Privacy Policy
Effective date: 14 October 2026
This Privacy Policy explains how personal data is processed when you visit othermind.dev (the "Site") or contact Othermind by email. It is written to meet the requirements of the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the Finnish Data Protection Act (tietosuojalaki 1050/2018).
1. Who we are (the controller)
Othermind is not a company. The controller is Quyen Nguyen (sole proprietor, Business ID 3592700-9), operating under the name Othermind.
- Controller: Quyen Nguyen (Finnish sole proprietor / toiminimi)
- Business ID (Y-tunnus): 3592700-9
- Registered address: Puistokatu 6 A 369, 90120 Oulu, Finland
- Email: [email protected]
"We", "us" and "our" in this policy mean the controller above. For any privacy question or request, email [email protected].
2. What this policy covers, and what it does not
This policy covers the Site and email correspondence with us.
It does not cover personal data that we process on behalf of clients when we build or host AI agents for them. In that work the client is normally the controller and we act as their processor, under a separate data processing agreement (DPA). If you interact with an AI agent run by one of our clients, please refer to that client's privacy notice.
3. What personal data we process
a) Email inquiries. When you email us, we process your name, email address, any company or contact details you include, the content of your messages and attachments, and the dates and technical headers of the emails.
b) Website analytics. We use Cloudflare Web Analytics to understand how the Site is used (for example page views, referring sites, and browser, device and country information in aggregate). Cloudflare Web Analytics does not use cookies or local storage and, according to Cloudflare, does not fingerprint or track individual visitors. We only see aggregated statistics and cannot identify you from them.
c) Server and security logs. The Site is hosted on and delivered through Cloudflare. As with any website, delivering a page requires processing technical data such as your IP address, the time of the request, the URL requested, your browser's user-agent and referrer. Cloudflare processes this data to deliver the Site and to protect it against abuse and attacks.
We do not ask for, and ask you not to send us, special categories of personal data (such as health information) by email.
4. Why we process it and our legal bases
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Answering your inquiry, preparing a quote, and taking steps before entering into an agreement at your request | Email inquiries | Art. 6(1)(b) – steps prior to entering into a contract |
| Answering general inquiries not related to a possible agreement, and keeping a record of business correspondence | Email inquiries | Art. 6(1)(f) – our legitimate interest in communicating with people who contact us |
| Understanding and improving the Site | Aggregated analytics | Art. 6(1)(f) – our legitimate interest in running a useful website |
| Delivering the Site securely, preventing abuse and investigating incidents | Server and security logs | Art. 6(1)(f) – our legitimate interest in keeping the Site available and secure |
Where an inquiry leads to an agreement, related records may also be kept to meet our bookkeeping and tax obligations under Finnish law (Art. 6(1)(c) – legal obligation).
Where we rely on legitimate interests, we have considered that the processing is limited and expected, and that it does not override your rights. You can object at any time (see section 8).
We do not sell personal data, do not use it for advertising, and do not make decisions about you based solely on automated processing.
5. How long we keep it
- Email inquiries: kept for as long as needed to handle the inquiry and any follow-up, and deleted within 24 months after our last contact, unless the inquiry leads to an agreement. Correspondence that forms part of a client relationship or of our accounting records is kept for as long as that relationship lasts and for the periods required by Finnish accounting and tax law.
- Analytics: only aggregated statistics are available to us; they are retained according to Cloudflare's standard Web Analytics retention.
- Server and security logs: processed by Cloudflare and retained for limited periods according to Cloudflare's practices for service delivery and security.
6. Who processes data for us
We use the following service providers (processors), who process personal data on our behalf and under data processing terms:
- Cloudflare, Inc. (USA) – website hosting, content delivery, security and Web Analytics. See cloudflare.com/privacypolicy.
- Zoho – email hosting (Zoho Mail) for [email protected]. Our mailbox is hosted in Zoho's EU data centre (zoho.eu), so email is stored in the EU. See zoho.com/privacy.html.
We may also disclose personal data where required by law or to establish, exercise or defend legal claims. We do not otherwise share your personal data with third parties.
7. International transfers
Email is hosted in the EU (Zoho's EU data centre). Cloudflare, which hosts and delivers the Site, is a U.S. company and may process personal data such as IP addresses outside the European Economic Area (EEA), including in the United States. Such transfers are protected by one of the following safeguards:
- the EU-U.S. Data Privacy Framework, where the recipient is certified under it (an adequacy decision of the European Commission); or
- the European Commission's Standard Contractual Clauses (SCCs), together with additional safeguards where needed.
You can ask us for more information about the safeguards used by emailing [email protected].
8. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you and receive a copy;
- rectify inaccurate or incomplete data;
- erasure of your data, where the legal conditions are met;
- restrict processing in certain cases;
- object to processing based on our legitimate interests;
- data portability for data you provided to us, where processing is based on a contract and carried out by automated means.
To exercise your rights, email [email protected]. We may need to confirm your identity. We will respond without undue delay and in any case within one month, which may be extended in the cases permitted by the GDPR. Exercising your rights is free of charge.
9. Right to complain
If you believe we process your personal data unlawfully, you have the right to lodge a complaint with a supervisory authority. In Finland this is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto): tietosuoja.fi. You may also complain to the supervisory authority in the EU/EEA country where you live or work. We would appreciate the chance to address your concern first, so feel free to contact us at [email protected].
10. Cookies
The Site does not use cookies or similar tracking technologies, and we do not use any advertising or third-party tracking tools. Cloudflare Web Analytics works without cookies. Because no non-essential cookies are used, the Site does not show a cookie banner.
11. Security
We use reasonable technical and organisational measures to protect personal data, including encrypted connections (HTTPS) to the Site and access controls on our email account. No method of transmission over the internet is completely secure, so please avoid sending highly sensitive information by email.
12. Changes to this policy
We may update this policy, for example if the Site or our service providers change. The updated version will be posted on this page with a new effective date. If the changes are significant, we will make reasonable efforts to point them out.
13. Contact
Questions about this policy or your personal data: [email protected].