Privacy Policy

This Privacy Policy is intended for all persons visiting the Achieveminds website, submitting any enquiries or complaints therefrom, and any persons entering into, or seeking to enter into, agreements with, or otherwise contracting the services of Achieveminds Coaching Limited(hereinafter referred to as “Achieveminds”, “us” or “we”).  We understand the importance of your personal data and are wholly committed to ensuring the privacy thereof.

The purpose of this Privacy Policy is to inform you about (i) the collection and retention of your personal data, (ii) our obligations to process your data lawfully under the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as the “GDPR” or “Regulation”) and any other legislation as may be applicable to Achieveminds Coaching and (iii) your data protection rights under the same Regulation.

We ensure that we process your data in a lawful manner, in accordance with the Regulation and any other legislation as may be applicable, and that we only collect and retain personal data in ways described in this Privacy Policy. Achieveminds Coaching takes the obligations imposed by the Regulation, and any other legislation as may be applicable, very seriously and we ensure that all the necessary technical and organisational measures have been put in place to safeguard your rights.

It is important to read this Privacy Policy and to understand its contents so that you are fully aware of how and why we are using your data. Before using our services you shall be requested to read and accept this Privacy Policy. Should you decide not to accept this Privacy Policy we will be unable to provide you with any of the services you may require and you should stop using our website immediately.

1. Definitions

“Data Subjects” means the individuals about whom personal data has been collected and processed by us.

“Personal Data” means information pertaining to an individual who is, or can be, identified from the data held or processed by us. This can include data which relates to the identity, characteristics or behaviour of an individual or which influences the way in which that individual is treated or evaluated, such as the person’s name and surname, address, date of birth, nationality, gender, civil status, contact details and bank account details.

“Processing” means the performance of any activity or operation on personal data, including (i) obtaining, recording or keeping data; (ii) organising or altering the data; (iii) retrieving, consulting or using the data; (iv) disclosing the data to a third party; and (v) erasing or destroying the data.

2. Data Controller

The data controller of this website is Achieveminds Coaching Limited, a limited liability company registered in Malta bearing company registration number C 109427, whose registered office is situate at 40, Villa Fairholme, Triq Sir Augustus Bartolo, Ta’ Xbiex, XBX 1095, Malta.

3. Data We Collect

In the course of its relationship with you, Achieveminds Coaching will need to collect, use, and sometimes, disclose various items of your Personal Data to effectively provide you with the best experience of our products and services. We ensure that your Personal Data shall be processed for specified, explicit and legitimate purposes in a manner which is fair and lawful. We also seek to ensure that any Personal Data which is being processed is correct and up to date. Achieveminds Coaching shall only collect and process Personal Data to the extent necessary for the specific purposes for which it was collected.

For the sake of transparency, we have provided a list of the different kinds of Personal Data about our clients or mere users of our website that we may need to collect and process. It is important to note that this list is merely indicative and not exhaustive.

• Identity Data which includes first name, last name, gender and nationality.
• Contact Data which includes email address, billing address, mailing address and contact numbers.
• Financial Data which includes bank account details and any payment methods used by the client to pay for our services.
• Profile Data which includes information about the games that may be of interest to you, your skill level in those games and the languages you speak.
• Marketing and Communications Data which includes your preferences in receiving marketing from us and your communication preferences.

The abovementioned Personal Data will be provided directly by you upon entering into contractual obligations with us.

4. Log Data

When you visit our website we will automatically process the following information and this shall solely be for the use of Achieveminds Coaching:

• The client’s internet protocol (IP) address.
• The type and version of your browser.
• The date and time when you accessed the website.
• The pages that you visited on the website and the time spent on those pages.

5. Data Retention

We ensure that we shall only retain your Personal Data for as long as is necessary and insofar as there remains a lawful purpose, in terms of the Regulation or any other applicable law, for the retention thereof. Once your Personal Data is no longer required, we shall take all the reasonable steps to ensure that it is disposed of in its entirety in a correct and timely manner. The period of retention of your Personal Data may vary between a few months to over ten years due to legal obligations which arise from applicable laws and, or court orders.

6. Cookies

Cookies are small files of code that are transferred to and stored on the user’s browser when the user visits the website. We use cookies to analyse trends and help us facilitate and improve your experience of our website.

You can opt to refuse all or some browser cookies, or to be alerted when a cookie is being set. However, if you refuse cookies, you may not be able to access or use some parts of the website.

7. Disclosure your personal data

We may have to grant access to, disclose or share your Personal Data with the parties set out below:

• The coaches listed on our website.
• Third-party suppliers or business partners engaged to process Personal Data on behalf of Achieveminds Coaching.
• Service providers, including those that provide IT support services for Achieveminds Coaching.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We require all third parties to ensure that they have adequate safety measures in place to safeguard Personal Data. Achieveminds Coaching shall ensure that third-party service providers shall only process Personal Data in fulfilment of its contractual obligations towards us or upon our documented instructions and not for any other purposes.

8. Your right as a data subject

As a Data Subject, you have rights under the Regulation, and any other applicable legislation, which you may exercise in certain circumstances in relation to your Personal Data.

8.1 The Right of Access

You have the right to obtain confirmation as to whether or not any of your Personal Data is being processed, and, where that is the case, you also have the right to access the Personal Data, as well as any information concerning, inter alia, the purposes of the Processing and the categories of the Personal Data being processed.

You may obtain a copy of the Personal Data being processed by submitting a written request to our privacy officer, who may be contacted at fabro@achieveminds.com.

8.2 The Right of Rectification

You have the right to obtain the rectification of inaccurate Personal Data pertaining to yourself and to have incomplete Personal Data completed. We kindly ask you to inform us of any changes to the Personal Data held by us, since failure to do so may impair our ability to provide you with your requested services or may hinder the quality thereof.

8.3 The Right of Erasure

You have the right to request the deletion or erasure of Personal Data pertaining to yourself where:

• There is no good reason for us to continue Processing it.
• You have successfully exercised your right to object to Processing under Article 21 of the Regulation.
• You believe that your Personal Data has been processed unlawfully.
• The Personal Data has to be erased for compliance with a legal obligation under the law.

8.4 The Right to Restriction of Processing

Where one of the following applies, you shall have the right to request that the Processing of your Personal Data be suspended:

• You contest the accuracy of the Personal Data held by us
• We unlawfully use your Personal Data but you oppose the erasure of the Personal Data and request the restriction of its use instead.
• We no longer need the Personal Data for the purposes of Processing, but you require the Personal Data for the establishment, exercise or defence of legal claims.
• You have objected to our Processing of your Personal Data pending our verification as to whether we have overriding legitimate grounds to process it.

8.5 The Right to Data Portability

Upon request, you shall have the right to receive the Personal Data pertaining to yourself which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such data to another controller.

8.6 The Right to Object

You have the right to object, on grounds relating to your particular situation, at any time, to the Processing of your Personal Data and we shall consequently refrain from the Processing thereof unless we have compelling legitimate grounds for the Processing which override your interests, rights and freedoms, such as the performance of the contract in question or the exercise of any legal obligations to which we are subject or for the establishment, exercise or defence of legal claims.

9. Response to Breaches of Personal Data

Upon discovering a suspected or actual breach of Personal Data, we shall perform an internal investigation and take appropriate remedial measures in a timely manner. Where there is any risk to your rights and freedoms, we shall notify the relevant Supervisory Authorities without undue delay, and, when possible, within 72 hours from when we learn of such breach.

10. Accountability

Achieveminds Coaching shall be responsible for and be able to demonstrate compliance with the principles outlined in this Privacy Policy.

11. International Data transfer

In the event that we transfer your Personal Data to entities outside the European Economic Area, we shall ensure that adequate safeguards are used, including but not limited to (i) only transferring Personal Data to countries that have been approved by the European Commission as providing an adequate level of protection for Personal Data and (ii) in the absence of an adequacy decision by the European Commission, using specific agreements or addendums approved by the European Commission. Authorisation may be obtained from the relevant Data Protection Authority where required.

12. Transaction Security

Achieveminds Coaching ensures that all Personal Data collected, retained and processed is stored securely and protected against unauthorised or unlawful Processing and against any loss, destruction or damage. We regularly review and, where practicable, improve upon the security measures in place.

13. Governing Law

This Privacy Policy is governed by Maltese law and relevant EU legislation. In the event of any conflict between this Privacy Policy and any applicable laws, the latter shall prevail.

14. Changes to the Privacy Policy

We reserve the right to update this Privacy Policy from time to time. If there are any changes to this Privacy Policy, we will replace this page with an updated version and shall duly inform you of the said changes.

15. Questions & Feedback

If you have any questions, or if you would like to send us your feedback, please contact us using the following email address: fabro@achieveminds.com. Any suggestions that you may have, and which may contribute to a better quality of service are welcome and greatly appreciated.

16. Validity

This Privacy Policy shall be deemed effective as of 30.09.2024.