Data for the purpose of entering into business relationships with prospective MindTime Users, and to perform the contractual obligations under the contacts that we have with MindTime Users. Activities that we conduct in this context include:
- Creation and management of MindTime accounts and MindTime account credentials, including the evaluation of applications to commence or expand the use of our Services;
- Creation and management of orders on mindtime.com; and
- Accounting, auditing, and billing activities.
Legal and regulatory compliance. We use Personal Data to correctly apply taxes and fulfil financial reporting obligations. For example, we may be required to record and Customer’s order location for the purpose of compliance with EU VAT regulation. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.
Legitimate business interests. We rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose Personal Data we process. We:
- Monitor, prevent and detect fraud and unauthorised use;
- Mitigate financial loss, claims, liabilities or other harm to Users and MindTime;
- Respond to inquiries, send service notices, and provide customer support;
- Promote, analyse, modify, and improve our products, systems, and tools, and develop new products and services;
- Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimising our digital assets;
- Analyse demand and advertise our products and services;
- Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
- Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business;
- Ensure network and information security throughout MindTime and our Services; and
- Transmit Personal Data within our affiliates for internal administrative purposes.
Thinking Styles Profile and related services (MindTime as a data processor). As a processor of our proprietary Profile, we use Personal Data of our User’s Customers to process profiles on behalf of our Users. All such use is pursuant to the terms of our business relationships with our Users. In addition, we may offer MindTime consulting services to Users who have requested such services, and our delivery of such related services to our Users may involve the use of Personal Data. The entity responsible for the collection and use of Customer’s Personal Data in the context of payment transactions and payment-related services is the User.
If we need to use your Personal Data in other ways, we will provide specific notice at the time of collection and obtain your consent where required by applicable law.
b. Marketing and events-related communications
We may send you email marketing communications about MindTime products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. When we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, invite you to opt in to our marketing information campaigns.
c. Interest-based advertising
When you visit our Sites or online services, both we and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser (including the use of pixel tags). Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.
We work with Google AdWords and other advertising networks. To learn how to opt out of behavioural advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initiative and Digital Advertising Alliance. You may download the AppChoices app to opt out in mobile apps. If you opt out from interest-based advertising, you may see advertising that is not relevant to you. At present, there is no industry standard for recognising Do Not Track browser signals, so we do not respond to them.
4. How We Disclose Personal Data
MindTime does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
a. MindTime. We share Personal Data with other MindTime entities in order to provide our Services, for internal administration purposes, and for product research.
b. Service providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorise such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements, and in an anonymous manner wherever possible. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.
c. Business partners. We share Personal Data with third party business partners when this is necessary to provide our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment processors (such as Stripe or PayPal).
e. Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.
f. Compliance and harm prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of MindTime, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
5. Your Rights and Choices
You have choices regarding our use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will complete your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.
b. How you can see or change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your account or by contacting us.
c. Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
- The right to request confirmation of whether MindTime processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
- The right to request that MindTime rectifies or updates your Personal Data that is inaccurate, incomplete, or outdated;
- The right to request that MindTime erase your Personal Data in certain circumstances provided by law;
- The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time.
d. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact MindTime as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data.
For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire, or process additional information in order to identify you for the purpose of responding to your request.
If you are a Customer of a MindTime Services User, please direct your requests directly to the User.
6. Security and Retention
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing and control of Personal Data. We maintain organisational, technical, and administrative measures designed to protect Personal Data within our organisation against unauthorised access, destruction, loss, alteration, or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.
If you use MindTime Services, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, even if you close your MindTime account, to the extent necessary to comply with our legal and regulatory obligations. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
Google Analytics data is retained for 38 months.
7. Use by Minors
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Services.
9. Links to Other Websites
The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.
10. Contact Us
If you would like to: view, amend, or delete any personal information we may hold about you, register a complaint, offer suggestions for improvement, or want more information, contact our Data Protection Officer via our contact form or write to:
Stichting the MindTime Foundation,
Attn.: Legal and Privacy
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