Privacy Policy
Last updated: 11 November 2026
1. Who is responsible for your data?
MINDS FIRST is a trading name of Pavel Smoliakov - Organizačný a IT poradca (IČO 55710522), with a place of business at Orechová 5004/131, 900 42 Dunajská Lužná, Slovak Republic. The operator is the data controller for the activities described in this policy.
Email: info@minds-first.com
Telephone: +421 944 004 504
2. What information do we process?
We process the information necessary to handle business enquiries and provide our services, including:
- Email enquiries: your name, email address, job title or role, company details, message and any attachments you choose to send.
- Website service enquiry form: your name, work email address, company website, description of your business challenge and any service or additional details you choose to provide.
- First Perspective questionnaire: your name, work email address, position, company name, company website, selections about your business challenges, written answers and additional business context you provide.
- Business research: relevant information about a company from its website and publicly accessible professional sources; occasionally this may include names and professional roles of identifiable people.
- Website use: IP addresses, browser information, timestamps and technical request logs may be processed to deliver and protect the website.
- Service delivery: correspondence, project briefs, agreed deliverables, contract information and relevant business records if you become a client.
We do not ask for special-category personal data (such as health or political opinions). Please do not submit such data, unnecessary information about other identifiable people, or trade secrets that you are not authorised to disclose.
3. Purposes and legal bases
| Purpose | Legal basis under GDPR |
|---|---|
| Respond to email enquiries and requests submitted through the website service enquiry form | Legitimate interests, Art. 6(1)(f): responding to requested professional contact and assessing potential cooperation; Art. 6(1)(b) only where necessary for pre-contractual steps requested by an individual contracting party. |
| Review First Perspective responses, research a business problem and prepare an initial assessment | Legitimate interests, Art. 6(1)(f): dealing with the respondent's voluntary professional request and demonstrating whether our expertise may help. |
| Communicate and deliver agreed services | Art. 6(1)(b) where the contract is with a natural person; otherwise legitimate interests, Art. 6(1)(f), for communications with representatives of business customers; legal obligation, Art. 6(1)(c), where applicable. |
| Operate and protect the website, investigate abuse and keep necessary technical logs | Legitimate interests, Art. 6(1)(f), for service operation and security. |
| Retain legally required financial and business records | Legal obligation, Art. 6(1)(c), where applicable. |
When relying on legitimate interests, we consider the necessity of the processing and the rights and expectations of the individuals concerned. You may object to processing carried out on that basis.
4. Website service enquiry form
You can request information about our services directly through a form on the MINDS FIRST website. The form collects your name, work email address, company website and a short description of your enquiry. You may also indicate a service you are interested in. We use this information to review your request, reply to you, and discuss possible cooperation. Submitting a request does not create a contract and does not sign you up for marketing communications.
The form is separate from First Perspective. Email delivery from the website enquiry form is currently unavailable. When delivery is enabled, the site will validate enquiries, apply measures to prevent abuse and forward successful submissions to the business operator via Brevo. The hosting and delivery services may handle IP addresses, timestamps and technical logs as necessary for security or delivery.
Providing information is voluntary, but we need a working email address and enough information about your enquiry to respond. A link to this Privacy Policy is provided next to the form submission control. Information received through this form follows the same retention rules as other business enquiries.
5. The First Perspective questionnaire and AI assistance
The First Perspective page embeds a questionnaire hosted by Tally. We use the answers to assess the business challenge, prepare a tailored preliminary perspective and respond to the person who submitted it.
We may use personal ChatGPT to assist with structuring and analysing de-identified business information. Before using it, we remove names, email addresses and other direct and indirect identifiers that could reasonably identify a natural person. If the remaining material could still identify a person, we do not enter it into the personal AI service. We do not automatically transmit complete Tally submissions to ChatGPT. We use ChatGPT with model-improvement disabled for this workflow and review all substantive outputs ourselves before communicating them.
There is no automated decision-making, including profiling, that produces legal or similarly significant effects concerning individuals within the meaning of GDPR Article 22.
6. Website analytics
MINDS FIRST does not load Google Analytics 4 or advertising tags on this website. The embedded First Perspective questionnaire connects to Tally on its own domain. See the Cookie Policy for details.
7. Who can access the information?
Only the business operator has direct working access to submitted enquiries. This does not mean data is processed without external technology providers. Depending on the service, recipients or categories of recipients include:
- Tally (Belgium): hosts the First Perspective questionnaire and stores responses on our behalf under its data processing agreement. Form-owner email notifications are enabled. Tally’s email subprocessor SendGrid (United States) may process notification content.
- Google Drive: controlled-access copies of questionnaire responses and related documents may be stored here. Records containing personal data are to be stored under Google Workspace with applicable data-processing terms, rather than consumer Google Drive.
- Brevo: designated to transmit website enquiry emails when form delivery is enabled.
- Email providers: transmission and storage of correspondence and questionnaire notifications.
- ChatGPT Sites (OpenAI) and its infrastructure providers: website hosting, delivery and security.
- Public authorities or professional advisers: only where required by law or necessary to establish, exercise or defend legal rights.
We do not sell personal data or enrol people in a marketing mailing list simply because they email us, submit a website enquiry or complete First Perspective.
8. International data transfers
Tally states that form response data is stored in the EU, although some service subprocessors operate outside the EEA, including SendGrid in the United States for form email notifications. Website hosting, document storage and email providers may also process data outside the EEA.
Where personal data is transferred outside the EEA, the transfer must be covered by a valid GDPR Chapter V mechanism, such as an applicable European Commission adequacy decision (including where a US recipient is validly certified under the EU–US Data Privacy Framework) or Standard Contractual Clauses with applicable supplementary safeguards. The relevant vendor terms and transfer mechanisms must be reviewed before activating each service. Information about applicable safeguards and how to obtain them may be requested via info@minds-first.com.
We do not intentionally transfer identifiable questionnaire responses into a personal ChatGPT account.
9. How long do we retain data?
- Email enquiries, website contact-form requests and First Perspective submissions that do not lead to a project: up to 12 months after the last substantive communication, unless a separate legal basis requires or justifies longer retention.
- Copies in Tally, website form-processing systems, Google Drive and email: subject to the same applicable deletion schedule; we review and delete them across locations under our control.
- Client records: for the duration of the engagement and for longer where required by accounting, tax or other law, or necessary for legal claims; the specific period follows the relevant legal obligation or limitation period.
- Technical and security logs: only as long as reasonably necessary for website operation and security, subject to the hosting provider’s applicable retention settings.
Tally documents that deleted submission data can remain in backups for up to 90 days unless earlier removal is available through its deletion controls. Deletion requests are processed subject to lawful retention exceptions.
10. Your rights
Subject to the requirements of GDPR, you can request access, rectification, erasure, restriction of processing and data portability where applicable; object to processing based on legitimate interests; and withdraw consent at any time where consent is the legal basis. Withdrawal does not affect earlier lawful processing. You also have the right to object to direct marketing.
Send requests to info@minds-first.com. We normally reply within one month, subject to the extensions allowed by GDPR. We may verify your identity where reasonably necessary.
You may lodge a complaint with the Úrad na ochranu osobných údajov Slovenskej republiky, Galvaniho 7/B, 821 04 Bratislava, Slovak Republic; dataprotection.gov.sk. You may also contact another competent EEA supervisory authority.
11. Cookies
The MINDS FIRST website does not set its own analytics or advertising cookies. The hosting platform and the embedded Tally questionnaire may use technical technologies to deliver and protect their services. The Cookie Policy explains where those technologies may apply.
12. Security and provision of data
We restrict access to business information to the operator, use account security and access controls, and delete information in accordance with the retention rules. Information provided through the website enquiry form, email or First Perspective questionnaire is voluntary and is not a statutory requirement. However, without sufficient contact details and business context we may be unable to respond to your enquiry or prepare First Perspective.
13. Public-source information
We may research businesses through publicly available websites and professional information. Where this includes personal data not obtained directly from an individual, we comply with GDPR Article 14, including its notice requirements and available exceptions. The sources are public company websites and publicly available professional pages.
14. Changes
We update this notice if our processing or service providers change materially. The current version and its date are published on our website. Privacy enquiries: info@minds-first.com.