1. INTRODUCTION TO THE PRIVACY POLICY

CloudNest, Lda, corporate entity no. PT51906514, headquartered at Rua General Humberto Delgado, n.º 21, 2140-126 Chamusca, Portugal, hereinafter referred to as “CloudNest” or “The Mind Hub”, is the entity responsible for processing personal data collected through its website and other digital platforms associated with the brand The Mind Hub.

The Mind Hub is a company specialized in CRM implementation and Artificial Intelligence applied to business productivity, offering a platform that enables the creation and operation of customized AI agents capable of automating sales, customer service, and internal operations.

CloudNest, Lda is committed to protecting the privacy and personal data of all users, clients, and partners, in compliance with the General Data Protection Regulation (GDPR) and Law no. 58/2019.

This Privacy Policy aims to explain how we collect, use, store, and protect your personal data, as well as to clarify your rights as a data subject.

2. PURPOSE

This Policy aims to ensure that the processing of personal data carried out by CloudNest, Lda is lawful, fair, transparent, and secure, demonstrating the company’s commitment to complying with applicable legislation and fundamental data protection principles.

CloudNest undertakes to:

• Process only the data strictly necessary for each specific purpose;
• Ensure the accuracy and updating of personal data;
• Implement appropriate technical and organizational measures to protect information;
• Act transparently with all personal data subjects.

3. GLOSSARY

For a better understanding of this Policy, the main terms used are defined below:

• Personal Data: Any information relating to an identified or identifiable natural person (e.g., name, email, telephone number, IP address).
• Data Processing: Any operation performed on personal data, such as collection, registration, organization, storage, alteration, consultation, use, disclosure, or deletion.
• Data Subject: The natural person to whom the personal data relates.
• Data Controller: The entity that determines the purposes and means of data processing — in this case, CloudNest, Lda.
• Processor: A natural or legal person who processes personal data on behalf of the controller.
• Consent: A freely given, specific, informed, and explicit indication of the data subject’s wishes by which they agree to the processing of their personal data.
• Anonymization: A process that makes it impossible to identify the data subject.
• GDPR: Regulation (EU) 2016/679 on the protection of natural persons regarding the processing of personal data and the free movement of such data.

4. PERSONAL DATA COLLECTED

CloudNest may collect personal data in different contexts, as illustrated below:

a) Registration and Use of The Mind Hub Platform

During the registration process and use of the Mind Hub platform, the following personal data may be collected: full name, company name, taxpayer identification number (NIF), email address, and phone/WhatsApp number.

This data is used to create and manage the user account, based on contract performance pursuant to Article 6(1)(b) of the GDPR.

Additionally, email addresses may be used to send commercial updates, information, and newsletters, with the data subject’s explicit consent, under Article 6(1)(a) of the GDPR.

Technical data such as IP address, browser type, device, and access logs are also collected to ensure security and proper platform functioning, based on CloudNest’s legitimate interests under Article 6(1)(f) of the GDPR.

b) Financial Operations

For invoicing, payments, and financial management purposes, the following data is processed: name, taxpayer identification number (NIF), and bank details.

This processing is based on legal obligations pursuant to Article 6(1)(c) of the GDPR.

c) Support and Contact

For customer service, clarifying doubts, and providing technical support, The Mind Hub may collect: name, email address, and phone/WhatsApp number.

This data is used exclusively to respond to contact requests, provide technical assistance, and ensure adequate support.

5. AUTOMATICALLY COLLECTED DATA

In addition to the data you provide directly, CloudNest may automatically collect:

• IP address and approximate location data;
• Device type and operating system;
• Browsing data and website interactions (through cookies);
• History of conversations with AI agents (only when the user interacts with The Mind Hub platform).

This information is used to improve user experience, ensure security, and optimize service performance.

6. USE OF COOKIES

The Mind Hub website uses cookies to improve performance and user experience.

Types of Cookies Used:

• Essential: Required for website functionality.
• Analytical: Used to analyze visitor behavior (e.g., Google Analytics).
• Functional: Used to remember user preferences.
• Advertising: Used to display relevant ads based on user interests.

Users may manage or disable cookies directly in their browser settings (Chrome, Firefox, Safari, Edge).

By continuing to browse the site, users are deemed to accept the use of cookies in accordance with this Policy.

7. USE OF GENERATIVE ARTIFICIAL INTELLIGENCE

The Mind Hub integrates Generative AI technologies to enable the creation of Cognitive Agents that automate business communications and processes.

These technologies use third-party APIs (such as OpenAI, Anthropic, Google AI, among others) to generate responses, text, and interactions.

CloudNest ensures that no personal data is shared with these providers unless strictly necessary and always in compliance with the GDPR.

Data That May Be Processed:

• Data provided by the user (e.g., name, email);
• Content of conversations with the Cognitive Agent;
• Technical data (e.g., IP, interaction time, device).

Purposes:

• Responding to queries and providing support;
• Improving user experience and personalizing interactions;
• Training and optimizing AI agent performance (always anonymized).
• Interactions with Cognitive Agents may be reviewed, deleted, or anonymized upon request by the data subject.

8. SHARING PERSONAL DATA

CloudNest, Lda may share personal data only when necessary and always in compliance with the GDPR, including with:

• Judicial or administrative authorities, when legally required;
• Service providers (e.g., payment platforms, data hosting, legal and financial advisers);
• Companies within the same corporate group, solely with the data subject’s explicit consent;
• Technological processors (e.g., servers, CRM systems, AI APIs), under confidentiality and GDPR-compliant agreements.

No personal data is sold, rented, or transferred for improper commercial purposes.

9. DATA RETENTION PERIOD

Personal data is retained only for the period strictly necessary to fulfill the purposes for which it was collected, including:

5 years for invoicing data (legal obligation);

• Until consent is withdrawn for marketing communications;
• Throughout the contract duration and up to 2 years after its end for legal defense;
• Indefinitely in anonymized form for statistical or service improvement purposes.

10. DATA SECURITY

CloudNest implements appropriate technical and organizational measures to ensure the security of personal data, including:

• Data encryption in transit and at rest;
• Role-based access control and multifactor authentication;
• Audit logs and security monitoring;
• Confidentiality agreements with all employees and partners;
• Regular backups and storage on secure servers located within the European Union.

11. RIGHTS OF DATA SUBJECTS

Under the GDPR, data subjects have the right to:

• Access their personal data;
• Request rectification or updating;
• Request erasure (“right to be forgotten”);
• Restrict or object to processing;
• Request data portability;
• Withdraw consent at any time;
• Lodge a complaint with the Portuguese Data Protection Authority (CNPD).

All requests must be addressed to CloudNest’s Data Protection Officer (DPO) through the contact details below.

12. DATA PROTECTION OFFICER (DPO) CONTACT

For questions, requests, or to exercise your privacy rights, you may contact us at:

📧 Email: legal@themindhub.ai

📍 Address: CloudNest, Lda – Rua General Humberto Delgado, n.º 21, 2140-126 Chamusca, Portugal

13. CHANGES TO THE PRIVACY POLICY

CloudNest, Lda reserves the right to update or modify this Privacy Policy at any time. Any changes will be published on The Mind Hub website with an indication of the revision date.

Continued use of our services after the publication of changes implies acceptance of the updated Policy.

Last updated: October 2025