Privacy Policy

Effective Date: September 12, 2026

ARCHIPEL respects your privacy and is committed to handling personal data responsibly and transparently.

This Privacy Policy explains how I collect, use, store and protect personal data when you:

• visit https://archipelworld.com;
• contact me or join an ARCHIPEL mailing list;
• complete an ARCHIPEL intake, fit or feedback form;
• participate in coaching, educational processes, workshops, pilot programmes or other ARCHIPEL services; or
• otherwise communicate with me in connection with ARCHIPEL.

1. Data Controller

The person responsible for the processing of your personal data under the EU General Data Protection Regulation (GDPR) is:

Verena Gittner
Email: hello@archipelworld.com
Website: https://archipelworld.com

2. Personal Data I May Collect

The information I collect depends on how you interact with ARCHIPEL.

Website, contact and mailing-list information

This may include:

• name;
• email address;
• information submitted through contact or registration forms;
• stated interests or reason for contacting me;
• communication preferences;
• correspondence between us.

Coaching, pilot and service intake information

If you apply for or participate in an ARCHIPEL coaching or educational process, I may collect information such as:

• name and email address;
• time zone;
• confirmation that you are aged 18 or over;
• the situation, decision, pattern or problem you would like support with;
• examples of situations you are experiencing;
• how the issue affects your life;
• your goals and desired changes;
• things you have already tried;
• patterns or behaviours you notice;
• information about support you currently receive;
• information relevant to determining whether ARCHIPEL is an appropriate service for you;
• preferences about how you would like to be supported;
• feedback about the process.

You are not expected to disclose information that is unnecessary for our work.

Information created during our work together

If you become a client or participant, I may also create or receive:

• session notes;
• private practitioner notes and working hypotheses;
• Personal Navigation Maps;
• observations and reflections;
• experiments or practices we agree to try;
• progress and review notes;
• between-session messages or voice notes;
• feedback at the midpoint or end of the process;
• scheduling and administrative information.

Technical and website information

Depending on your cookie choices and the tools active on the website, technical information may include:

• IP address;
• browser and device information;
• pages visited;
• approximate location derived from technical information;
• referral source;
• website interaction and usage information;
• cookie or similar identifiers.

3. Why I Process Personal Data and My Legal Bases

I process personal data only where I have an appropriate legal basis.

Responding to inquiries and assessing whether a service is appropriate

I may use information you provide to:

• respond to your inquiry;
• understand what type of support you are seeking;
• assess whether an ARCHIPEL service is suitable;
• recommend another form of support or another ARCHIPEL service where appropriate;
• take steps requested by you before we begin working together.

The legal basis is generally Article 6(1)(b) GDPR — taking steps at your request before entering into a contractual relationship.

Where an inquiry is not related to a possible contractual relationship, processing may instead be based on my legitimate interest under Article 6(1)(f) GDPR in responding to communications and operating ARCHIPEL.

Providing coaching, education or other ARCHIPEL services

If we work together, I process relevant information to:

• prepare for sessions;
• provide the agreed service;
• maintain appropriate records;
• create and update your Personal Navigation Map;
• communicate between sessions where this forms part of the service;
• review progress;
• administer the client relationship.

The legal basis is Article 6(1)(b) GDPR — performance of our agreement.

Legal, financial and administrative obligations

Certain information may be processed or retained where necessary to comply with legal, tax, accounting or other applicable obligations.

The legal basis is Article 6(1)(c) GDPR.

Marketing and newsletters

If you separately choose to receive ARCHIPEL emails, updates or marketing communications, I process your contact information on the basis of your consent under Article 6(1)(a) GDPR.

You may withdraw that consent at any time, including by using an unsubscribe link where available.

Agreeing to marketing is not a condition of receiving coaching or another ARCHIPEL service.

Website analytics and non-essential cookies

Where consent is legally required, analytics and other non-essential cookies or similar technologies are used only after you have given consent.

The legal basis is Article 6(1)(a) GDPR.

You can change or withdraw your cookie choices through the cookie settings available on the ARCHIPEL website.

4. Sensitive and Health-Related Information

During an intake form or coaching conversation, you may choose to disclose information that qualifies as special-category personal data under Article 9 GDPR.

This may include information concerning:

• physical or mental health;
• therapy or medical support;
• disability;
• addiction;
• other health-related circumstances.

ARCHIPEL is not intended to collect detailed medical records or unnecessary health information.

Where I process special-category information that you voluntarily provide for the purpose of assessing whether ARCHIPEL is appropriate for you or providing the agreed coaching or educational process, I rely on your explicit consent under Article 9(2)(a) GDPR.

You may withdraw this consent at any time by contacting me at hello@archipelworld.com.

Withdrawal does not affect the lawfulness of processing that occurred before your consent was withdrawn.

If withdrawal means that I can no longer appropriately provide the service, it may be necessary to end or modify our work together.

5. Coaching Scope and Safety Information

ARCHIPEL coaching and education are not psychotherapy, psychiatric treatment, trauma treatment, medical treatment or crisis care.

Information provided during screening may therefore be used to determine whether the ARCHIPEL process is appropriate for your current situation.

For example, the intake may ask whether:

• you are currently in an acute crisis;
• you are concerned about your ability to keep yourself or another person safe;
• your primary issue may also require medical, mental-health, addiction, legal, crisis or relationship-safety support.

Answering such a question does not automatically exclude you from ARCHIPEL unless the nature of the situation falls outside the scope of the service.

6. Service Providers and Recipients of Personal Data

I do not sell your personal data.

I use a limited number of service providers to operate ARCHIPEL. They may process personal data only where necessary to provide their services.

Tally

I use Tally BV, Sint-Pietersnieuwstraat 11, 9000 Ghent, Belgium, to create and manage online forms, including intake, fit and feedback forms.

Tally acts as a data processor for information submitted through my forms.

Tally states that form data is encrypted in transit and at rest and stored in Europe.

Detailed coaching intake answers and health-related information are not intentionally transferred into marketing systems unless there is a specific need and an appropriate legal basis.

Website and hosting

The ARCHIPEL website is operated using WordPress.

Website hosting is provided by:

ALL-INKL.COM – Neue Medien Münnich
Owner: René Münnich
Hauptstraße 68
02742 Friedersdorf
Germany

ALL-INKL.COM operates its data centres in Dresden, Germany, and states that its customer data is stored exclusively on servers in Germany.

Mautic

I use a self-hosted installation of Mautic at:

https://mautic.archipelgame.ch

Mautic is hosted within my ALL-INKL.COM hosting environment in Germany.

Mautic may hold basic contact and communication information such as:

• name;
• email address;
• interests;
• tags;
• communication status;
• marketing preferences.

Detailed coaching intake answers, health-related information and private coaching notes are not intentionally stored in Mautic.

Email

My ARCHIPEL email accounts are hosted by ALL-INKL.COM – Neue Medien Münnich in Germany.

Ordinary email is not necessarily end-to-end encrypted. Please avoid sending highly sensitive information by ordinary email where this is not necessary.

Personal Navigation Maps and client documents

I use Proton Drive and Proton Docs, provided by Proton AG, Route de la Galaise 32, 1228 Plan-les-Ouates, Switzerland, to store and work with client documents, including Personal Navigation Maps.

Where a Personal Navigation Map is shared with you, you may be given permission to view and edit the relevant document during our work together.

Proton Drive and Proton Docs use end-to-end encryption. Client documents are kept separately and are not shared with other clients.

Private practitioner notes

I keep separate private practitioner notes for preparation, reflection and continuity of the coaching process.

These notes may include:

• observations;
• questions;
• working hypotheses;
• topics to revisit;
• reflections that are not part of your shared Personal Navigation Map.

Private practitioner notes are stored in a private, non-shared area of Proton Drive and are accessible only to me.

They are subject to the retention periods described in this Privacy Policy.

Video calls

Online coaching sessions may take place using Google Meet.

Google may process account, device, connection and technical information in connection with the use of Google Meet in accordance with its applicable privacy terms.

I do not routinely record coaching sessions.

If there were ever a reason to record a session, this would only happen after informing you beforehand and obtaining any consent required.

Payments

Payments may currently be made by bank transfer or through Revolut.

When you make a payment, Revolut and other financial institutions involved in the transaction may process information such as:

• your name;
• payment or account details;
• transaction amount;
• transaction date;
• transaction reference.

They process this information under their own legal obligations and privacy policies.

I retain only the payment and transaction information necessary for administering the service and meeting applicable accounting and tax obligations.

7. Google Analytics and Google Tag Manager

The ARCHIPEL website uses Google Tag Manager to manage website tags and Google Analytics to understand how visitors use the website and to improve its content and performance.

These services may process technical information such as device and browser information, website interactions, pages visited, approximate location information and technical identifiers.

Google processes information in accordance with its own privacy and data-protection terms.

The website’s analytics and cookie-consent configuration is currently being reviewed and may be updated as the website develops.

8. International Data Transfers

Some service providers may be located outside the European Economic Area or may process or make data accessible from countries outside the European Economic Area.

Where personal data is transferred internationally, appropriate legal transfer mechanisms are used where required, such as:

• an adequacy decision of the European Commission;
• Standard Contractual Clauses; or
• another lawful transfer mechanism under Chapter V GDPR.

Where applicable, further information about safeguards can be found in the relevant provider's privacy or data-processing documentation.

9. Data Retention

I do not retain personal information indefinitely.

Intake where we do not work together

If you complete an intake or fit form but do not become a client, I normally delete the detailed intake information within 3 months after the decision not to proceed.

Coaching and client records

If we work together, intake information, relevant coaching records, Personal Navigation Maps and associated client information are normally retained for 12 months after our final session.

After this period, they are deleted or anonymised unless there is a legitimate or legal reason to retain specific information for longer.

Private practitioner notes

Private practitioner notes are normally retained for 12 months after our final session and are then deleted unless retention is necessary because of an unresolved matter or legal obligation.

Financial and accounting records

Invoices, payments and other records required for tax or accounting purposes may be retained for the statutory retention period required by applicable law.

Mailing-list information

Marketing contact information is generally kept until you unsubscribe or otherwise withdraw your consent.

Limited information may be retained where necessary to document that you have opted out and prevent further marketing messages.

10. Form Logic and Screening

ARCHIPEL forms may use conditional logic.

For example, a form may:

• show additional questions depending on an answer;
• hide questions that are not relevant;
• end an intake early where the person indicates that they are under 18;
• end an intake early where an acute crisis or immediate safety concern is indicated.

This logic is used to avoid collecting unnecessary information and to communicate important scope or safety boundaries.

It does not make medical or psychological diagnoses.

If you believe an automated form route did not reflect your situation correctly, you may contact me at hello@archipelworld.com and ask me to review it.

11. People Under 18

The current individual ARCHIPEL coaching process described in the intake form is available only to people aged 18 or over.

The intake therefore asks applicants to confirm that they are at least 18 years old.

Other ARCHIPEL activities, such as school-based educational work, may be governed by separate arrangements and privacy information where appropriate.

12. Data Security

I take reasonable technical and organisational measures to protect personal data against:

• unauthorised access;
• loss;
• alteration;
• disclosure;
• misuse.

These measures include, where appropriate:

• password-protected accounts;
• limiting access to client information;
• keeping private practitioner notes separate from shared client documents;
• end-to-end encrypted storage for client documents and private notes;
• secure hosting;
• appropriate access controls;
• using service providers with relevant privacy and security measures.

No electronic system can guarantee absolute security.

13. Your Rights Under GDPR

Depending on the circumstances, you may have the following rights regarding your personal data.

Right of access

You can request information about whether I process your personal data and obtain a copy of the relevant data.

Right to rectification

You can ask me to correct inaccurate or incomplete personal data.

Right to erasure

You can request deletion of personal data where the legal requirements for erasure are met.

Right to restriction

You can ask me to restrict processing in certain circumstances.

Right to data portability

Where applicable, you can receive certain personal data you provided in a structured, commonly used and machine-readable format.

Right to object

Where processing is based on legitimate interests, you may have the right to object to that processing.

Right to withdraw consent

Where processing is based on consent, you can withdraw your consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

Right to lodge a complaint

You have the right to lodge a complaint with a competent data-protection supervisory authority, particularly in the EU or EEA country in which you live or work or where you believe an infringement occurred.

To exercise any of these rights, contact:

hello@archipelworld.com

I may need to verify your identity before fulfilling certain requests.

14. Information Required to Provide the Service

Some information requested in an intake form is required because I need it to:

• contact you;
• assess whether the service is appropriate;
• provide the agreed service;
• understand relevant scope or safety considerations;
• meet legal or administrative requirements.

Required fields are identified in the relevant form.

If you choose not to provide information necessary for these purposes, I may not be able to assess whether we can work together or provide the service.

Other questions are optional.

15. Marketing Is Separate From Coaching

Submitting an intake form or becoming an ARCHIPEL client does not automatically subscribe you to marketing communications.

Where marketing consent is requested, it will be requested separately.

You may unsubscribe from marketing emails at any time.

16. Changes to This Privacy Policy

I may update this Privacy Policy when ARCHIPEL services, technology providers, business processes or applicable requirements change.

The current version will be available at:

https://archipelworld.com/privacy-policy/

The effective date at the top of this policy will be updated when material changes are made.

17. Contact

For questions about this Privacy Policy, how your personal data is handled, or to exercise your data-protection rights, contact:

Verena Gittner
Email: hello@archipelworld.com
Website: https://archipelworld.com