Privacy Policy

PROMIND INSIGHT, INC.

Privacy Policy

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At ProMind Insight, your privacy is a priority. This Privacy Policy explains how we collect, use, share, and protect personal information when you visit our website and when you use our AI-powered personality assessment and related services (together, the “Services”). It is designed to comply with the EU/UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and — where we provide services to educational institutions — the Family Educational Rights and Privacy Act (FERPA).

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By using the Services, you agree to this Policy. If you do not agree, please do not use the Services.

 

1. Who We Are

 

ProMind Insight, Inc. is the controller of the personal information described in this Policy. You can reach us using the details in the “Contact Us” section at the end.

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2. Information We Collect

 

What we collect depends on how you interact with us.

• When you browse our website. Technical and usage data such as your IP address, device and browser type, and how you use the site, together with information from cookies and similar technologies (see “Cookies”). If you use a “Contact Us” form, we collect the name, email, and message you provide.

• When you take a ProMind Assessment. A facial image, captured solely to generate your assessment, and the personality-intelligence results derived from it (for example, personality traits and related insights). How we handle the image is described in Section 3.

• When you create an account. Your login credentials, saved assessment results and history, preferences, and — if you purchase — billing information (payment card details are handled by our payment processor, not stored by us).

 

We currently collect facial imagery for the assessment; we do not collect genetic data, voice recordings, or health records. If our Services expand to other data types, we will update this Policy first.

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3. How We Handle Facial Data — Capture and Destroy

 

Our handling of facial data is built for privacy:

• We ask for your consent before any image is captured.

• The image is used only to generate your assessment.

• The image is immediately converted into a non-reversible analysis (a mathematical representation) and then permanently destroyed — we do not store your photo.

• The non-reversible analysis cannot be turned back into your image or used to identify you from your face.

• We do not perform facial recognition, we do not match faces against any database, and we keep no library of facial images.

 

In short: we look, we learn, and we let the picture go. Because we never keep your image or any reversible biometric record, there is no facial database that could be breached or misused.

 

4. Legal Basis for Processing (GDPR)

 

Where the GDPR applies, we process personal data on one or more of these bases:

• Consent. We obtain your explicit consent before capturing and analyzing your facial image, and for any optional research use. You may withdraw consent at any time.

• Contract. To provide the assessment and results you or an authorized organization requested.

• Legal obligation. To comply with applicable law.

• Legitimate interests. To operate, improve, and secure our Services, where your rights and freedoms do not override those interests.

 

5. How We Use Information

 

• To provide your assessment results to you or to the organization authorized to receive them.

• To operate, maintain, secure, and improve the Services.

• To improve the accuracy of our models — using only anonymized data, and only where you have given separate, optional consent.

• To comply with legal obligations and enforce our terms.

 

6. Automated Analysis and Profiling

 

The assessment uses automated analysis to generate personality insights (“profiling” under the GDPR). These results are informational and are intended to be interpreted by qualified people, not to make legal or similarly significant decisions about you on a solely automated basis. Where the GDPR applies, you have the right to request human review of, and to contest, any decision based solely on automated processing that produces legal or similarly significant effects.

 

7. How We Share Information

 

• We do not sell or rent your personal information, and we do not sell biometric information.

• Authorized requesters. Where an organization (such as a team, employer, or institution) has lawful or contractual authority to receive an assessment, we share results with that authorized party.

• Service providers. Trusted vendors who help us operate the Services, under contracts that require them to protect your data and use it only for us.

• Legal authorities. When required by law, subpoena, or lawful government request.

 

8. Cookies and Tracking

 

We use cookies and similar technologies to run the site, remember your preferences, and understand site usage. You can control cookies through your browser settings and, where required, through our cookie banner. Some features may not work without certain cookies.

 

9. Your Privacy Rights

 

Depending on where you live, you may have some or all of the following rights. To exercise them, contact us at legal@ProMindInsight.com; we will respond as required by law and will not discriminate against you for exercising them.

• GDPR (EU/UK). Access; rectification; erasure (“right to be forgotten”); restriction; objection; data portability; withdrawal of consent at any time; and the right to lodge a complaint with your data protection supervisory authority.

• CCPA/CPRA (California). To know what we collect, use, disclose, and retain; to access and to delete your information; to correct inaccurate information; and to opt out of the sale or sharing of personal information (we do not sell or share it).

 

10. Education Records (FERPA)

 

When we provide Services to a school, college, or university, we act as a “school official” with a legitimate educational interest (or as a service provider) under FERPA, on behalf of and under the direction of the institution. In that role we use student education records only for the purpose the institution authorizes, we do not re-disclose personally identifiable information from those records except as FERPA permits or with consent, and the institution retains ownership and control of its data. Students and parents may exercise their FERPA rights through the institution.

ProMind does not currently provide Services involving Protected Health Information (PHI) under HIPAA. If that changes, we will update this Policy and put appropriate agreements (such as Business Associate Agreements) in place.

 

11. Data Retention

 

• Facial images are not retained — they are destroyed immediately after the analysis is created.

• Assessment results are kept only as long as needed to provide the Services, or as an authorizing institution’s agreement or the law requires, and are then deleted or anonymized.

• Account information is kept for the life of your account and as required by law, after which it is deleted or anonymized.

• Anonymized data, which cannot identify you, may be retained to support benchmarking and model quality.

 

12. Data Security

 

We use industry-standard safeguards, including encryption in transit and at rest, multi-factor authentication, role-based access controls, separation of identity data from analysis data, and regular audits. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

 

13. International Data Transfers

 

We are based in the United States, and your information may be processed in the U.S. or other countries. Where required for transfers subject to the GDPR, we use appropriate safeguards such as Standard Contractual Clauses, along with encryption and pseudonymization of sensitive data.

 

14. Children’s Privacy

 

The Services are intended for adults aged 18 and older. We do not knowingly collect personal information from anyone under 18 without verified parental or guardian consent. Where a minor is assessed in an institutional setting, we rely on the consent and authority of the parent, guardian, or institution as permitted by applicable law. If you believe we have collected a minor’s information without proper consent, contact us and we will delete it.

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15. Changes to This Policy

 

We may update this Policy from time to time. The current version will always be posted here with its effective date, and we will provide additional notice of material changes where appropriate. Your continued use of the Services after an update means you accept the revised Policy.

 

16. Contact Us

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For questions or to exercise your rights, contact:

ProMind Insight, Inc. — Privacy Officer

Email: legal@ProMindInsight.com

Address: PO Box 242, Breinigsville, PA 18031