This notice covers two things: this website, and Mind by Design, the self-reflection tool developed by AM Learning. It is written in plain language, because you deserve to understand how your information is handled without needing a law degree.
Data controller: TrueDigital Ltd, trading as AM Learning, operated by Áine Maher. Registered in Ireland, company number 679018.
Contact: privacy@am-learning.com
This website
am-learning.com sets no tracking cookies and runs no analytics that process personal data. No Google Analytics, no Facebook Pixel, no retargeting scripts. If you email us or use a contact link, your message and email address are used only to reply to you.
Mind by Design
Mind by Design is a self-reflection exploration, not a clinical or diagnostic tool. It does not identify mental health conditions or specific neurological traits. It gives you a picture of your current thinking patterns based on your answers, and that picture belongs to you.
What is collected
Your answers
Your responses to the exploration questions are used to calculate your profile. Beyond that, individual answers are never published, shared or looked at in isolation; they are only ever analysed as grouped, anonymised data across many participants. You can ask for your answers to be deleted at any time.
Your email address (optional)
At the end of the Quick Snapshot you can choose to share your email so your results can be sent to you and so a future retake can show how your patterns have shifted. If you skip this step, your results appear on screen and no email is collected.
Career context
You are asked a brief question about your current working context, for example whether you manage a team, are self-employed, or are between roles. This helps AM Learning understand the range of people using the tool. It does not affect your results, is stored alongside your profile data, and is never shared with anyone.
Marketing preference (optional, separate)
If you provide an email, you can separately choose to receive occasional insights from AM Learning. The box is never pre-ticked, and declining has no effect on your results. You can unsubscribe at any time.
Nothing else is collected. Mind by Design does not ask for your name, employer, or any other identifying information.
Why, and on what basis
Your data is processed on the basis of your consent, given on the welcome screen before any questions are asked. It is used to generate your profile, deliver your results if you request them by email, and send occasional insights if, and only if, you opt in. You can withdraw consent at any time, as easily as you gave it.
How long it is kept
- Your answers: kept only for as long as they are needed to generate results and improve the exploration, analysed only as grouped, anonymised data, and deleted on request at any time.
- Profile scores and email (if provided): kept so you can retake and compare, until you ask for deletion.
- Marketing list: until you unsubscribe.
Where it is stored
All data is stored within the EU/EEA, encrypted in transit and at rest. Access to identifiable data is restricted to Áine Maher and authorised data processors. No personal data is used in analytics or logging systems.
Third party services
Mind by Design uses a small number of tools to operate. Each is a data processor under GDPR with a data processing agreement in place through its service terms:
- Typeform hosts the exploration and stores responses (EU data residency).
- Substack handles the Mind by Design newsletter, only if you subscribe.
- Gumroad processes payment and delivery, only if you purchase a Mind by Design product. Gumroad handles your payment details directly; AM Learning never sees them.
How grouped data is used
When answers are analysed, they are grouped and anonymised into an aggregate dataset from which no individual can be identified. This is no longer personal data under GDPR. It may be used to improve Mind by Design, to publish insights and thought leadership drawing on aggregate patterns, and to inform new tools and programmes. These uses draw on patterns across many people, never on data that could identify one person.
Use within organisations
When Mind by Design is used inside an organisation, for example as part of a team development programme, individual results are never shared with the employer unless the individual explicitly and separately consents. Team level reporting uses only aggregate data with a minimum group size of five. This is a non-negotiable principle.
Your rights
Under GDPR you can, at any time, by emailing privacy@am-learning.com:
- See your data: request a copy of everything held about you, provided within 30 days.
- Delete your data: your email, profile scores and preferences are permanently deleted. Anonymised aggregate data, which cannot identify you, is retained.
- Correct your data: update your email address or fix anything inaccurate.
- Export your data: receive your profile data in a machine readable format.
- Withdraw consent: via the unsubscribe link in any email, or by getting in touch. Withdrawal does not affect the lawfulness of processing that happened before it.
If you are not satisfied with how a concern is handled, you have the right to lodge a complaint with the Data Protection Commission (Ireland) at dataprotection.ie.
A note on wellbeing
Some Mind by Design questions ask you to reflect on how you respond under pressure, how you talk to yourself, and how you manage difficult emotions. If anything comes up that feels difficult, you are welcome to pause or stop at any time. If you are experiencing persistent distress, the tool is not a substitute for professional support; please speak to someone you trust or contact your GP.
Changes to this notice
If Mind by Design grows new features that change how data is handled, this notice will be updated before they go live, and the date at the top will change. Significant changes will be flagged to anyone on the email list.
Questions
Anything unclear, or anything you would like to exercise? Email privacy@am-learning.com.