Privacy Policy

1. Introduction

Spartner B.V. ("Spartner", "we", "us", or "our") operates the Mind platform and related services, including integrations with social media platforms and messaging services. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our services.

This policy applies to:

• The Mind web application
• Social media integrations (Facebook, Instagram, LinkedIn, X/Twitter)
• WhatsApp Business notifications
• All related APIs and services

2. Data Controller

Spartner B.V. is the data controller responsible for your personal data processed through our services.

3. What Data We Collect

3.1 Account Information

• Name and email address
• Password (encrypted)
• Profile preferences and settings
• Phone number (for WhatsApp notifications, if provided)

3.2 Social Media Integration Data

When you connect your social media accounts via OAuth, we collect:

• Facebook/Instagram: Page access tokens, page names, profile information necessary for posting
• LinkedIn: Profile ID, name, and authorization tokens for posting on your behalf
• X (Twitter): Account ID, username, and authorization tokens

We access only the permissions you explicitly grant during the OAuth authorization process.

3.3 Content Data

• Posts, articles, and content you create or schedule
• Images and media you upload
• Analytics and performance metrics from your social media accounts

3.4 WhatsApp Notification Data

For WhatsApp Business notifications, we collect and process:

• Phone numbers you provide for receiving notifications
• Message delivery status (sent, delivered, read)
• Notification preferences and opt-in/opt-out status

3.5 Technical Data

• IP addresses and device information
• Browser type and version
• Usage logs and analytics

4. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds:

5. How We Use Your Data

• Service Delivery: To provide, maintain, and improve our platform
• Social Media Management: To schedule and publish content to your connected social media accounts on your behalf
• Notifications: To send WhatsApp notifications about content generation, publishing status, and important updates
• Analytics: To provide insights about your content performance
• Support: To respond to your inquiries and provide customer support
• Security: To protect against fraud and unauthorized access

6. Social Media Integrations

6.1 OAuth Authorization

When you connect social media accounts, you are redirected to the respective platform (Facebook, Instagram, LinkedIn, or X) to authorize our application. We use OAuth 2.0, which means:

• We never see or store your social media passwords
• You control which permissions you grant
• You can revoke access at any time through the platform's settings

6.2 Posting on Your Behalf

When you use our service to create and schedule posts:

• You remain the author and owner of all content
• We act solely as your scheduling and publishing tool
• Content is sent directly to the social media platforms
• We do not use your content for any purpose other than publishing as you instruct

6.3 Revoking Access

You can disconnect your social media accounts at any time:

• Through our platform settings
• Through the connected platform's app settings (Facebook, LinkedIn, etc.)

7. WhatsApp Business Notifications

7.1 Purpose

We use WhatsApp Business API to send you notifications about:

• Content generation completion
• Publishing status updates
• Important alerts and failures
• Account verification (OTP codes)

7.2 Your Consent

You must explicitly opt-in to receive WhatsApp notifications. You can opt-out at any time by:

• Changing your notification preferences in your account settings
• Replying "STOP" to any notification message

7.3 Data Sharing with Meta

WhatsApp is owned by Meta Platforms, Inc. When we send you notifications:

• Your phone number and message content are processed by WhatsApp/Meta
• Meta's WhatsApp Privacy Policy also applies
• Message content is end-to-end encrypted during transmission

8. Data Sharing and Third Parties

8.1 Service Providers

We share data with trusted service providers who assist in operating our platform:

• Cloud hosting providers (data storage and processing)
• Payment processors (billing and subscription management)
• Analytics services (usage statistics)

8.2 Social Media Platforms

When you connect accounts or publish content, data is shared with:

• Meta Platforms (Facebook, Instagram, WhatsApp)
• LinkedIn Corporation
• X Corp. (Twitter)

Each platform's privacy policy governs how they handle your data.

8.3 What We Do NOT Do

• We do NOT sell your personal data
• We do NOT share your data with advertisers
• We do NOT use your content to train AI models without explicit consent

9. Data Retention

10. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States. We ensure adequate protection through:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Data processing agreements with all service providers
• Technical security measures

11. Your Rights (GDPR)

Under the General Data Protection Regulation (GDPR), you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate personal data
• Right to Erasure: Request deletion of your personal data
• Right to Data Portability: Receive your data in a portable format
• Right to Restrict Processing: Limit how we use your data
• Right to Object: Object to certain types of processing
• Right to Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at info@spartner.nl. We will respond within 30 days.

12. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Encryption in transit (TLS/HTTPS) and at rest
• Secure OAuth token storage
• Regular security audits
• Access controls and authentication
• Employee data protection training

13. Cookies

We use essential cookies for:

• Session management and authentication
• Security and fraud prevention
• Remembering your preferences

We may also use analytics cookies with your consent to improve our services.

14. Children's Privacy

Our services are not intended for individuals under 16 years of age. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Email notification
• Notice on our platform

The "Last updated" date at the top indicates when this policy was last revised.

16. Contact Us

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl.