Privacy Policy
Last updated:
1. Who is responsible and what this policy covers
The controller is LEV ZIMBITSKIY, trading as MasterMind · Tech, Calle Carmelo Roda, 6, 46025 Valencia, Spain; tax identifier ESY5383974X. For privacy matters, contact info@mmindtech.com.
This policy covers visitors to our public website, enquiries, demonstration requests and the optional website services described below. It applies to individual visitors and consumers as well as people acting for businesses. Our website is not directed at children.
The Shop is open. Order, delivery, tax, payment and subscription processing is explained separately in the Shop Privacy Notice. That notice also covers necessary Shop storage. This website policy does not replace the privacy information for the authenticated MasterMind platform or property operations.
2. Information we handle
Visits and security. Our hosting systems receive connection information such as IP address, request time, requested address, browser information and response status. We use technical logs and abuse checks to operate and protect the website. Enquiry controls also use submission timing and pseudonymous rate-limit records derived from IP addresses or email addresses.
Enquiries and demonstrations. We receive your selected topic, name, email address, message and any optional company or property information you provide, together with relevant page/language context. Contacting us is voluntary. The fields marked as required are needed to route and answer your request; without them, the form cannot submit it. You can contact us by email instead. Please do not send passwords, payment-card details, guest records or unnecessary sensitive information.
Optional services. Each purpose has its own choice in Cookie settings:
| Choice | Information and purpose |
|---|---|
| External services | Calendly receives connection information when you load its scheduler and the booking details you choose to enter, so we can arrange a demonstration. |
| Audience measurement | Google Analytics 4, delivered only through Google Tag Manager, receives pseudonymous browser/session identifiers, technical device information, language, a cleaned public page address and selected interactions. We measure visits, product interest, broad traffic-source categories, enquiries accepted by our system and the transition from the public Shop to Checkout. |
| Browser error diagnostics | Sentry receives a sample of eligible browser errors to help identify website faults. We replace error messages with fixed text and restrict diagnostic details to approved technical fields, such as our own script locations and language. |
Our GA4 and Sentry event fields exclude names, email addresses, enquiry text, addresses, VAT numbers, order or payment references, access tokens and complete query strings. Connection IP addresses still reach the providers’ servers; the Sentry project is configured not to store IP addresses.
GA4 may measure the public Shop and a successful Checkout handoff, but not activity inside Checkout or completed purchases. Sentry is excluded from Contact, Shop and private journeys. Pages with query strings or fragments are normally excluded. After an enquiry is accepted, only recognized Contact navigation information may be removed from the address before a permitted analytics event is sent. We do not record form contents. Sentry session replay, tracing, profiling, logs, breadcrumbs and automatic session tracking are disabled.
3. Purposes and legal bases
We rely on:
- Steps you request before entering a contract, or performance of your contract (Article 6(1)(b) GDPR), when your enquiry, demonstration or support request concerns a contract with you personally.
- Legitimate interests (Article 6(1)(f) GDPR) in answering other enquiries, communicating with business representatives, providing business-customer support, operating the website and preventing abuse. We consider the effect on your rights and limit the data to what is needed.
- Legal obligations (Article 6(1)(c) GDPR), where applicable, including responding to valid requests and retaining required records.
- Your consent (Article 6(1)(a) GDPR) for optional embedded scheduling, audience measurement and browser error diagnostics, together with the applicable rules for accessing or storing information on your device.
You can reject optional services and still browse, contact us or buy. Sending an enquiry or accepting purchase terms does not subscribe you to a newsletter or give tracking permission. Cookie consent is not a waiver of your rights or consent to unrestricted international transfers.
4. Your choices
Optional services are off until you choose them. The banner offers equally accessible Allow all optional, Reject all optional and Cookie settings, where the three purposes can be selected independently. Calendly additionally requires you to choose scheduling. Google is not loaded to send cookieless measurement before consent.
Use Cookie settings in the footer to change or withdraw your choices at any time. Withdrawal stops further collection by the affected integration and discards its pending events. A marketing page may reload to unload a service; Contact and Shop forms are not reloaded for Google withdrawal. We remove accessible first-party measurement cookies where possible. Withdrawing scheduling removes the embedded calendar and prevents further loads. Closing the calendar alone does not withdraw consent.
Withdrawal does not affect the lawfulness of earlier processing or automatically delete information already received by a provider. Our controls cannot delete storage on another provider’s domain. See the Cookie Policy for storage periods, browser controls and alternatives to scheduling.
5. Recipients and their roles
Access is limited to people and providers who need it for the stated purposes, and to authorities or professional advisers where legally required or necessary to protect rights.
Hosting, email and enquiries. Arsys Internet, S.L.U., Spain, provides hosting infrastructure. We handle enquiries in our email system and may also use Zoho CRM; support may be handled in Zoho Desk. Zoho’s standard contracting entity for Spain is Zoho Corporation B.V., Netherlands. These services use the European data centre and process service data on our behalf. No Zoho browser-tracking script is installed. Zoho’s privacy information and contracting-entity list identify its group entities and processing arrangements.
Calendly. Calendly LLC, USA, processes scheduling data on our behalf and also handles certain connection, service-use and account information for its own purposes under its Privacy Notice. Its cookie choices remain separate from ours. You can request a demonstration through our form or email without loading Calendly.
Google. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, supplies Analytics and Tag Manager under the standard terms for Spain. Google processes Analytics customer data on our instructions under its data-processing terms; it also handles Tag Manager service-use information. The account contributes aggregated data to Google’s modeling and business insights. Google products-and-services sharing, Google Signals, user-provided-data collection, Enhanced Measurement and advertising personalization are disabled. We do not grant Google advertising storage, advertising-user-data or advertising-personalization permission. See Google’s privacy information and processing terms.
Sentry. Functional Software, Inc., trading as Sentry, USA, processes diagnostic event data on our behalf under its Data Processing Addendum. We use its European ingestion region, with error-only monitoring and 10% sampling. Sampling reduces volume; it does not guarantee that exactly one in ten errors is recorded. Sentry’s own account and service administration is described in its Privacy Policy.
6. International processing
Some providers and their support teams or subprocessors operate outside the European Economic Area, including in the United States. A European data centre or ingestion address does not mean all processing stays in Europe.
- Google publishes reliance on the EU-US Data Privacy Framework for covered US transfers, with standard contractual clauses for relevant transfers where that framework does not apply. See its transfer safeguards.
- Sentry’s DPA, Schedule 3 provides for the Data Privacy Framework for covered US transfers and standard contractual clauses where it does not apply. Some account, support and organization information can be processed outside its European event-storage region.
- Calendly’s DPA and Privacy Notice describe US processing, Data Privacy Framework coverage and contractual safeguards. Zoho describes intra-group and other international transfers under agreements based on EU standard contractual clauses in its Privacy Policy.
These safeguards do not eliminate every international-processing risk. You can obtain information or request a copy of the applicable safeguards through the linked documents or by contacting us. We do not treat ordinary cookie consent as a substitute for an applicable transfer safeguard.
7. Retention
We retain enquiries and related correspondence while needed to answer them, follow up the requested matter, provide support or meet legal and claims-related obligations. Technical security records are retained for operational and abuse-prevention needs, with longer restricted retention where an incident or legal obligation requires it. We delete or anonymize information when it is no longer needed. Purchase-record periods are addressed separately in the Shop Privacy Notice.
| Service | Relevant period |
|---|---|
| Consent choice | Up to 180 days after your latest saved choice, without renewal merely from browsing. |
| GA4 | Event-data setting: two months. User-data setting: 14 months, with activity-based reset disabled. These settings do not limit standard aggregate reports or cookie lifetimes; key-event retention follows Google’s applicable user-data rules. |
| GTM | Google states that standard HTTP request logs are deleted within 14 days. This is not the retention period for all Google data. |
| Sentry | Developer-plan error events: 30 days. This does not mean issue history, account or organization records are all deleted after 30 days. |
Provider administration records, aggregates and any records needed for a specific investigation have different purposes and periods. Withdrawing consent stops new optional collection, not every existing retention period.
8. Security and automated processing
We use proportionate technical and organizational safeguards, including access restrictions, validation and abuse controls. No system is completely secure. Automated checks may reject invalid or suspected spam submissions; email us if a genuine request cannot be sent.
MasterMind does not use this website’s analytics to make solely automated decisions with legal or similarly significant effects on you. Behavioural measurement is not the same as anonymity or an absence of all profiling. We do not enable advertising tags or personalized advertising in this integration.
9. Your rights
Subject to the applicable conditions, you can request access, correction, erasure, restriction and portability of your personal data. Where processing relies on consent, you can withdraw it without affecting earlier lawful processing.
Right to object: you may object, on grounds relating to your particular situation, to processing based on legitimate interests. We must then stop unless we demonstrate compelling legitimate grounds or the processing is needed for legal claims. You may object to direct marketing at any time without giving a reason.
Send requests to info@mmindtech.com or our postal address above. We may ask only for information reasonably needed to verify your identity and locate relevant records. Do not send identity documents unless requested. We normally respond within one month; if a lawful extension is needed, we explain it within that period. Some records must remain to satisfy legal obligations or protect claims.
You can complain to the Spanish Data Protection Agency (AEPD) or the competent supervisory authority where you live, work or believe an infringement occurred.
10. Updates and contact
We update this policy when our processing changes and show the effective update date on the published page. New optional purposes requiring consent need a new choice. For questions, contact info@mmindtech.com. See also our Cookie Policy and Legal Notice.