Privacy Policy

This Privacy Policy governs the processing of personal data by Mindset International s. r. o. when you use our website and platform XPoint.sk (collectively, the "Platform"). We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation — "GDPR") and Act No. 18/2018 Coll. on Personal Data Protection as amended (Slovak Republic).

1. Data Controller Identification

The Data Controller responsible for processing your personal data on XPoint.sk is:

2. Personal Data We Collect, Purposes, and Legal Bases

We process your personal data strictly for specified, explicit, and legitimate purposes:

3. Data Sharing and Recipients

Mindset International s. r. o. does not sell your personal data to third parties. We share your personal data only under the following conditions:

• Independent Experts: When you initiate a booking through XPoint.sk, your necessary contact information is shared with the relevant expert to facilitate the requested service.
• Data Processors: We engage trusted third-party service providers acting on our behalf under data processing agreements complying with Art. 28 GDPR (cloud hosting, email communication services, web analytics).
• Legal Obligations: We may disclose your data to Slovak public authorities, law enforcement agencies, or courts where mandated by law.

4. International Data Transfers

Certain service providers (such as Google LLC for Google Analytics 4 and Microsoft Corporation for Microsoft Clarity) may process data outside the European Economic Area (EEA). Where data is transferred outside the EEA to countries lacking an adequacy decision, we ensure appropriate safeguards are in place pursuant to Chapter V GDPR, such as European Commission Standard Contractual Clauses (SCCs) or the EU-U.S. Data Privacy Framework.

5. Data Retention Periods

• Account Data: Retained for the duration of your active account. Upon account deletion, personal data is permanently purged within 30 days.
• Accounting & Transaction Records: Retained for 10 years following the year of transaction pursuant to Section 35 of Slovak Act No. 431/2002 Coll. on Accounting.
• Xplorer Data: Purged upon account deletion. Anonymized, aggregate statistics that do not identify individuals may be retained indefinitely.
• Marketing Data: Retained until consent is withdrawn or following 3 years of account inactivity.
• Analytics Data: Retained per cookie schedules detailed in our Cookie Policy (maximum 14 months for GA4).

6. Your Rights under GDPR

Under Articles 15 to 22 GDPR and Slovak Act No. 18/2018 Coll., you hold the following statutory rights:

• Right of Access (Art. 15 GDPR): Request confirmation and a copy of your personal data.
• Right to Rectification (Art. 16 GDPR): Request correction of inaccurate personal data.
• Right to Erasure (Art. 17 GDPR): Request deletion of your personal data where legal grounds apply.
• Right to Restriction (Art. 18 GDPR): Request temporary suspension of data processing.
• Right to Data Portability (Art. 20 GDPR): Request transfer of your data in a structured, machine-readable format.
• Right to Object (Art. 21 GDPR): You have the absolute right to object at any time to processing based on legitimate interests (including Xplorer community polling).
• Right to Withdraw Consent (Art. 7(3) GDPR): Withdraw consent at any time without affecting prior lawful processing.

To exercise your rights, contact us at [email protected].

Right to Lodge a Complaint

You have the right to lodge a complaint with the Slovak supervisory authority:

7. Automated Individual Decision-Making and Profiling

We do not engage in automated decision-making or profiling that produces legal effects or significantly affects you within the meaning of Article 22 GDPR.

8. Updates to This Privacy Policy

Mindset International s. r. o. may update this policy periodically. Material changes will be communicated via email or platform notifications prior to taking effect.