Who we are
This notice explains how Mindclip Behaviour Oy ("we", "us") processes personal data in connection with our websites, our consulting services and our survey platform (together, the "Services"). It applies to the Mindclip Behaviour website, the Maria Pennanen website (together, the "Websites") and the Mindclip Behaviour Survey at survey.mindclip.com (the "Survey Platform").
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Controller: Mindclip Behaviour Oy, Helsinki, Finland
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Business ID (Y-tunnus): 3132533-4
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VAT: FI31325334
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Postal address: PL 27, 00101 Helsinki, Finland
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Visiting address: Maria 01, Lapinlahdenkatu 16, 00180 Helsinki, Finland
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Email: info@mindclip.com
If you have concerns, you can contact the Finnish Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto), P.O. Box 800, 00531 Helsinki, tietosuoja@om.fi.
Last updated: 30 September 2026.
What data we collect
We collect only what is needed for the purposes below.
On the Websites:
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Enquiries and contact forms: name, email, role, company, message.
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Webinars and events: name, email, company, role, registration and attendance data.
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Scheduling (discovery calls, workshops): name, email, time zone, meeting details.
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Newsletter subscriptions: name, email, consent preferences.
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Analytics and advertising cookies: pseudonymous identifiers, device and browser information, pages visited, referrers. Set only after consent (see Cookies).
On the Survey Platform:
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From participants: name, email address, survey answers, and the results we calculate from them (your behavioural profile and report).
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From participants about feedback givers: the names and email addresses you enter so we can send them the feedback survey.
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From feedback givers: your answers about the participant. We ask for nothing beyond the email address the participant gave us.
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Technical data: the minimum server logs needed to run and secure the platform. We use no analytics or advertising tools on the Survey Platform.
Cross-site use and marketing
If you submit your details on either Website (contact forms, webinar sign-ups, discovery calls, newsletter), we may use that information across both Websites to respond, schedule, deliver services, and send relevant updates about Mindclip Behaviour and Maria Pennanen's professional activities.
We run a single newsletter under Mindclip Behaviour. We send it only where you have given consent. If you opt in on either Website, you receive Mindclip updates only. You can unsubscribe at any time using the link in every email, and your opt-out applies across both Websites.
For routine B2B communications, such as replying to your enquiry or scheduling a call, we rely on legitimate interests and keep the scope narrow.
Survey Platform email addresses are used only to run the survey. We do not add them to the newsletter or use them for marketing.
Why we process data and legal bases (GDPR Art. 6)
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Responding to enquiries, scoping proposals and workshops: contract or steps prior to a contract (Art. 6(1)(b)); limited legitimate interests for routine B2B communications (Art. 6(1)(f)).
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Delivering webinars and events: contract (Art. 6(1)(b)).
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Newsletters and direct marketing: consent (Art. 6(1)(a)); unsubscribe at any time.
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Analytics and advertising cookies on the Websites: consent (Art. 6(1)(a)).
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Running your survey and producing your report: contract, or steps you asked for before one (Art. 6(1)(b)). This applies when you sign up yourself and when your organisation or a programme arranged the survey for you.
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Inviting feedback givers and processing their answers: our legitimate interest in delivering the 360 feedback the participant requested (Art. 6(1)(f)). Feedback givers can decline by not completing the survey.
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Compliance, security and fraud prevention: legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)).
Because the survey rests on contract and legitimate interest, we do not ask participants to consent to this notice. We ask you to read it.
Survey feedback givers and who sees results
If you received a survey link, a participant entered your email address and asked for your feedback. We use your address only to send the survey and up to a few reminders.
Your answers are anonymous to the participant. A participant must invite at least 5 feedback givers, and we calculate results only once at least 4 have answered. Results are shown as an aggregate. The participant never sees who answered or what any individual said.
We keep your email address together with your answers for as long as the participant's data is kept (see Retention). We need it to attribute your answers to the right survey and to send reminders. It is never shown to the participant, and we do not use it for anything else. We do not ask feedback givers for their name. You can ask us to delete your answers at any time by writing to info@mindclip.com.
Only the participant receives their individual results and report. If you take the survey as part of a workshop, programme or corporate engagement, the organiser does not receive your individual results. The organiser and the group may see an anonymised group overview without names, and only where the group is large enough that no individual can be identified from it. Your facilitator or coach at Mindclip Behaviour sees your results in order to run the debrief you signed up for. We do not sell or share results with anyone else.
Who processes your data and international transfers
We use processors under data processing agreements. They act only on our instructions.
Websites:
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Mailchimp (Intuit): marketing emails and newsletters
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HubSpot: CRM and contact management
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Calendly: scheduling
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Zoom: webinars and meetings
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Typeform: forms and applications
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Google Analytics 4: website analytics, consented cookies
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LinkedIn Insight Tag / Ads: advertising and conversion, consented cookies
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Vimeo: video hosting and embeds, may set cookies on play
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Zapier: workflow automation
Survey Platform:
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Supabase: database storing survey data and results, Frankfurt (EU)
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Vercel: hosting of the survey application, Frankfurt (EU)
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Resend: survey invitations, reminders and report links, Ireland (EU)
Some processors are established outside the EEA, for example in the U.S. Where applicable, we rely on the EU-U.S. Data Privacy Framework and the European Commission's Standard Contractual Clauses in each vendor's data processing agreement.
Retention
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Enquiries and proposals: 12 to 24 months from last contact.
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Webinar registrations: up to 24 months for attendance records and follow-ups, or sooner on request.
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Newsletter subscribers: until you unsubscribe; thereafter kept on a suppression list to honour the opt-out.
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Survey participants' answers, profile and report: 24 months from completion, so you can retake the survey and compare. Deleted or anonymised after that, or earlier on request.
Feedback givers' email addresses and answers: kept with the participant's data, 24 months from completion, then deleted.
Anonymised group overviews: kept without time limit. They contain no personal data.
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Contracts and billing data: per statutory bookkeeping limits.
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Analytics cookies: per the lifespans in the Cookie Policy below.
Your rights
You may request access, rectification, erasure, restriction or portability of your data, object to processing based on legitimate interests, and withdraw consent at any time for newsletters and cookies. One limit: once feedback givers' answers have been anonymised, we can no longer identify or delete an individual feedback giver's answers.
To exercise your rights, write to info@mindclip.com. You also have the right to complain to the Office of the Data Protection Ombudsman (contact above).
Cookies and tracking
Each Website uses a cookie banner. Non-essential cookies (analytics, advertising, media) are set only after your consent on that Website. If you visit both Websites, you may be asked for consent on each domain separately. You can change or withdraw consent at any time via Cookie Settings in the banner or footer.
We use analytics (Google Analytics 4) and advertising and conversion tools (LinkedIn Insight Tag) to understand interest in our Services and measure webinar sign-ups, only with consent. Details are in the Cookie Policy below.
The Survey Platform sets no analytics, advertising or tracking cookies. It uses only the cookies or browser storage strictly necessary to keep your survey session open and secure. These need no consent and expire when the session ends.
Security
We use TLS in transit, restricted access, least-privilege controls and vendor data processing agreements. Survey data is stored in the EU and survey links are unique and cannot be guessed. No method is fully secure, but we take reasonable technical and organisational measures to protect personal data.
Privacy of children
Our Services are intended for professionals. We do not knowingly collect data from anyone under 18.
Changes
We will update this notice when our processing changes and post a new "Last updated" date.
Contact: Mindclip Behaviour Oy, info@mindclip.com
Cookie Policy
Last updated: 30 September 2026.
We use cookies and similar technologies on the Websites to run them and measure performance. Non-essential cookies are set only after your consent via the banner. You can change or withdraw consent at any time via Cookie Settings. The Survey Platform uses essential session cookies only.
Categories:
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Essential (always on): security, load balancing, basic preferences, survey session.
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Analytics (consent): understand site usage to improve content (Google Analytics 4).
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Advertising and conversion (consent): measure campaigns and webinar sign-ups (LinkedIn Insight Tag).
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Media (consent): video embeds may set cookies on play (Vimeo).
Cookies in use (name, provider, purpose, category, typical expiry):
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_ga,ga*: Google Analytics 4, usage analytics (pageviews, sessions), Analytics, up to 13 months
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li_fat_id, li_sugr, bcookie: LinkedIn, ad conversion and attribution, Advertising, 30 days to 24 months
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vuid: Vimeo, video analytics for embedded videos, Media, 24 months
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Consent cookie(s): consent manager, stores consent state, Essential, 6 to 12 months
Managing cookies: use Cookie Settings in the banner or footer to change or withdraw consent.
