Mindsetor
LEGAL // PRIVACY PROTOCOL
Privacy Policy.
Last updated September 2026
Data Controller
Mindsetor B.V.
Brightlands Smart Services Campus, Smedestraat 2, 6411 CR Heerlen, Netherlands
KVK: 42042393
RSIN: 869442958
Email: support@mindsetor.com
What We Do
MINDSETOR is a B2B corporate well-being platform for proactive burnout prevention. We provide:
- Tracking Dashboard — Activity (steps, calories) and sleep monitoring
- Care Hub — Video sessions with psychologists and lifestyle coaches
- Gamification — Leaderboards, season badges, and Mindsetor Points
- Burnout Insights - Wellbeing pattern recognition with optional self-referred specialist sessions. Informational, not diagnostic.
Data We Collect
- Account Data: Name, email, employer (job title not collected)
- Activity Data: Steps, calories, heart rate, Resting Heart Rate (via Apple HealthKit, Google Health Connect, or Garmin)
- Stress Data: Heart Rate Variability (SDNN or RMSSD, depending on your device) for nervous system recovery analysis (via Apple HealthKit, Google Health Connect, or Garmin)
- Sleep Data: Duration, consistency, and quality metrics (via Apple HealthKit, Google Health Connect, or Garmin)
- Mood Data: Self-reported mood ratings (valence protection)
- Well-being Insights: Burnout risk scores (Risk Velocity), weekly trends, and sleep risk analysis
- Session Data: Booking details, session notes (Care Hub)
- Usage Data: Features used, points earned (Device type/OS not collected)
- Garmin Connect Data: If you connect a Garmin account, we receive activity, sleep, heart-rate, heart-rate-variability and stress data directly from Garmin, alongside anything you also share through Apple Health or Health Connect. Section 09 lists exactly what.
Why We Process Your Data
- Platform services: Contract (Art. 6(1)(b))
- Health data processing: Explicit consent (Art. 9(2)(a))
- Care Hub sessions: Contract + Consent
- Burnout risk scores: Consent + Legitimate interest
- Session records: Legal obligation (Wkkgz/WGBO)
The Employer Firewall
Your employer cannot see your individual data.
Employers only receive participation rates and anonymized, aggregated trends. A strict minimum of 10 active users is required to generate any team analytics. If fewer than 10 users are active, no data is shown to preserve anonymity. Individual scores, mood data, session notes, and health metrics are never shared.
Automated Decision-Making
Our V3 Risk Engine analyzes the convergence of your mood valence, sleep consistency, activity capability, and heart rate variability (HRV) to calculate a burnout risk score ("Risk Velocity"). You have the right to:
- Request human review of any automated assessment
- Book a Care Hub session to discuss your results
- Object to automated processing
Data Retention
- Account data: Until account deletion or end of Service Agreement, plus 2 years for legal-claim defense
- Activity & sleep data: 3 years after last activity
- Specialist session notes: 20 years (Dutch WGBO Art. 7:454 BW, as amended effective 1 January 2020)
- Gamification data: Duration of account
Upon account deletion, personal identifiers (name, email) are permanently erased. Anonymized, non-identifiable health metrics (steps, sleep duration, mood patterns) may be retained for research and product improvement purposes. This anonymized data cannot be linked back to you.
Third-Party Processors
- Google Firebase: Database (Firestore), authentication, hosting - EU (europe-west1, Belgium). Google Firebase is SOC 2 Type II and ISO 27001 certified.
- Google Cloud: Cloud Functions, infrastructure - EU (europe-west1, Belgium). Google Cloud is SOC 2 Type II and ISO 27001 certified.
- Firebase Cloud Messaging: Push notification delivery — EU/USA. No health data in notification payloads.
- Agora (Agora Lab, Inc.): Video calls for Care Hub sessions — USA, with Standard Contractual Clauses (SCCs). Only video/audio streams; no health data transmitted.
- Garmin (Garmin Ltd.): Health-data synchronisation via OAuth API — USA / EU, under Standard Contractual Clauses (SCCs), supplemented by the EU-US Data Privacy Framework where applicable. Applies only if you connect Garmin. See section 09.
HealthKit and Health Connect data stays on your device. We request permission to read it, but it is not stored by Apple or Google on our behalf.
The full sub-processor register is maintained in our Data Processing Agreement.
Garmin Connect Data
This section applies only if you choose to connect a Garmin account. Connect nothing and none of it applies to you.
- What we receive: Daily summaries (steps, active minutes, calories, resting heart rate, average stress level, Body Battery charged and drained), sleep (total duration, deep, light, REM and awake time, bedtime and wake time, the timing of each sleep stage through the night, and Garmin's own sleep quality score), heart-rate variability in milliseconds, including the individual readings your watch records through the night, stress detail (average and maximum stress, high-stress and restful duration), and activities (type, duration, distance).
- How it reaches us: Garmin sends each summary to our servers after your watch syncs to Garmin Connect. Where Garmin sends only a notification that something is ready, our servers then ask Garmin for that day's summaries.
- What we store alongside it: Your Garmin user ID, the access tokens that keep the connection alive, and which permissions and scopes you granted. These sit on our servers and are never readable by the app on your phone. The app can see the connection's status and its timestamps: when you connected, when data last arrived and was processed, when your permissions changed, and when it was disconnected.
- Where it is processed: Google Cloud in the EU (europe-west1, Belgium), the same infrastructure described in section 08. Each raw delivery from Garmin is stored so that it can be processed into your daily record, and for no other purpose. We delete it once processing completes; a delivery we cannot process, or cannot clean up afterwards, may be retained indefinitely.
- What we use it for: Your daily points, your sleep score, and the well-being indicators you see in the app. Garmin data can feed the burnout risk score described in section 06.
- What no one does with it: No artificial intelligence or language model processes your Garmin data. We do not sell it, use it for advertising, or hand it to a third party for analysis. Your employer never sees your individual Garmin readings. Garmin data is subject to the same employer firewall as everything else (section 05).
- Turning it off: Disconnect Garmin in the app and we delete the tokens and the connection record. If Garmin cannot be reached at that moment the disconnection may not complete, so write to support@mindsetor.com and we will finish it by hand. You can also revoke access from your Garmin account. Data we already received is kept under the retention periods in section 07, and section 11 covers your right to have it erased.
Garmin holds and processes your data under Garmin's own privacy policy before any of it reaches us. Beyond setting up and ending this connection, the only thing we send Garmin is a request for your own data, carrying the access token from that connection. We tell Garmin nothing about you that Garmin does not already hold.
Security
- All data encrypted in transit and at rest (Google Cloud infrastructure)
- Firestore security rules enforce user-level data isolation
- Firebase Auth with secure session management
- Hosted on Google Cloud, which is SOC 2 Type II and ISO 27001 certified. Mindsetor itself is not certified to either standard.
Your Rights
- Access: Request a copy of your data by emailing support@mindsetor.com; account-level data is also viewable in-app
- Rectification: Correct inaccurate information via your profile settings or by contacting us
- Erasure: Delete your account and all associated data via Settings → Privacy → Delete Account
- Restriction: Limit how we use your data
- Portability: Request your data in machine-readable JSON format by emailing support@mindsetor.com; data is delivered within 30 calendar days
- Object: Object to processing based on legitimate interest
- Withdraw Consent: Revoke consent at any time by deleting your account
- Complaint: Lodge complaint with Dutch DPA (Autoriteit Persoonsgegevens)
Contact support@mindsetor.com — we respond within 30 days.
Age Requirement
MINDSETOR is intended for employees of corporate clients. Users must be at least 16 years old.
Changes to This Policy
We notify users of material changes via email or in-app notification at least 14 days before they take effect.
Medical Device Status
Mindsetor is not a medical device under EU MDR (Regulation 2017/745). Per MDR Recital 19, software intended for lifestyle and wellbeing purposes is excluded from the medical-device definition. Mindsetor's risk indicators are informational, not diagnostic. Mindsetor does not predict, prevent, monitor, treat, or alleviate disease.
Bedrijfsarts and Arbowet
Mindsetor does not replace, modify, or interface with the relationship between an employee and the bedrijfsarts under the Dutch Arbowet. The bedrijfsarts remains the employer's occupational-health responsibility. Mindsetor is voluntary, individual-facing wellbeing support. Data does not flow to the bedrijfsarts unless the employee chooses to share it themselves.
Participation Is Voluntary
Participation in any Mindsetor pilot or deployment is voluntary. Employers may not condition employment, performance review, promotion, or remuneration on participation, non-participation, or any in-app engagement pattern. You may withdraw consent under Article 7(3) GDPR at any time, without explanation, and without consequence to your employment.
Contact
Email: support@mindsetor.com
Address: Brightlands Smart Services Campus, Smedestraat 2, 6411 CR Heerlen, Netherlands