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Privacy Policy

last updated 25th Sept 2023

Scope of policy

We, Solutionary Minds SARL (the “Company”) are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms and Conditions) applies to your use of: (i) our website and / or (ii) our Platform of web applications developed using 3rd party provider ( (collectively, the “Company Platforms”), and any of the services accessible through the Company Platforms, (“Services”).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We may for some purposes act as Data Controller for the purposes of applicable data protection laws (including the EU General Data Protection Regulation 2016/679 – “GDPR”) (“Data Protection Laws”).  We are registered in Luxembourg under company number B268185.

Any third parties that we provide your data to may also be data controllers for the purpose of the Data Protection Laws and at that stage use of your personal data will be governed by the privacy policy of the individual third party.


Information we may collect from you

We may collect and process the following data about you:

Information you give us (Submitted Information): you may give us information about you by filling in forms on the Company Platforms, or by corresponding with us (for example, by email). This includes information you provide when you register to use or subscribe to any of our Services, use our website to, access and download documents such as white papers and when you report a problem with any of the Services. The information you give us may include:

E-mail address
Your user name or password

Seniority on the role

Details of your use of the Company Platforms including, but not limited to, traffic data and location data, (Log Information).

If you contact us, we may keep a record of that correspondence.

For clarity, we do not retain your credit card information, which is processed directly by PayPal or Stripe, two of the most frequently used online payment systems. When you make a purchase, you provide your name and/or email address, along with your credit card information, directly to Paypal or Stripe.


Why we collect your personal data

Your personal data is collected primarily so that you can effectively use the Company Platforms and the associated Services. In using the Company Platforms the lawful basis for processing your personal data will either be: (a) to meet the contractual obligations relating to the provision of the Services; or (b) in some instances you may be required to provide your explicit consent to the following use of your personal data:
(i)Contact by us for the administration of the Services provided by the Company Platforms, or to provide you with information regarding the Company and its associated Services;

(ii)To enable you to receive marketing and other communication in relation to services and other offerings provided by the Company, including invitations to submit surveys or attend to events.

(iii)To aggregate your personal data with others personal data into a non – identifiable form in order to carry out analysis of our users for internal business purposes and for the purposes of third-party reporting.

(iv)To make your data available to the community, to connect, engage, participate in community events or access new opportunities.

(v)To prepare personalized analysis of your skills, capabilities and receive dedicated recommendations for your learning experience.


Disclosure of your information

We may disclose some or all the Submitted Information and/or your contact details that we collect from you when you register or use the Company Platforms to third parties on an aggregated basis.

We may disclose your Submitted Information to third parties:
(i)In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
(ii)If Solutionary Minds SARL or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets.
(iii)If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
(iv)Enforce or apply our Terms & Conditions and any other agreements or to investigate potential breaches; or
(v)Protect the rights, property or safety of Solutionary Minds SARL, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.


Where we store your personal data

The data that we collect from you is transferred to, and stored at our web site hosting providers,, Google through their Drive services and other 3rd party providers we may need to perform the Services like, but not limited to, mailing lists (like Mailchimp), processing payments (like PayPal, Stripe).

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Company Platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Company Platforms; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We may collect and store personal data on your device using application data caches and browser web storage (including HTML 5) and other technology.



Our Company Platforms uses cookies to distinguish you from other users of the Company Platforms however, it does not identify you personally. This helps us to provide you with a good experience when you browse our Company Platforms and allows us to improve our Company Platforms. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

Cookies we use

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses so-called “cookies”, i.e. text files that are stored on the user’s device and enable an analysis of the use of the website. The information generated by the cookie about the use of this website (including the user’s IP address, which is, however, shortened by the procedure “_anonymizeIp()”) will be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate the user’s IP address with any other data held by Google.

By using this website, the user consents to the processing of this collected data by Google in the manner and for the purposes set out above.

The user has the option to completely disable measurement by Google Analytics on this website by clicking a link. This will place an opt-out cookie on the user’s device, which will ensure that user sessions are not recorded as long as this cookie remains installed on the user’s browser.


Your rights

In accordance with applicable Data Protection Laws, you have the right to be informed about the use of your data, access your personal data, the right to rectification, a right to restrict our processing activities of your data and a right of erasure.

You have the right to ask us not to process your personal data for any marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You will be required to provide your consent to the processing of your submitted information by checking certain boxes in the Company Platforms.

The Company Platforms may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Company Platforms or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.


Access to information

The applicable Data Protection Laws give you the right to access information held about you. Your right of access can be exercised in accordance with such Data Protection Laws. You will not have to pay a fee to access your personal data (or exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

You can exercise the right at any time by contacting us at


Changes to privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next start the Company Platforms including where we are required to obtain either revised or additional consent from you with regards to the collection, transfer and processing of your personal data. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Company Platforms or the Services.


Contact us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to

Signed as by Andra Fola Directors acting for and on behalf of The Company.