PRIVACY POLICY

Last updated November 27, 2025

This Privacy Notice for Achat Cloud SAS (doing business as Atrivia Labs) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Visit our website at achieva30.com or any website of ours that links to this Privacy Notice
Download and use our mobile application (Achieva 30 - Build Habits), or any other application of ours that links to this Privacy Notice
Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://achieva30.com, or by contacting us.

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK FEATURES
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO THIS NOTICE?
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names
email addresses
mailing addresses
usernames
passwords
contact preferences
billing addresses
contact or authentication data
debit/credit card numbers
phone numbers
job titles

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's reminders, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

Information automatically collected

In Short: Some information such as your Internet Protocol (IP) address and/or browser and device characteristics is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and other technical information.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services. This may include your IP address, device information, browser type, and activity in the Services.
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.
Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.

Google API: Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts.
To deliver and facilitate delivery of services to the user.
To respond to user inquiries/offer support to users.
To send administrative information to you.
To fulfill and manage your orders.
To enable user-to-user communications.
To request feedback.
To send you marketing and promotional communications.
To deliver targeted advertising to you.
To protect our Services (including fraud monitoring).
To identify usage trends.
To determine the effectiveness of our marketing and promotional campaigns.
To save or protect an individual's vital interest.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

If you are located in the EU or UK:

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on:

Consent: We may process your information if you have given us permission.
Performance of a Contract: Necessary to fulfill our contractual obligations to you.
Legitimate Interests: Reasonably necessary to achieve our legitimate business interests (marketing, analyzing usage, preventing fraud, etc.).
Legal Obligations: Necessary for compliance with our legal obligations.
Vital Interests: Necessary to protect your vital interests or those of a third party.

If you are located in Canada:

We may process your information if you have given us specific permission (express consent) or where permission can be inferred (implied consent). In exceptional cases, we may be legally permitted to process your information without your consent, such as for fraud detection, investigations, or business transactions.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition.
Affiliates: We may share your information with our affiliates (including our parent company and any subsidiaries).
Business Partners: To offer you certain products, services, or promotions.
Other Users: When you share personal information or interact with public areas of the Services.
Offer Wall: Our application(s) may display a third-party hosted "offer wall." When you click on an offer wall, you will be brought to an external website. A unique identifier, such as your user ID, will be shared with the offer wall provider to prevent fraud and credit your account.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services.

The Services may link to third-party websites, online services, or mobile applications. We do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Specific information about how we use such technologies is set out in our Cookie Notice: https://achieva30.com/cookie-policy.

Google Analytics: We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout.

7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

We provide AI Products through third-party service providers ("AI Service Providers"), including Anthropic, Google Cloud AI, OpenAI and xAI. Your input, output, and personal information will be shared with and processed by these AI Service Providers.

Our AI Products are designed for functions such as AI applications, bots, insights, predictive analytics, research, translation, and text analysis.

8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

If you register using social media details (like Facebook or X), we receive profile information such as your name, email address, friends list, and profile picture. We recommend that you review their privacy notice to understand how they collect and share your personal information.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user's account.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and delete such data.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws, including the right to request access, rectification, erasure, restrict processing, and data portability.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature. As no uniform technology standard has been finalized, we do not currently respond to DNT browser signals.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have specific rights.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	YES
D. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	YES
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	YES
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics	YES
L. Sensitive personal Information		NO

California "Shine The Light" Law: California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes.

15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020.

Republic of South Africa

You can contact the Information Regulator (South Africa):
General enquiries: [email protected]
Complaints: [email protected] & [email protected]

16. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at [email protected], or contact us by post at:

Achat Cloud SAS
Data Protection Officer
235 rue Claude Francois
Achat Cloud
Montpellier 34080
France

If you are a resident in the European Economic Area or Switzerland, we have appointed Guillaume P to be our representative. You can contact them directly by email at [email protected], by visiting https://atrivialabs.com, or by post to:

235 rue Claude Francois
Achat Cloud
Montpellier 34080
France

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.

To request to review, update, or delete your personal information, please visit: https://achieva30.com.