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Privacy Policy

Version: 2.0
Effective date: 21 July 2026
English version

1. Controller

Mindgevity, a société par actions simplifiée registered with the Trade and Companies Register of Perpignan under number 989 211 842, with its registered office at:

7 Rue Alexander Fleming
66000 Perpignan
France

is responsible for the processing described in this Privacy Policy.

Contact: support@mindgevity.fr

2. Scope

This Privacy Policy applies when you visit our website, place an order, use an account, request or access a Guide, complete a questionnaire, contact us, provide feedback or subscribe to marketing communications.

3. Personal data we process

Depending on how you use our services, we may process the following categories of personal data.

Identity, contact and account data

Name, email address, telephone number, billing or delivery address, country, language, account details, authentication data and access records.

Order and transaction data

Order details, products or programmes selected, payment status, invoices, delivery information, returns, refunds and related correspondence.

Complete payment-card details are processed by our payment providers and are not stored by Mindgevity.

Questionnaire and personalised Guide data

When you choose a personalised Guide, we process your questionnaire answers, generated results and personalised Guide.

Your questionnaire answers may include information about your lifestyle, diet, sleep, physical activity, routines, preferences, wellbeing goals and health.

Questionnaire answers, generated results and personalised Guides are stored in encrypted form.

Universal Guide data

A universal Guide does not require completion of the questionnaire. We process only the information necessary to record your selection and provide access.

Product-improvement data

Where you provide separate consent, we may use a pseudonymised copy of your questionnaire answers, generated results and the parts of your personalised Guide necessary to test and improve our questionnaire, personalisation rules, the quality of personalised Guides and related services.

Pseudonymisation means that direct identifiers are removed or replaced while the data remain personal data.

Communications and marketing data

Support requests, messages, complaints, reviews, feedback, marketing preferences and records of consent or withdrawal.

Technical and cookie data

IP address, device and browser information, website activity, security logs, session information, cookie identifiers and similar technical data.

Further information is available in our Cookie Policy.

4. Purposes and legal bases

Website, accounts and security
We process technical, account and security data to operate and protect our website and services, prevent fraud and investigate incidents.
Legal basis: our legitimate interests and, where applicable, compliance with legal obligations.
Audience measurement
We use TWIPLA in Maximum Privacy / Privacy Level 4 to obtain aggregated statistics about website use and technical performance. In this configuration, TWIPLA does not place analytics cookies or use persistent identifiers or fingerprinting. We do not combine these statistics with orders, accounts, questionnaire answers, health-related information or personalised Guides.
Legal basis: our legitimate interests in measuring and improving website performance
Orders and customer service
We process identity, contact, order and transaction data to manage purchases, payments, delivery, accounts, returns, refunds and customer support.
Legal basis: performance of a contract and compliance with legal obligations.
Personalised Guide
We process your questionnaire answers, generated results and personalised Guide to create, provide and make your personalised Guide accessible.
Legal basis: your consent. Where questionnaire answers include data concerning health, we rely on your explicit consent.
Providing questionnaire information is optional. You may select a universal Guide instead.
Universal Guide
We process the information necessary to provide access to the universal Guide.
Legal basis: performance of a contract.
Product improvement
Where you provide separate consent, we use a pseudonymised copy of your questionnaire answers, generated results and the parts of your personalised Guide necessary to test and improve our questionnaire, personalisation rules, the quality of personalised Guides and related services.
Where these data include health information, we rely on your separate explicit consent.
Consent to product improvement is optional and does not affect your purchase or access to your Guide.
Accounting, compliance and legal claims
We process relevant information to comply with accounting, tax, consumer-protection and regulatory requirements, handle complaints and establish, exercise or defend legal claims.
Legal basis: compliance with legal obligations and our legitimate interests in protecting our rights.
Marketing
We process contact details and marketing preferences to send information about our products and services.
Legal basis: your consent or, where permitted by applicable law, our legitimate interests in contacting existing customers about similar products or services.
You may unsubscribe at any time.

5. Pseudonymisation and anonymisation

Product-improvement data are processed in pseudonymised form.

Until anonymisation, pseudonymised information remains capable of being linked to you and is processed in accordance with this Privacy Policy.

If you withdraw your consent before anonymisation, we will stop using the relevant personal data for product-improvement purposes.

We may subsequently transform product-improvement data into information that cannot reasonably be linked to an identifiable person. Once this process is irreversible, the resulting anonymous information is no longer associated with you and cannot be identified or deleted in response to an individual request.

6. Recipients

Personal data may be accessed by authorised Mindgevity personnel and by service providers that support:

  • website hosting and cloud infrastructure;

  • payment processing;

  • delivery and logistics;

  • authentication, security and fraud prevention;

  • email and customer support;

  • accounting, legal and professional services;

  • audience-measurement and website-performance services.

Personal data may also be disclosed to public authorities where required by law.

Questionnaire answers, health-related information and personalised Guide content are not shared with advertising partners.

7. International transfers

Some service providers may process personal data outside the European Economic Area.

Where required, we use recognised transfer safeguards, such as an adequacy decision, Standard Contractual Clauses or another permitted transfer mechanism.

You may contact us to obtain further information about, or a copy of, the safeguards applicable to a transfer.

8. Retention

We retain personal data only for as long as necessary for the relevant purpose or required by law.

Questionnaire answers, generated results and personalised Guides: no longer than 12 months from Guide generation.

Pseudonymised product-improvement data: no longer than 12 months from Guide generation unless they are irreversibly anonymised earlier.

Personal access links: a personal access link providing direct access to the Guide remains valid for 72 hours. Limited security and access records may be retained for longer where necessary to operate and protect the service.

Order and contract records: for the duration of the customer relationship and the applicable limitation periods.

Invoices and accounting records: for the statutory accounting and tax retention periods.

Account data: until deletion or after an appropriate period of inactivity, unless longer retention is necessary.

Marketing data: until withdrawal, objection or expiry of the applicable retention period.

Cookies, similar technologies and audience-measurement data: for the periods specified in our Cookie Policy.

9. Security

We use technical and organisational measures appropriate to the sensitivity of the information, including encryption, access controls, authentication safeguards, secure access links, pseudonymisation and monitoring.

No online system can guarantee absolute security. You should keep your login details and personal access links confidential.

10. Your rights

Subject to applicable conditions, you may request:

  • access to your personal data;

  • correction of inaccurate or incomplete data;

  • deletion;

  • restriction of processing;

  • portability of data you provided;

  • objection to processing based on legitimate interests;

  • objection to direct marketing;

  • withdrawal of consent.

Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

If you withdraw your consent, we may no longer be able to provide or maintain access to your personalised Guide.

To exercise your rights, contact support@mindgevity.fr. We may request information necessary to verify your identity.

You may lodge a complaint with the CNIL or another competent supervisory authority.

11. Required and optional information

Identity, contact, order and payment information may be necessary to process a purchase, provide a product, issue an invoice or respond to a request.

Questionnaire answers, health-related information, product-improvement consent, marketing consent and non-essential cookies are optional.

If you do not provide information necessary to process an order or provide a selected product or service, we may be unable to complete your purchase or provide that product or service.

12. Children

Our website, questionnaires and Guides are intended for individuals aged 18 or over.

We do not knowingly collect questionnaire answers or health-related information directly from children through these services.

13. Updates

We may update this Privacy Policy to reflect changes to our services or processing activities.

The current version and effective date will be published on our website.

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