Privacy Notice — Wheremind
Version: 1.0 · Date: 4 October 2026
Controller: Clamar Consultoria Unipessoal Lda (“Clamar”, “we”), NIF PT517994232, Rua Eng. Carlos Amarante 258, 4250-089 Porto, Portugal. Clamar decides why and how personal data is processed to operate the Service.
Trade name: Wheremind is a trade name of Clamar, not a separate company.
Seller of the €5 plan: Link, Stripe’s merchant of record. Link decides why and how personal data is processed for that payment and its invoice. That processing is described in Link’s and Stripe’s own notices, not in this one.
Privacy contact: billing@clamar.co
This notice explains how Clamar processes personal data for Wheremind at wheremind.ai and invite.wheremind.ai, under the EU General Data Protection Regulation (GDPR) and Portuguese Law 58/2019 of 8 August.
1. Scope
This notice covers personal data Clamar processes when you:
- create or use an account;
- sign in with a one-time code sent to your email;
- connect an agent with OAuth, where that connection is offered, and call the Service;
- write to us about the Service.
It does not cover Link’s or Stripe’s processing of the €5-plan payment and invoice, where Link is the seller. It does not cover the Maps provider’s own processing where that provider acts independently. Use of Maps content is also subject to that provider’s terms, as described in the Terms of Service.
2. Categories of personal data
| Category | Examples |
|---|---|
| Identity and contact | Email address, and name or organisation if you give them |
| Account | Account identifier, authentication metadata, Wheremind token identifiers, session identifiers |
| Sign-in | Email address, one-time sign-in code (stored only as needed to check it), login time, IP address, user-agent |
| Agent connect | Redirect URI, client identifier, PKCE code-challenge (not the verifier), state and nonce, short-lived authorization codes, access-token identifiers (hashes only, not the token value in logs or URLs), connect time, IP address and user-agent on authorize, token, and register |
| Usage logs | Request time, tool or endpoint name, approximate volume, error codes, IP address, user-agent, throttle and quota events |
| Billing status | Whether a checkout completed, plan, and the payout data Clamar receives. Full card numbers are not stored by Clamar. The invoice for the €5 plan comes from Link |
| Support | Messages you send to billing@clamar.co |
We do not give you Maps provider keys. Those keys stay on Clamar servers.
We do not intentionally collect special-category data. Do not send it in prompts unless it is strictly necessary and lawful.
3. Purposes and legal bases
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Provide the Service, send the sign-in code, authenticate the account, connect an agent where offered, enforce quotas and the kill-switch | Contract (Art. 6(1)(b)) |
| Host, secure, debug, and prevent abuse | Legitimate interests (Art. 6(1)(f)) in running a secure service |
| Keep the accounting records the law requires of Clamar, including payout records | Legal obligation (Art. 6(1)(c)) |
| Service messages about your account, such as downtime or changes to these terms | Contract and/or legitimate interests |
We do not sell personal data. You may object to processing based on legitimate interests (§8).
The legal basis for Link’s payment and invoice is Link’s, not Clamar’s.
4. How we obtain data
- From you, when you create an account, request a sign-in code, connect an agent, or write to us.
- Automatically, from your browser, agents, and clients when they sign in or call the Service (logs and technical data).
- From Link or Stripe, as payment status and payout data for a completed checkout. Not as a copy of Link’s customer invoice file unless you send it to us.
The sign-in code is sent to the email you give us. It is short-lived and single-use.
We do not put authorization codes or access tokens in URLs, query strings, logs, or referrers. Where agent connect uses OAuth, it uses PKCE, and tokens are sent in the POST body or the Authorization header only.
Agent-connect endpoints, when enabled, are on invite.wheremind.ai:
GET /.well-known/oauth-authorization-serverandGET /.well-known/oauth-protected-resourcePOST /oauth/register(public client, no client secret)GET /oauth/authorize,POST /oauth/token, andPOST /oauth/session- Allowlisted callback only:
https://invite.wheremind.ai/oauth/callback
5. Recipients
We use providers under written terms, including:
- Cloudflare, for hosting, CDN, and security;
- Google Cloud and Google Maps Platform, to run Maps calls on Clamar servers. This is infrastructure for the product, not a way to sign in;
- Email delivery, to send sign-in codes and service mail;
- Link and Stripe, for checkout. For the €5 plan, Link is the seller and an independent controller of the payment and the invoice. Clamar receives status and payout data.
Providers may change. We will update this notice when the list of recipients changes in a way that matters.
6. International transfers
Personal data may be processed in the EEA and, where a provider is outside the EEA, transferred under appropriate safeguards, typically Standard Contractual Clauses and extra measures where needed. You may ask about those safeguards at billing@clamar.co.
7. Retention
- Account and contact data: for the life of the account and a short wind-down after it closes.
- Usage logs: for a limited operational window for security, abuse, and disputes, then deleted or aggregated.
- Sign-in codes: only until they are used or expire, then deleted.
- OAuth codes and PKCE verifiers: only for the short exchange, then deleted.
- OAuth refresh tokens: until you revoke them, they expire, or the account ends. Logs keep hashes, not token values.
- Payout and tax records Clamar must keep: for the period required by Portuguese accounting and tax law.
- Support messages: for as long as needed to handle the matter.
When the period ends, we delete or irreversibly anonymise the data, unless the law requires a longer period or we need the data for a legal claim.
8. Your rights
Under the GDPR and Law 58/2019 you may have the right to access, rectify, erase, or restrict your personal data, to data portability where the basis is contract and the processing is automated, to object to processing based on legitimate interests, and to withdraw consent where we rely on consent. You may complain to the Portuguese supervisory authority, CNPD (Comissão Nacional de Proteção de Dados), or another competent EU authority.
Email billing@clamar.co. We may need to verify your identity. Some rights are limited where we must keep data for a legal obligation or a legal claim.
Requests about Link’s invoice or the payment itself go to Link, because Link is the controller for that processing.
We have not appointed a data protection officer. Privacy requests come to the contact above.
9. Security
We use access controls on account tokens, PKCE and allowlisted redirects where agent connect is offered, server-side holding of Maps keys, and logging that does not record secrets, plus the protections of our hosts, including Cloudflare. No method of transmission or storage is perfectly secure. Protect your tokens and tell us if you think an account is compromised.
10. Children
The Service is not directed at children. We do not knowingly collect personal data from children for it.
11. Cookies
The site may use strictly necessary cookies or similar technologies for session security and load balancing. If we add analytics or other non-essential cookies, we will update this notice and ask for consent where the law requires it.
12. No sale of data
We do not sell personal data and we do not use your prompts to sell advertising. Messages about your account are service messages. Any optional marketing would need its own legal basis and an easy opt-out.
13. Maps content
When an agent or application shows place or route results to a person, you must show the Maps attribution the provider requires. That display may involve the provider’s own services. You receive a Wheremind token only, not a provider key.
14. Changes
We may update this notice. The version and date are at the top. Material changes will be sent by email or shown in the Service where practicable.
15. Complaints and contracts
Processing for the Service is in the context of Clamar’s establishment in Portugal. Complaints may be brought to the CNPD. The contract for use of the Service is the Terms of Service (Portuguese law, courts of Porto, without prejudice to mandatory consumer rights). The contract for the €5-plan payment is with Link.
Privacy Notice, version 1.0, 4 October 2026.