Privacy Policy MindNavigator

Version 2.4 — GDPR Compliant (Extended)

Last updated: April 16, 2026 | Effective date: April 16, 2026

Quick overview — What you need to know

MindNavigator respects your privacy and protects your data in line with the GDPR. We only collect data that is necessary for our platform and never share it for commercial purposes.

For parents: Your child has privacy rights and autonomy, but you have certain rights of access and deletion rights if your child is under 16. Children can manage their own privacy settings, but only you can permanently delete all data.

For young people: Your data is safe with us. You decide a lot about your own privacy (what your parents see), depending on your age. You can always export your data and delete older data. For complete deletion we apply extra safeguards to help you.

Questions? Email us at privacy@mindnavigator.io

1. Who are we and why this policy?

1.1 Data controller

MindNavigator B.V.
Address: Will be published after Chamber of Commerce registration
Chamber of Commerce (KvK): Pending (will be published here once available)
Email: privacy@mindnavigator.io
Website: www.mindnavigator.io

1.2 Data Protection Officer

Data Protection Officer (DPO):
Glenn Bosch (the data controller currently fulfils the DPO role)
Email: dpo@mindnavigator.io
For all privacy-related questions and complaints. As we scale up, an independent DPO will be appointed.

1.3 Why this policy?

Transparency: You have the right to know what happens with your data.
Control: You must be in control of your personal information.
Legal obligation: The GDPR requires this of us.
Trust: Your trust is the foundation of our collaboration.

2. What data do we collect?

2.1 Account data (Required)

Name, email address, date of birth, encrypted password, and IP address.

2.2 Profile data (Optional)

School information, interests, goals, and preferences.

2.3 Platform usage (Automatic)

Tool responses, progress data, login activity, and platform behaviour.

2.4 Communication data

Messages with customer support and guides, feedback, and notifications.

2.5 Payment data (Only for paid subscriptions)

Billing details, type of payment method (no card details), and transaction history.

2.6 AI-generated content

Personalised reports, coaching suggestions, and progress analyses.

AI chat conversations (Dr. Florentine Forest): As a premium feature you can chat with our AI expert. This works as follows:

Chat messages are not permanently stored (stateless processing)
Child context (name, age group, scores) is passed to the AI for personalised advice
Token usage is tracked for cost management (no personal content)
Rate limiting: maximum 30 messages per hour per user

2.7 Retention periods (GDPR Art. 5.1.e)

We do not retain your data longer than necessary. Retention periods are:

Account data: As long as the account is active. Deleted immediately upon confirmation of account closure (two-step via email token); only financial data is retained longer due to legal obligations (see below).
Quiz answers & brain-type profiles: Up to 3 years or as long as the account is active, whichever comes first. Automatic deletion via cleanup cron thereafter.
Energy tracking data: 180 days for pattern analysis, then automatic deletion. You can also delete older data yourself sooner.
Progress data (XP, badges, streaks): As long as the account is active
IP addresses (security): 90 days
Login history: 1 year
Communications (support, messages): 3 years after last message
Proof of parental consent: 2 years (Dutch Implementation Act art. 5 — proof of consent for processing data of minors)
Financial data (billing): 7 years (legal obligation — Dutch tax authority; only relevant once premium functionality is activated)
Backup data: Maximum of 30 days after deletion from production database

On account deletion: Account closure happens in two steps — you receive a confirmation email with a unique link valid for 24 hours. After confirmation, your account is deleted immediately from the production database; backups are purged within 30 days. Proof of parental consent is retained for 2 years due to legal obligation; financial data is retained for 7 years for the Dutch tax authority.

2.8 Cookies and tracking

MindNavigator uses minimal cookies for basic functionality:

Strictly necessary cookies (no consent required):

Session cookie: Keeps you logged in (expires after 24 hours)
Preferences cookie: Remembers language/theme choice (expires after 1 year)
Security cookie: CSRF protection (expires after session)

Optional cookies (consent required):

Analytics cookie (Google Analytics): Anonymous usage statistics with IP anonymisation (expires after 24 hours — 2 years, depending on cookie type)

No tracking cookies:

✗ No advertising cookies
✗ No social media tracking
✗ No cross-site tracking
✗ No third-party cookies

Managing consent:

First visit: Cookie banner with choice of options
Change: Via Account Settings → Cookie Preferences
Browser settings: You can also manage cookies via your browser

For full information: www.mindnavigator.io/cookies

2.9 Beta programme data

During the beta phase of MindNavigator we collect additional data from beta testers:

Registration data: Email address, name, registration date
Verification status: Whether the account is verified, number of reminder emails sent
Beta feedback: Feedback about features, including any screenshots

Retention period: Duration of the beta programme + 6 months after it ends.

Legal basis: Consent (Art. 6.1.a GDPR) — you give consent when signing up for the beta programme.

3. Why do we collect this data? (GDPR legal bases)

3.1 Contract performance (Art. 6.1.b GDPR)

To provide our services, such as account management, platform functionality and customer support.

3.2 Legitimate interest (Art. 6.1.f GDPR)

For platform improvement, security and (anonymous) research.

3.3 Consent (Art. 6.1.a GDPR)

For optional features we explicitly ask for your consent via:

Clear opt-in checkboxes (not pre-ticked)
Separately per feature (not bundled)
Freely withdrawable via Account Settings
No impact on core functionality if declined

Optional features we ask consent for:

Newsletters and product updates
Participation in research (anonymous)
Advanced personalisation (additional AI analysis)
Marketing emails about new features

3.4 Legal obligation (Art. 6.1.c GDPR)

Where the law requires it, such as retaining tax data for 7 years.

4. Special protection for minors (GDPR Art. 8)

4.1 Children aged 6-11 (young children)

Parental consent always required — children in this age group cannot create their own account.
The account is created and managed by the parent/guardian.
The parent has full control and access to all data.
No community features: No messaging, no social interaction, no coach connections.
Adapted interface: Playful, gamified environment with short sentences and visual elements, tailored to the age.
The parent manages all privacy settings — the child has no separate control here.

4.2 Children aged 12-15

Parental consent required for all data processing.
Parents have the right of access, rectification and erasure of their child's data.
The child can manage privacy settings themselves (what parents see), but cannot delete all data.

4.2.1 How does parental consent work?

When a child (12-15) registers, we follow this process:

Child enters basic data: Name, date of birth, email address
System detects age: Automatic check whether the child is under 16
Parent email address requested: Child enters parent/guardian email address
Parent receives verification email with:
- Explanation of MindNavigator and what we do
- Link to this full privacy policy
- Overview of the data we collect
- "I give consent" button (active opt-in)
The account is only activated after parental confirmation

If consent is refused:

The account is not activated
All submitted data is permanently deleted within 7 days
Both parent and child receive a notification
The child can re-register with a different parent email address

💡 Withdrawing consent: Parents can withdraw their consent at any time via Account Settings → Parental Supervision → "Withdraw Consent". The account is then deleted within 7 days.

4.3 Young people aged 16-17

Young people can give their own consent and fully manage their privacy.
They can delete their own data, with a 7-day reflection period and parental notification.
Parental involvement is still required for payments and in case of safety concerns.

4.4 Privacy between parent and child

12-15 year olds: Parents can see progress and patterns, but not private messages or individual energy check-ins.

16-17 year olds: Young people decide what parents see, except for payment-related information.

4.5 Energy tracking privacy

Children decide themselves what is shared with parents:

Shared by default (12-15 years): Weekly patterns, best times of the day, warning when there are concerns (5+ days tired).
Always private: Every individual energy check-in moment, messages with coaches, specific quiz answers.
Child can adjust: Via "Privacy Settings" in the dashboard with 3 levels (Share Less / Normal / Share More).

4.6 How we secure your data (GDPR Art. 32)

Technical measures:

Encryption in transit: All communication via HTTPS/TLS 1.3
Encryption at rest: Database encrypted with AES-256
Password security: Bcrypt hashing with salt (industry standard)
Access control: Multi-factor authentication for employees
Network security: Firewall, DDoS protection, intrusion detection
Logging: All access to data is logged (retained 1 year)

Organisational measures:

Minimal access: Employees only have access to data required for their work
Background checks: All employees with data access are screened
Privacy training: Mandatory GDPR training for all employees
Processor agreements: All external parties sign Data Processing Agreements
Annual audit: External security audit by a certified party

Incident response:

Breach detection: Real-time monitoring for suspicious activity
Notification deadline: Within 72 hours of discovering a breach
Breach assistance: Free identity protection for 1 year in the event of a serious breach
Incident contact: dpo@mindnavigator.io

Testing & updates:

Penetration testing: Twice a year by an external party
Bug bounty programme: Responsible disclosure rewarded
Security updates: Within 48 hours of discovering a critical vulnerability

5. Data Deletion — Who Decides?

🔐 Important information for parents and children

We apply an age-based approach to data deletion, to protect children from impulsive decisions while respecting their autonomy.

5.1 Children aged 12-15

The child CAN:

Export their data (GDPR Art. 20 — Data portability)
Delete older data (older than 6 months)
Adjust privacy settings (what parents see)

The child CANNOT:

Delete all data — Parental consent is required for this

Why this choice?

Protection against impulsivity: Children at this age can make impulsive decisions (especially with ADHD/ASD traits), which they may later regret.
Safety: The data contains valuable insights for support and coaching. Permanent deletion can make guidance harder.
GDPR compliant: This is consistent with Art. 8 GDPR, which requires parental consent for data processing of minors under 16.
Educational: The child learns the difference between daily data management (privacy settings) and permanent deletion.

💡 Alternative for the child: Does your child want the data deleted? They can send a "Deletion Request" to you via the dashboard. You'll receive a notification and can discuss together whether this is needed.

5.2 Young people aged 16-17

The young person CAN:

Export data
Delete older data (>6 months)
Delete all data, with additional safeguards:

Additional safeguards for full deletion (16-17 years):

Extensive warning about consequences
Parent automatically receives a notification
7-day reflection period (deletion is only final after 7 days)
Option to cancel the deletion within 7 days

5.3 Adults (18+)

Full control over your own data:

Export, delete, and manage without restrictions
Direct deletion available (with confirmation)

5.4 How does deletion work for parents?

As a parent of a child <16, you can via the Parental Dashboard manage your child's data:

Log in to your Parental Dashboard
Go to "Data Management" under your child's profile
Choose "Delete Data" and confirm by typing: DELETE MY CHILD'S DATA
Data is deleted directly and permanently (cannot be undone!)

⚠️ Important: We recommend exporting the data first before deleting it. That way you always have a backup for future support.

5.5 Exporting data — be careful

When you export your data, you receive a file with all personal information.

⚠️ Warning:

This data is sensitive — do not share it casually
Exported data is no longer protected by MindNavigator
We recommend storing exports in encrypted form
If export is forced by parent/school: Contact dpo@mindnavigator.io

The export includes:

All quiz answers and results
Brain-type profile
Energy tracking (full history)
Notes (from you and your parent)
Progress and earned badges
Learning-route progress and reflections
Score history per domain
Consent records and privacy settings
Activity logs

💡 What can you do with this file?

Give it to your psychologist/coach
Keep it as a backup
Transfer it to another platform

5.6 Backup policy

What happens to data in backups after deletion?

Backup retention period: Backups are kept for 30 days after deletion from the production database
Permanent erasure: After 30 days backups are also permanently erased
Expedited deletion: You can request expedited deletion (within 7 days, €25 administration fee)
Acute need: In case of acute need (e.g. stalking): Free, immediate deletion within 24 hours — contact dpo@mindnavigator.io

6. Parental Dashboard and Control

6.1 What do you see as a parent?

Through the Parental Dashboard you have access to:

✓ What you DO see (12-15 years, default):

Weekly quiz summaries (no individual answers)
Top 3 strengths (e.g. "Focus 84%, Planning 76%")
Energy patterns (e.g. "40% Good/Super, 60% Okay/Tired")
Best times of the day for focus
Warning if your child is tired for 5+ days
Progress (quizzes completed, streaks, badges)
Which tools your child uses

✗ What you do NOT see:

Each individual energy check-in moment
Which questions your child answered incorrectly in quizzes
Individual quiz answers per question
Private messages between your child and their coach
Notes your child writes

This balance is designed to give you enough insight for good guidance, while your child retains enough privacy for trust-building.

6.2 Can my child adjust this?

Yes! Your child can choose from 3 levels via "Privacy Settings":

🟠 Share Less: Only that quizzes have been completed (no scores), no energy tracking
🟢 Normal (recommended): Patterns and summaries (as described above)
🔵 Share More: Also concern warnings and which tools are used

If your child chooses "Share Less", you receive a notification with a friendly reminder that this makes it harder to support them. You can then have a conversation about why this choice was made.

6.3 Features in the Parental Dashboard

Access to progress and patterns (according to the child's privacy settings)
Export your child's data (for your own records / support)
Delete your child's data (with extra confirmation)
Schedule sessions with coaches/tutors on behalf of your child (12-15 years)
Receive notifications on concern signals (if enabled by the child)

6.4 Automatic concern signals — how this works

When your child indicates 'Tired' or 'Very tired' for 5 days in a row, you receive a notification.

Important information:

This is NOT a diagnosis, but a signal to start a conversation
Your child can disable this feature via Privacy Settings → Concern Signals
When disabled, you receive one notification about this
The AI can make mistakes — when in doubt, always contact a professional

6.5 Data parents enter about the child

Parents can add notes, observations and profile information about their child.

Your child has the right to know:

Which data you have added
When this was added
To correct this data if it is inaccurate

Who added what?

In the dashboard your child sees:

Which data they entered themselves (marked green)
Which data you added (marked blue)
When data was added/changed (timestamp)

Ages 12-15:

Your child can request a correction through you as parent
In case of disagreement: A coach can mediate

Ages 16-17:

Your child can correct or hide your data themselves
You are informed when this happens

7. Your privacy rights (GDPR)

You have various rights under the GDPR. You can exercise these via your account or by emailing privacy@mindnavigator.io.

✓ Right of access
✓ Right to rectification
✓ Right to erasure
✓ Right to restriction
✓ Right to data portability
✓ Right to object

We do not take important decisions fully automatically; human review is always available.

7.1 Special rights for minors

For children aged 12-15:

✓ Right of access (via own dashboard)
✓ Right to export (self-service)
✓ Right to adjust privacy settings
⚠️ Right to erasure (via parent)

For young people aged 16-17: All rights, with additional safeguards for full deletion (7-day reflection period, parental notification).

For adults 18+: Full control without restrictions.

7.8 Response times (GDPR Art. 12.3)

We respond to your requests within:

1 month (standard): For all regular requests
2 months: For complex requests (with explanation why)
72 hours: For acute emergencies (e.g. stalking, safety)
5 business days: You always receive a receipt confirmation within 5 business days

7.9 Identity verification

For access/deletion requests we ask for verification to protect your privacy from unauthorised access:

Primary verification: Logging in with your account
In case of doubt: Additional verification via email/SMS
In case of serious doubt: Copy of ID (with the national ID/passport number blacked out)

💡 Why this is necessary: This prevents someone else from requesting your data without your consent.

8. Third parties and data sharing

MindNavigator shares your data with the following parties (GDPR Art. 13.1.e — Categories of recipients):

8.1 Hosting and infrastructure

Google Cloud Platform (Firebase)

Purpose: Database, authentication, file storage
Location: The Netherlands — europe-west4 (Amsterdam). Personal data does not leave the EU.
Safeguard: Google Cloud Data Processing Addendum (accepted 2026-03-29) + Standard Contractual Clauses Module 2+3 + EU GDPR certification
Data shared: All account data, quiz data, progress, energy tracking

8.2 AI services

Anthropic (Claude AI)

Purpose: Analysis of quiz data, content generation, brain-type profiles
Location: United States
Safeguard: Anthropic Data Processing Addendum (effective 24 February 2025) + EU Standard Contractual Clauses Module 2 (controller-processor) + No-training clause
Data shared: Pseudonymised quiz answers (no name/email)
Privacy: Claude AI may NOT use data for model training

8.3 Payment processing

Mollie (for paid subscriptions)

Purpose: Processing payments (iDEAL, credit card, Bancontact, etc.)
Location: The Netherlands (EU)
Safeguard: PCI-DSS certified, processor agreement
Data shared: Name, email address, payment details
Privacy: Card details are NOT stored by us

Note: Mollie will be engaged for payment processing once premium functionality is activated. During the current beta phase, Mollie does not process any user personal data.

8.4 Email communication

Resend

Purpose: Sending transactional emails (account verification, password reset, notifications, report notifications)
Location: United States
Safeguard: EU Standard Contractual Clauses apply; DPA validation in progress
Data shared: Email address, name, email content

8.5 Analytics

Google Analytics (with Consent Mode v2)

Purpose: Anonymised usage statistics for platform improvement
Location: United States (with EU Data Processing)
Safeguard: DPA + SCCs + IP anonymisation + Google Consent Mode v2
Data shared: Anonymised page visits and usage patterns (IP address is anonymised)
Privacy: Only active after your explicit consent via the cookie banner. Do Not Track is respected. Minors (<16 years) are automatically excluded. No remarketing or ad personalisation.

8.6 Error monitoring

Sentry (technical error monitoring)

Purpose: Detecting and resolving technical errors in the platform
Location: EU (Germany)
Safeguard: DPA, data processing within the EU
Data shared: Technical error information, stack traces, browser and operating system information
Privacy: No personal user data; only technical context on errors. 10% sample of transactions.

8.7 Coaches and support providers

Only data you explicitly share via the platform

Coaches have NO access to your login credentials
Coaches have NO access to messages with other coaches
Coaches have NO access to data you have set as private
Coaches are bound by professional confidentiality and the GDPR

8.8 WHAT WE NEVER DO

✗ Sell data to advertisers
✗ Share with data brokers
✗ Use for commercial profiling
✗ Share with insurers or employers (without your explicit consent)
✗ Resell to other platforms

8.9 Processor agreements (GDPR Art. 28)

All parties listed above have signed a Data Processing Agreement (DPA) stating that:

They may only process data according to our instructions
They have adequate security measures
They may not use data for their own purposes
They must notify us within 24 hours of a data breach

You can request copies of DPAs via dpo@mindnavigator.io

8.10 Additional safeguards for coaches and support providers

Coaches have access to data of children. To prevent misuse we have additional safeguards:

Access control:

Coaches only have access to data that the child/parent explicitly shares
Coaches have NO access to: login credentials, financial data, data of other children, messages with other coaches
Access can be revoked by the child/parent at any time

Professional safeguards:

Professional confidentiality: All coaches are bound by professional confidentiality (GDPR Art. 9.3)
Background checks: Mandatory screening for all coaches
Privacy training: Annual GDPR training required
Audit trail: All data access is logged and monitored
In case of misuse: Immediate access block + report to the DPO

Parental supervision:

Parents can view the coach list via the Dashboard
Parents can revoke coach access at any time
Parents receive a notification when a new coach is linked
In case of concerns: Contact us directly at dpo@mindnavigator.io

💡 Transparency: In the dashboard you can see exactly which coach has access to which data, and when this access was last used.

9. Transfers to countries outside the EU (GDPR Art. 44-50)

MindNavigator uses services that may process data outside the EU. In line with the GDPR, we take additional safeguards:

9.1 Google Cloud Platform (Firebase)

Location: The Netherlands — europe-west4 (Amsterdam). Firestore and App Hosting run exclusively in the EU. Personal data does not leave the EU.
Safeguard: Google Cloud Data Processing Addendum (accepted 2026-03-29) + Standard Contractual Clauses Module 2+3 + EU GDPR certification
Purpose: Database hosting, authentication, file storage

9.2 AI services (Claude AI / Anthropic)

Location: United States
Safeguard: Anthropic Data Processing Addendum (effective 24 February 2025) + EU Standard Contractual Clauses Module 2 (controller-processor) + encryption in transit
Purpose: Content generation, analysis of quiz data (pseudonymised)
Privacy: AI providers may NOT use data for training
Data minimisation: Only pseudonymised data (no names/emails)

9.3 Payment processing (Mollie)

Location: The Netherlands (EU) — no transfer outside the EU
Safeguard: PCI-DSS certified, processor agreement
Purpose: Payment processing once premium functionality is activated

Note: Mollie will be engaged for payment processing once premium functionality is activated. During the current beta phase, Mollie does not process any user personal data.

9.4 Email communication (Resend)

Location: United States
Safeguard: EU Standard Contractual Clauses apply; DPA validation in progress
Purpose: Transactional emails (verification, notifications, password reset)

9.5 Analytics (Google Analytics)

Location: United States (Google LLC), with EU Data Processing Amendment
Safeguard: Google Cloud Data Processing Addendum + EU Standard Contractual Clauses Module 2 + IP anonymisation (default in GA4) + Google Consent Mode v2
Purpose: Anonymised usage statistics for platform improvement (only after explicit cookie consent)
Minor protection: Users under 16 are automatically excluded from analytics tracking; Do Not Track is respected; no remarketing or ad personalisation

9.6 Error monitoring (Sentry)

Location: EU (Frankfurt, Germany) — Sentry EU tenancy (de.sentry.io). Personal data does not leave the EU
Safeguard: Sentry Data Processing Addendum + processing exclusively within the EU; no transfers to third countries
Purpose: Technical error monitoring and stack-trace analysis for platform stability
Legal basis: Legitimate interest (GDPR art. 6(1)(f)) — minimally necessary technical monitoring
Privacy-by-design: URL query strings are automatically anonymised before transmission (filtering of possible tokens or email addresses); 30% sampling of performance data; only active in production

9.7 Your rights regarding transfers outside the EU

You have the right to:

Object to transfers to countries outside the EU
Request copies of the Standard Contractual Clauses
Ask questions about safeguards via dpo@mindnavigator.io

⚠️ Important: If you object to transfers outside the EU, certain functionality (AI analysis, payments) may no longer work.

9.8 Legal protection

All transfers take place in line with GDPR Art. 46 with adequate safeguards:

Standard Contractual Clauses (SCCs): Approved by the European Commission
Supplementary measures: Encryption, pseudonymisation, data minimisation
Impact assessment: Carried out for each third party (Transfer Impact Assessment)
Monitoring: Annual review of safeguards

9.9 Government requests and legal procedures

When does MindNavigator share data with government?

Only with a court order or legal obligation
Never voluntarily without a legal basis
Only data specifically named in the order
Minimal disclosure: We never provide more data than strictly necessary

Your rights regarding government requests:

You are informed (unless the court prohibits this)
You can object via court
We provide only the minimum necessary data
Legal review: Every request is reviewed legally

Transparency report:

Each year we publish a transparency report (anonymised):

Number of government requests received
Type of requests (e.g. criminal, tax, youth care)
Number of requests granted vs. refused
Average response time

2026 statistics: Government requests: 0 | Data provided: 0 | Requests refused: 0

⚠️ Important warning:

If you have concerns about abuse of government requests (e.g. in custody cases, stalking by an ex-partner with police contacts), contact us directly at dpo@mindnavigator.io. We can engage additional legal protection.

10. AI Profiling and automated decision-making (GDPR Art. 22)

🤖 Transparency about AI use

MindNavigator analyses your quiz answers to determine a 'brain-type profile'. This is a form of profiling as defined in GDPR Art. 4.4. We explain how this works and what safeguards we have in place.

10.1 What does the AI do?

MindNavigator uses AI (Claude AI from Anthropic) to:

Analyse quiz results: Recognise patterns in your answers
Determine brain-type profiles: Such as "Visual Thinker", "Analytical Brain", etc.
Generate personalised tips: Tailored study and learning strategies
Monitor progress: Track development over time

10.2 Do AI systems make decisions about you? (GDPR Art. 22)

✅ No — no automated decision-making with legal effect

These AI systems do NOT make decisions with legal or significant effect (GDPR Art. 22). AI-generated insights are recommendations, not diagnoses or decisions.

You have the right to:

Human review: Via coaches/tutors who can review and correct AI-driven insights
Explanation: How the AI reaches conclusions (via dpo@mindnavigator.io)
Objection: Against AI use (with impact on functionality)
Correction: If AI-generated data is inaccurate

10.3 Safeguards against misuse

What we NEVER do with AI profiles:

✗ Share with schools without your consent
✗ Share with insurers or employers
✗ Use for medical diagnosis (we are not a medical platform)
✗ Sell to third parties
✗ Use for discrimination or exclusion

Additional safeguards:

No training: AI models are NOT trained on your personal data
Pseudonymisation: The AI does not receive names/emails, only pseudonymised data
Human control: Coaches can always override AI output
Transparency: You can always see what the AI has generated (badge "AI-generated")

10.4 Risks you should be aware of

⚠️ Important warnings:

Brain-type profiles can be misinterpreted by third parties (e.g. "ADHD brain" is not a diagnosis)
Data can be sensitive in certain contexts (e.g. legal proceedings, custody)
We recommend not sharing screenshots of profiles online
In case of a data breach: Large impact on stigma and the future (hence the additional security measures)

10.5 DPIA (Data Protection Impact Assessment)

In line with GDPR Art. 35, MindNavigator has conducted a Data Protection Impact Assessment (DPIA) for the AI profiling of children. Given the nature of the processing (profiling of minors with AI) we consider this a mandatory step.

Status: DPIA v1.1 was completed on March 29, 2026 and is available internally. A summary can be requested via dpo@mindnavigator.io

10.6 Your control over AI

You can always:

Delete your brain-type profile (without consequences for core functionality)
Object to AI analysis (via Account Settings → AI Preferences)
Ask how the AI reached a conclusion
Request human review (via your coach)

💡 If you object to AI: You can continue to use the platform, but without personalised recommendations.

11. Contact and complaints

For questions about this privacy policy or your rights, please contact:

MindNavigator B.V.

Email: privacy@mindnavigator.io

If you have a complaint about how we handle your data, you can contact our Data Protection Officer via dpo@mindnavigator.io.

If we cannot resolve the matter together, you can file a complaint with the Dutch Data Protection Authority via autoriteitpersoonsgegevens.nl.

12. Changes to this Privacy Policy

12.1 When do we change this policy?

We may change this privacy policy in case of:

New features: For example new AI features or tools
New legislation: Changes to GDPR or other privacy laws
Feedback from the Dutch Data Protection Authority: Recommendations from the regulator
External audit recommendations: Improvements following security audits
User feedback: Clarifications based on questions received

12.2 How will you be informed?

For substantial changes:

Email notification to your registered email address
Pop-up in the platform on your first login after the change
Summary of changes in a clear changelog
30-day reflection period for material changes that limit your rights

For minor changes:

Update of the "Last updated" date at the top of this document
Changelog available via dpo@mindnavigator.io

12.3 Your rights when changes are made

You can always:

Object to new processing activities
Account keeps working: If you object, your account stays active — only the new feature is not used
Delete your account: In case of fundamental objection you can delete your account free of charge
Ask questions: Anything unclear? Email dpo@mindnavigator.io

12.4 Version history

Changelog:

v2.4 (April 16, 2026):
- DPIA v1.1 completed (March 29, 2026) — section 10.5 updated from "planned" to "completed"
- Version archive set up: all earlier versions now archived internally
v2.3 (March 29, 2026):
- DPIA update: DPO role filled by Glenn Bosch (privacy@mindnavigator.io)
- Firebase location corrected: exclusively europe-west4 Amsterdam, no US fallback for personal data
- Google Cloud DPA + EU GDPR certification added (accepted 2026-03-29)
- GDPR Art. 30 record of processing activities established (available internally)
- Retention periods updated in line with SSOT data-retention.ts
v2.2 (November 17, 2025):
- Added: AI transparency (section 10)
- Added: Transfers outside the EU (section 9)
- Added: Security measures (section 4.5)
- Added: Retention periods (section 2.7)
- Added: Third parties details (section 8)
- Added: Cookies policy (section 2.8)
- Added: Consent process (section 4.1.1)
- Added: Coach safeguards (section 8.9)
- Added: Government requests (section 9.6)
v2.1 (November 17, 2025): Initial version with basic GDPR compliance

Archive: All previous versions are available upon request via dpo@mindnavigator.io

💡 Tip: Bookmark this page to always access the latest version of our privacy policy. The effective date at the top shows when the current version takes effect.

This privacy policy is drafted in line with the GDPR and protects your rights to the maximum extent. If you have questions, we are always here to help.

Last update: March 29, 2026

MindNavigator — Your privacy, our priority 🔒

Quick overview — What you need to know

MindNavigator respects your privacy and protects your data in line with the GDPR. We only collect data that is necessary for our platform and never share it for commercial purposes.