ProcessMind Privacy Policy

ProcessMind Privacy Policy

Effective Date: September 14, 2026

Introduction

This privacy notice for ProcessMind B.V. (“we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

• Visit our website at https://processmind.com, or any website or service of ours that links to this privacy notice,
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@processmind.com.

Data we process on behalf of your organisation. If you use the Services through an organisation — for example as an employee, contractor or invited user of a ProcessMind customer — that organisation is responsible for the personal information it submits to the Services, and ProcessMind processes that information on the organisation’s documented instructions as a processor (or sub-processor) under our Data Processing Addendum. If you have questions or requests about that information, please contact the organisation that gave you access; you can also contact us and we will refer your request to that organisation.

SUMMARY OF KEY POINTS

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? Yes — for example, when you sign in with Microsoft Entra ID, Google or LinkedIn we receive basic profile information from that provider, and other users of the Services may provide information about you (for example when they invite you to a workspace or mention you in content they create). We may also receive your business contact details from a partner or service provider in connection with a request you or your organisation has made.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We also use service providers (for example for hosting, payments, error monitoring and analytics) and, where you have consented or we have another lawful basis, we use information from those services to measure and improve our advertising. We only process your information with a valid legal basis and, when necessary, with your consent. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting processmind.com/about/contact-us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

1 WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• usernames
• contact preferences
• contact or authentication data
• billing addresses
• debit/credit card numbers

Your Contributions to Our Services In using the ProcessMind services, we gather and preserve the content you create, dispatch, obtain, and disseminate. This encompasses the details of processes you engage with, documentation you compile on these processes, and any feedback or comments you offer regarding them.

Contributions to Our Websites Our services encompass the websites we own or operate. We collect content you submit to these sites, including any social media or networking platforms under our management. This includes content shared when you offer feedback, engage in interactive features, respond to surveys, participate in contests, promotions, sweepstakes, or take part in activities and events we host.

Support Channel Submissions Our Services encompass customer support, where you might provide information to address issues with our Services. This includes identifying yourself as a technical contact, initiating support tickets, direct conversations with our representatives, or any interaction with our support team. During these interactions, you’re requested to share your contact details, describe the issue you’re facing, and possibly provide additional documentation, screenshots, or relevant information to aid in resolving your concern.

Billing and Payment Information When you sign up for our paid services, we collect billing details such as the name and contact information of the billing contact, and payment methods including credit card numbers. This data is necessary to process your payments and is securely handled and stored by our payment processing partner, Paddle. For more details on how your payment data is managed, please refer to Paddle’s privacy policy: https://www.paddle.com/legal/privacy.

Engagement with Our Services We monitor and record specific details about your interactions with our Services. This encompasses which features you access and utilize, the frequency of your visits, and the duration of your engagement with each feature.

Device and Connection Information When you use our Services via a computer, phone, tablet, or other devices, we gather data about the device and how you connect to our Services. This includes the type of connection and settings when you install, access, update, or use our Services. We collect details such as operating system, browser type, IP address, referring and exit URLs, device identifiers, and crash reports. Your IP address and country preference help us approximate your location to enhance your experience with our Services. The amount and type of information we collect vary based on your device’s settings and capabilities. Administrators of server and data center services have the option to limit this data collection through their administrative settings or by blocking data transmission at the network level.

Information we receive from other sources We receive limited information about you from other sources: your sign-in provider (as described above), other users of the Services (for example when they invite you or include your details in content they create), and, where relevant, partners and service providers that you interact with in connection with ProcessMind (for example a partner that helps your organisation deploy the Services). We use this information only to operate, secure and support the Services and our relationship with the organisation you belong to.

Information from Other Service Users Sometimes, other individuals who use our Services might share information about you. This can occur when they include your details in the content they contribute, such as mentioning you in documentation, processes, or comments within our Services.

Partners. If you interact with us through a partner (for example, a reseller or implementation partner), we may receive your business contact details from that partner so we can respond to your request, provide support and administer the partnership.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Please refrain from providing any sensitive information, such as your social security number, political opinions, religious beliefs, health information, or any other data classified as sensitive under applicable laws.

2 HOW DO WE USE YOUR INFORMATION?

In Short: We collect and use your information to deliver and improve our Services, communicate with you, enhance your experience, and protect our legal interests. This includes using your details for transaction processing, personalization, service improvement, promotional messages, customer support, and legal protections. We may also use your information for additional purposes with your explicit consent.

How we use the information we collect depends on any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

To provide the Services and personalize your experience We use your information to deliver our Services effectively, including transaction processing, login authentication, and customer support. Your account details, like name and photo, help identify you across Services to other Service users, while your email domain may inform personalized content based on your organization or industry. We aim for a seamless experience by integrating data across Services, ensuring content relevance and personalization based on your interactions. For opting out of personalization and details on cookie usage, visit our Cookies Policy: https://processmind.com/about/terms-and-policies/cookies-policy.

To improve our Services We continuously strive to enhance the functionality and user experience of our Services. By analyzing usage patterns, feedback, and trends, we identify opportunities for improvement and innovation. This process helps us develop new features and technologies that serve our users more effectively.

To communicate with you about our Services We utilize your contact details to send essential service-related messages. These include purchase confirmations, subscription reminders, responses to inquiries, and support. Additionally, we alert you to technical updates, security notices, and other administrative information via email.

To promote and increase engagement of our Services We use your contact details and service usage data to send targeted promotional messages, including emails and ads on other platforms. These messages aim to enhance your engagement by informing you about new features, surveys, newsletters, and events of interest, along with product offers and contests. For opt-out options, please see our Cookies Policy: https://processmind.com/about/terms-and-policies/cookies-policy.

Customer support Your information aids us in addressing technical problems, responding to support inquiries, analyzing system crashes, and enhancing our Services. With your explicit consent, we may share details with third-party experts to assist with these issues.

To protect our legitimate business interests and legal rights Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

With Consent We may use your information for purposes beyond those mentioned, but only with your explicit consent. This could include sharing testimonials or customer stories to highlight our Services.

3 WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

• Contract. We may process your information where it is necessary to perform a contract with you or to take steps at your request before entering into one — for example, to provide the Services you sign up for, to administer your account and to provide support.

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Legitimate Interests. We may process your information where it is necessary for our legitimate interests (or those of a third party) that are not overridden by your interests or fundamental rights — for example, to secure, monitor and improve the Services, to prevent fraud or abuse, and to manage our business relationships. Where we rely on legitimate interests, you have the right to object (see Section 10).

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In the exceptional cases permitted by Canadian law, we may process your information without consent — for example, where collection is clearly in an individual’s interests and consent cannot be obtained in a timely way, for investigations and fraud detection and prevention, to comply with a subpoena, warrant or court order, or where the information is publicly available as specified by the regulations.

4 WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Service providers and sub-processors. We share information with vendors that process it on our behalf — for example cloud hosting, payment processing, error monitoring (including error-triggered, masked session replays in the frontend), web font delivery, scheduling (when you choose to book a meeting), and AI model providers. Our current sub-processors and their processing locations are listed in the Sub-processor list.

• Analytics and advertising partners. Where required and with your consent, we share information with analytics and advertising providers (such as Google, Microsoft, and LinkedIn) to measure and improve our Services and our advertising. Conversion measurement can use hashed identifiers. You can manage this through your cookie preferences, as described in our Cookies Policy.

International transfers. ProcessMind stores Customer Data in the European Union (AWS region eu-central-1, Frankfurt, Germany) and processes personal information primarily within the EU/EEA. Some of our service providers are located outside the EEA, the UK or Switzerland — for example in the United States — for activities such as AI model processing, payment processing, error monitoring, scheduling, web analytics and web font delivery. Where personal data is transferred outside these regions, we rely on appropriate safeguards such as the EU Standard Contractual Clauses (and, where applicable, the UK Addendum or the equivalent Swiss provisions). See our Data Processing Addendum for details.

5 DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements and to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/“sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookies Policy: https://processmind.com/about/terms-and-policies/cookies-policy.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6 HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using third-party sign-in providers (Microsoft Entra ID, Google, or LinkedIn). Where you choose to do this, we will receive certain profile information about you from your provider. The profile information we receive may vary depending on the provider concerned, but typically includes your name, email address, and profile picture, as well as other information you choose to make available on that platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7 HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. Data deletion timelines depend on your account type.

We will retain your personal information only for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

The following retention timelines apply (see Section 6.2 of our Data Processing Addendum for details):

• Trial accounts: Customer Data is deleted thirteen (13) months after the trial account was created.
• Paid subscriptions: Customer Data is deleted ninety (90) days after the end of the subscription term.
• Free plans: Customer Data is retained for as long as the account remains active; Free plan accounts are not deleted automatically.
• You may delete your data at any time through the features available in the Services or by contacting us at privacy@processmind.com.

After the applicable deletion period, when we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. Data is not purged from automatic backups until the applicable backup retention windows expire (see the Security Measures document). Technical logs are retained as described in that document.

8 HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9 DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@processmind.com.

10 WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookies Policy: https://processmind.com/about/terms-and-policies/cookies-policy.

If you have questions or comments about your privacy rights, you may email us at privacy@processmind.com.

11 CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12 DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of a US state with a comprehensive consumer privacy law — such as California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia — you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, and financial information (for example, billing details)	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
G. Geolocation data	Approximate location derived from IP address	YES
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details (for example your name, email address, phone number and job title), and recruitment information if you apply for a job with us	YES
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual\’s preferences and characteristics	YES
L. Sensitive personal Information		NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - As long as the user has an account with us

• Category B - As long as the user has an account with us

• Category D - As long as needed for billing, tax, and accounting requirements

• Category F - According to the retention periods of the relevant analytics and advertising services (see our Cookies Policy)

• Category G - As long as the user has an account with us

• Category K - As long as the underlying information is retained

Sources of Personal Information

Learn more about the sources of personal information we collect in “WHAT INFORMATION DO WE COLLECT?”

How We Use and Share Personal Information

Learn about how we use your personal information in the section, “HOW DO WE USE YOUR INFORMATION?”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We do not sell personal information, and we have not sold personal information in the preceding twelve (12) months. Certain analytics and advertising technologies described in this notice and in our Cookies Policy may be treated as “sharing” for targeted advertising under applicable US state laws; you can opt out using the mechanisms described in this section.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non-discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting processmind.com/about/contact-us, by emailing us at privacy@processmind.com, or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@processmind.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

13 DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We process personal information under Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020. You may request access to or correction of your personal information using the contact details in Section 15, and may complain about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner or of New Zealand’s Privacy Principles to the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

You may request access to or correction of your personal information using the contact details in Section 15, and may complain to the Information Regulator (South Africa).

Canada

Where Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) or Quebec’s Law 25 applies, you may request access to or correction of your personal information using the contact details in Section 15, and you may complain to the Office of the Privacy Commissioner of Canada or, for Quebec, the Commission d’accès à l’information.

Brazil

If you are located in Brazil, you may exercise the rights granted by the Lei Geral de Proteção de Dados (LGPD) — including confirmation of processing, access, correction, anonymization, portability, deletion and information about sharing — using the contact details in Section 15, and you may complain to the Brazilian National Data Protection Authority (ANPD).

Japan

If you are located in Japan, you may request disclosure, correction, suspension of use or similar measures with respect to your personal information in accordance with the Act on the Protection of Personal Information (APPI), using the contact details in Section 15.

South Korea

If you are located in South Korea, you may exercise the rights provided by the Personal Information Protection Act (PIPA) — including access, correction, deletion and suspension of processing — using the contact details in Section 15, and you may complain to the Personal Information Protection Commission (PIPC).

India

If you are located in India, you may exercise the rights available under the Digital Personal Data Protection Act, 2023 — including access, correction, erasure and grievance redressal — using the contact details in Section 15, and you may lodge a complaint with the Data Protection Board of India.

14 DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15 HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at privacy@processmind.com or contact us by post at:

ProcessMind B.V.
Willem Sandbergstraat 33
Deventer, Overijssel 7425RC
The Netherlands

Phone: +31 85 060 68 09

E-mail: privacy@processmind.com

16 HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, to request details about how we have processed it, to correct inaccuracies, or to request deletion. You can submit a request using the contact details in Section 15 or, if you use the Services through an organisation, by contacting that organisation, which is responsible for the personal information it submits to the Services. We will consider and act upon any request in accordance with applicable data protection laws.

You may exercise the rights described in Section 10 by visiting processmind.com/about/contact-us or emailing privacy@processmind.com.