Archetify Privacy Policy

Last update: May 10th, 2024.


This Privacy Policy is an “agreement” between “Kyra Holding Group” (“Archetify”) and “you” (“User”), referencing to people that have voluntarily make their personality test and created groups to discover personality affinity and group dynamics via our official communication channels, subscribed to our newsletter and social media, signed up for a free trial of our Products and/or Services, purchased any of our Products and/or Services, and participated in different co-creation processes, research and user testings as a User, where personal data is collected, used and processed.


This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, access and delete your information. This Privacy Policy applies to all of the services offered by Archetify and its affiliates, excluding Special Learning Journeys where we officiate as processors and for them you will need to accept their specific privacy policy.


For everyone at Archetify protecting and respecting your privacy is important. This is why this Privacy Policy is written as clearly as possible, to give you all the information you need, in an understandable way, so you can make an informed decision on whether you would like to participate in our journeys or not.

Changes to this policy. We may change this Privacy Policy from time to time. We always indicate the date the last changes were published and we offer access to archived versions for your review. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

Executive Summary

  • Identity of Controller. The Controller is Kyra Holding Group – and the Data Controller Officer can be reached at

  • Data Purpose: Archetify conducts research on human behavior as well as impact measurements and performance analysis of our Products and/or Services. All data including User Content is anonymized before use for research purposes. This research looks at how different activities on Digital platforms or Journeys impact people’s behavior. Archetify may use Users Content and other data collected from You in accordance with the Agreement. Research and Content outcomes are key to helping Users make real change and progress in their lives.

  • Data Collection. Data collected will apply to one or more of the following legal basis: (i) consent, (ii) legitimate interest or (iii) contractual necessity, and it will be collected directly from you through your profiles, or other online or offline activities you accept to participate in. Only specific data is automatically transferred to us like name, email, residence country and age range. We do not knowingly collect information about children under 18 (or applicable laws) without parent consent.

  • Data Usage. Your Data may be subject to the following process activities: (i) storage and other processing necessary to provide, maintain and improve the Service; (ii) to provide technical support to the user; (iii) create a dashboard with relevant information about experience and users demographics; (iv) and disclosures as required by law or otherwise set forth in the Agreement.

  • Data retention. We will not retain sensitive personal data or information for longer than is required for the purposes for which such information may be lawfully used or is otherwise required under any law for the time being in force.

  • Data rights. You have the right to access and review personal data we hold about you, to rectify any personal data held about you that is inaccurate, delete of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us at

  • Data transfers. Your personal data may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”) or the UK or Brazil, for example, when one of our service providers uses servers or equipment based outside the EEA or UK or Brazil.

Processing of your personal data through our journeys

If you choose to become a User, you will be asked to provide your email address and your name, so we can identify you, process your payments and connect you to the service, as well as comply with potential requests to delete or access your data, offer you different opportunities to participate in our projects and access our new products and features. We won’t spam you or distribute your personal data to any third party for marketing purposes.

You can unsubscribe at any time and the personal data you’ve provided to become a User will be deleted and data that has not been processed to that point, will be deleted as well. 


However, all the data processed prior to that request and stored anonymously will be kept for research purposes.

In this case, all of the information kept will not be anonymized for contractual reasons so we are able to fulfill our obligations with you. When processing at scale, we will aggregate your information and no information provided will be made public in a way that it can be identifiable to you.

How do we collect data?

Most information we process is collected directly from you when you voluntarily do your personality test or join a group.


Other types of personal data may be obtained from third party companies and mainstream chat platforms we use to provide our services, like google, which may include your interaction with the Services.


This connection is necessary for the Services to function properly, and even though we might not store the data, we will always have the ability to retrieve the basic information stated before in accordance with your Privacy Settings on those third party platforms. Therefore Archetify shall not be liable for data missed use at this stage and will not hold responsibility in safeguarding issues since there are third party actors involved in data management, such as the mainstream chat platforms.

However, to deliver better confidentiality practices, Archetify will anonymize information in dashboards and reports to remove any traces of specific User information that can make it identifiable. Access is only granted on a need-to-know basis to those people whose roles require them to process your personal data and have access to identifiable personal information since access to these Users’ information is unavoidable when working within those platforms via their API and fanpages.

What type of data do we collect and to what purpose?

Archetify shall process Data, depending on the topic, only for the following purposes:

  • to perform, create, develop, operate, deliver, maintain and improve products and services provided or made by Archetify;

  • to elaborate aggregate reports in order to provide effective digital tools for behavioral change and to recommend new public policies to address topics around well-being; and

  • to communicate with you about new Services, products or special learning journeys

  • to comply with Law accomplishment or enforcements

When you use the Services, we may collect and process different personal data about you. The personal data we process, the basis of processing and the purposes of processing are detailed below. Sometimes, these activities are carried out by third parties (see “Who does Archetify share data with?” section below).

Unfortunately, due to the nature of our services, for the time being we can’t discriminate between data that can be collected and processed and some that can’t. So if you continue with the experience, all of this information will be processed.





Name and email address.

Contractual necessity/ Consent

This information will be processed when accessing our free trial through our official channels, when purchasing our Services and when volunteering to participate in Archetify activities. We use this information to send you invites to participate in different user activities like testing bots, interviewing with our team about certain topics, giving your opinion on focus groups or co-creating solutions to address pressing topics to help us gather feedback and make adjustments from a user-centered approach. We also use this isnformation to provide the Services and personalize the journey.

Until the participant unsubscribes which they can do at any time in their profile.

Conversation data: Information provided by you with your personality test.

Contractual necessity/ Consent/ Legitimate interest

This information enables us to analyse the topic we are addressing, to create reports that can boost public policies or to set the topic in other organizations’ agenda. It also helps us design Learning Journeys and Services that align to our target audience belief systems, needs, limitations and motivations to create change around certain topics and to raise awareness. We want to ignite conversations that make a positive impact on people’s lives. The analysis and visualization of this information publicly will always be kept anonymous and aggregated via a digital dashboard or other type of reports. Remember that if you subscribe as a Talker or purchase our Services, your personal information will not be stored anonymously to be able to comply with our Services, such as providing technical support, inviting you to special events, participating activities or testing, just to name a few. However, this information will be aggregated before processing in the reports.

After 1 year of inactivity.

Payment data: data associated with bank accounts and the payment method of their preference, as well as local fiscal information.

Consent/ Legitimate interest

We collect this information to enable us to process payments, renewals and issue invoices of the Products and Services purchased.

Information will be stored up to 3 months after the cancellation of the Product and/or Services purchased.

Satisfaction data: Bot performance metrics, ratings, responses to satisfaction surveys or state measures you claim regarding topics addressed during the interventions or other materials generated through your interactions with Archetify.

Consent/ Legitimate interest

We collect this information to enable us to measure our impact, understand the effectiveness of our interventions and improve our Services to you and other Talkers. This information is anonymized and aggregated to analyze results. But if you subscribed as a Talker, it will not be stored anonymously.

Until the Journey and/or Service you have interacted with is inactive or after 2 years of inactivity, whichever happens first.

Interaction with us in other platforms: Your data on Opinion Polls, Surveys, Votations on topics, Recordings and content gathered in one on one interviews and focus groups and/or performance and acceptability questionnaires about the Journeys.

Contractual necessity/ Consent/ Legitimate interest

Being part of our Talker community we will offer the possibility to participate in different activities related to our needs to have a user-centered approach in our creations. Contact information you provide may be used to reach you about these opportunities or other promotional, marketing and business purposes, as permitted by law. If you participate via forums, blogs, social media pages or any other platform that allows open & visible conversations, the content you provide on these channels will be considered “public” and is not subject to privacy protections.

Information will be saved up to 1 year after the end of the Journey, Products and Services.

How is your personal data stored and secure?

Archetify operates and uses appropriate technical and organizational security measures to protect your personal data. Data collections are stored respecting anonymity and confidentiality procedures in all available cases. Archetify makes a great effort to keep your conversations private and secure by taking measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.


You should take all security measures to safeguard your credentials, passwords and username that allow you to access and login and might be subject to security breaches. Unfortunately, we cannot guarantee the security of the personal data you provide since no system is 100% secure, so we will make our fullest efforts but Archetify will not be held liable for unintentional disclosure of your personal data.


Storage of personal data


We will keep your personal data for as long as it is necessary to fulfill the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. Sometimes in accordance with academic procedures, data used to develop a paper is required to be saved for a certain period of time. If that information differs from the information we provided when you started your conversation in one of our journeys, we will update our privacy policy to inform you.

Who does Archetify share your information with?

Archetify does not share your information with third parties, except as provided below:

  • Universities and other partners exclusively for analyzing, evaluating and providing effective tools for behavioral change or reporting on topics to encourage public policies reference to burning issues. The results of the study do not contain your personal data unless otherwise instructed by you. In all cases, unless expressed differently in the related privacy policy of the project you participate in, this information will be shared anonymously.

  • Service providers, such as IT providers involved in the development and maintenance of services provided and Cloud storage providers, such as Google, Vercel, Active Campaigns, Hubsport and Hotmart to name a few, to store the information you provide and visualize it in a fast and friendly way. They will be subject to contractual restrictions prohibiting them from using the personal data of our members for any other purpose,

  • Government, law enforcement officials or private parties as required by law. Archetify may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

  • Entity acquiring or merging with Archetify: in case of a merger or sale proposal of Archetify by another entity, we may share information while a due diligence exercise is being carried out or during the transitional process, provided that the information disclosed continues to be used to the purpose permitted and consented by you by this Privacy Policy by the new entity acquiring the information.

What are your rights?

There are several rights you may be entitled to according to the data protection legislation in your country, which may be the following:

  • The right of access: enables you to check what type of personal data we hold about you, what we do with that personal data and, if needed, to receive a copy of this personal data; this right also allows you to:


    • The right to rectification enables you to correct any inaccurate or incomplete personal data that we hold about you;

    • The right to erasure enables you to request that we erase personal data held about you in certain circumstances; and

    • The right to data portability enables you to receive your personal data in a structured, commonly used and machine readable format and to have that personal data transmitted to another data controller.

  • The right to be forgotten: states that data must be erased immediately after it is no longer needed for their original processing purpose or you have withdrawn consent


    The right to be informed: as we are detailing in this privacy policy, we are providing as much information as possible in a friendly way for you to understand what we do with your data, why we do it and for how long.

  • The right to lodge a complaint with supervisory authorities: we will try as hard as we can to comply with your requests, but if you are still unhappy please let us know using our contact info. However, you also have the right to complain to your local Data Protection Authority if you prefer.

 Note that we will require you to take steps to verify your identity in accordance with applicable law, and in cases where the data has already been processed, some rights might not be able to be applied to published documents. However, these studies will maintain anonymization.

Unfortunately, our journeys do not have the possibility of selecting which information is saved or not. It’s an all or nothing condition. So we may not comply with the right to restrict processing of your personal data. But you can opt out of the whole experience and request an erasure.

If you wish to exercise any of the above rights, please contact us (see “Identity of the controller of personal information” below).

Third parties’ compliance with law regulations

Since our Journeys and other Products and Services are hosted in third party mainstream chat platforms, you shall be bound by their Terms and Conditions, Privacy Policy, Cookies Policy and any updates on the fine print of that Platform given that you must have an account to be able to access the bot. Some of your rights must be explicitly executed by all parties.


Even if we eliminate your data from our databases, this does not mean that the conversation taking place within that platform will be erased on your end, unless you do it yourself.

However, please note that even if you eliminate it on your end, it does not mean that we cease to have access to it since we might have a copy on our own servers or information might have been transferred to one of our partners. So please, remember to send us your request in a timely manner to


#Children’s information


Our Platform, Products and Services are not targeted to children under 15 (or other age as required by local law), and we do not knowingly collect personal data from children under 15. If you learn that your child has provided us with personal data without your consent, you may contact us as set forth below. If we learn that we have collected any personal data in violation of applicable law, we will promptly take steps to delete such personal data and terminate the child’s account.

Transfer outside the European Economic area/UK and Brazil

Your personal data may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”) or the UK or Brazil, for example, when one of our service providers uses servers or equipment based outside the EEA or UK or Brazil.


We are also a 100% remote company which allows our team to work everywhere in the world, but we take organizational measures like encryption of databases and confidential mode on emails to safeguard your privacy, fundamental rights and freedom, and also exercise your rights.