Privacy Policy

1. Who we are

Mynd Labs ("we", "us") is the operating holding for intelligence-infrastructure products built by Barış Esmer. This policy applies to every visitor of any site or application listed above ("Services"). Where a sub-brand has additional product-specific terms (e.g., CommPass CRM data processing), those are referenced inline below.

2. What we collect

We collect three categories of data:

• Information you provide directly — when you fill a contact form, sign up for a newsletter, take a strategy quiz, or create an account on Mynd Platform / CommPass. This includes name, email address, and the answers you give to quiz questions.
• Information collected automatically — anonymous usage analytics (page views, referrer, device type) via PostHog (EU instance) and Ahrefs Web Analytics. We do not use third-party advertising trackers.
• Information from authentication — if you sign in to Mynd Platform or CommPass, we store your email and a hashed session token to keep you logged in. No password is stored in plaintext.

3. Why we use it

• To respond to your inquiries.
• To deliver the product or report you requested.
• To improve the Services (aggregate analytics only).
• To send transactional or newsletter emails — only if you explicitly opted in. You can unsubscribe at any time via the link in every email.

4. Legal basis (GDPR + KVKK)

For EU/EEA visitors, we rely on the lawful bases of consent (newsletter, optional analytics), contract (delivering products you requested), and legitimate interest (security, fraud prevention, aggregate analytics).

For Türkiye-resident visitors, this notice serves as our KVKK aydınlatma metni (KVKK Article 10 information notice). Data controller (Veri Sorumlusu): Mynd Labs. You may exercise your KVKK Article 11 rights (access, rectification, erasure, objection) by emailing hello@myndlabs.io with subject "KVKK request".

5. Where data lives

• Application database: Supabase (EU region) for CommPass and Mynd Platform.
• Static hosting: Vercel (multi-region, EU edge for European visitors).
• Analytics: PostHog (EU instance), Ahrefs Web Analytics.
• Email: Google Workspace + Postmark (DMARC reports only). Outbound emails are signed with DKIM.

All third-party processors above have signed Data Processing Agreements aligned with GDPR Article 28 and equivalent KVKK requirements.

6. Retention

Newsletter subscribers: until you unsubscribe. Quiz responses: 12 months for product analytics, then aggregated and anonymized. CRM lead data inside CommPass: as long as the operating customer (the broker/advisor using CommPass) retains the record. Auth sessions: 90 days idle, then auto-expired.

7. Your rights

You may request access to, correction of, deletion of, or a machine-readable export of your personal data by emailing hello@myndlabs.io. We respond within 30 days. You may also lodge a complaint with your local data protection authority (Türkiye: KVKK; EU: your national DPA).

8. Cookies

We use only strictly necessary cookies (session, language preference) and aggregate analytics cookies (PostHog). We do not set cross-site advertising cookies. You can disable cookies in your browser; the core Services remain functional but personalization and language detection will reset on each visit.

9. Changes to this policy

We update this policy when we change how we handle data. Material changes are announced at the top of this page. Continued use of the Services after a published change constitutes acceptance.

10. Contact

Mynd Labs · Operated by Barış Esmer · Datça, Türkiye · hello@myndlabs.io