• Referrers: Google, Linkedin, Twitter…
• Device Type: Phone, Desktop, Tablet…
• Browser: Chrome, Safari, Firefox…
• Countries: Spain, US, UK…

DO WE PROCESS COOKIES?

We do not use cookies on any of our sites.

DO WE USE YOUR EMAIL ADDRESS FOR ELECTRONIC COMMUNICATIONS?

Only if you have provided your email address as one of the means of communication to contact you regarding your request. We will only send you commercial communications to your email address if you have previously and expressly authorised us to use it for this purpose. You can opt out from these communications at any stage by expressing your desire to withdraw your consent.

DO WE COLLECT AND PROCESS THIRD-PARTY PERSONAL DATA?

No. As a general rule, we only collect process data sent by its owner. If you supply us with third-party data, before you do so, you must inform the third party and ask for express consent.

AND PERSONAL DATA ON MINORS?

We do not collect and process data about children under 14 years of age. Therefore, please refrain from supplying such data if you are not that age or from supplying data about third parties who are not that age. Empathy declines any responsibility for non-compliance with this provision.

2.1 PERSONAL DATA COLLECTED VIA CONTACT FORMS

By providing us with information in the contact form, you consent to us storing your details in order to contact you to:

• Answer your questions, applications or requests.
• Manage a requested service, or process your request.
• Provide information related to your request by electronic means.
• Provide commercial or event information by electronic means, provided that you have given express authorisation.
• Perform analysis and improvements on the website
• Provide details about our products and services or improve our commercial strategy.

2.2 PERSONAL DATA COLLECTED FOR USER MANAGEMENT

For what purposes do we process your personal data?

• Prepare quotations and follow up the commercial relationship by means of communications between both parties.
• Provide information related to your request by electronic means.
• Provide commercial or event information by electronic means, provided that you have given express authorisation.
• Manage administrative, communications and logistics services performed by the data controller.
• Perform billing and declaration of any relevant taxes.
• Make any transactions as appropriate.
• Control and manage debt recovery.

2.3 PERSONAL DATA COLLECTED VIA NEWSLETTER SUBSCRIPTION

You can subscribe to the Empathy Newsletter using an email address. We will store your email address in our database, and use it to send you emails periodically until you unsubscribe, or we stop sending emails. You can opt out of the newsletter subscription at any stage by clicking the unsubscribe link at the end of the email.

FOR WHAT PURPOSES DO WE PROCESS THIS DATA?

• Manage the requested service.
• Provide you with information related to your request electronically.
• Provide commercial or event information by electronic means, provided that you have given express authorisation.
• Perform analysis and improvements on the website.
• Provide details about our products and services, or improve our commercial strategy.

2.4 PERSONAL DATA COLLECTED VIA SOCIAL NETWORKS

You can communicate with Empathy via different social networks. We use these networks to connect with you and create a community of followers.

We process your personal data on the legal grounds that you have accepted a contractual relationship in the social network in question, and in accordance with its privacy policies.

You can view the privacy policies for the social networks on which we operate at the following links:

• Instagram   https://help.instagram.com/155833707900388
• Twitter   http://twitter.com/privacy
• Linkedin   http://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv
• Youtube   http://www.google.com/intl/es/policies/privacy/
• Medium   https://policy.medium.com/medium-privacy-policy-f03bf92035c9

2.5 PERSONAL DATA COLLECTED FOR RECRUITMENT PURPOSES

FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

• Organise recruitment processes for hiring employees.
• Organise appointments for job interviews
• Assess you as a candidate.

By sending us your CV, you accept and provide your unequivocal consent to the processing of your personal data for this purpose.

If you have given us your consent, we may pass personal data on to collaborating companies or similar with the sole purpose of helping you find a job.

By accepting the Privacy Policy, you give us your consent to pass your job application on to the entities that make up the group of companies in order for you to be included in their personnel recruitment processes.

2.6 PERSONAL DATA COLLECTED FOR SECURITY PURPOSES

Due to security reasons, we collect but we do not process your Public IP. This personal data is not collected, nor processed for any other purpose.

Where you must fill in a form and click “Submit” button to make a request, completing the form and submitting it will imply that you have been informed and have expressly given your consent to receive the newsletter, the content of the annexed clause, and/or have accepted our Privacy Policy.

All our forms show the asterisk symbol (*) when data is mandatory. If you do not complete these fields, or do not tick the “I accept…” checkbox for the Privacy Policy, you will not be allowed to send the form. The following formula is usually shown: “I am over 14 and I have read and accept the Privacy Policy.”

Your personal data is kept for as long as you have a relationship with us.

Once that relation is terminated, the personal data processed for each purpose will be kept for the legally established period, including the period during which a judge or a court may request it, the lapse period for legal actions being taken into account.

Processed data will be kept for as long as the legal deadlines referred to above do not expire, if there is a legal obligation to keep it, or in the case there is no legal deadline, until you request to have such data suppressed or you withdraw your consent.

We will keep all information and communications about your purchase or the provision of our service for as long as the guarantees over products or services are valid, so as to deal with possible claims.

In the case of CVs submitted as part of a recruitment process, any copies of CVs and other personal data provided as part of the recruitment process will be destroyed one year after the date of submission.

For personal data provided via social networks, the consultation or cancellation of your data is restricted as it forms part of a specific profile. We will only process your data as long as you allow us do so, by following or clicking on “Like”, “Continue” or similar buttons.

Any rectification of your data or restriction on information or publications via social networks must be made through the configuration of your profile or user on the social network itself.

In cases where the legal basis of the treatment is your consent, until you revoke it.

Rest assured, we have adopted an optimal level of protection for the Personal Data that we handle, and we have installed all the means and technical measures at our disposal in accordance with the technology available to avoid personal data loss, misuse, alteration, unauthorised access, and theft.

Who has access to your personal data and to whom is it disclosed?

Your data will not be transferred to third parties, unless there is a legal obligation to do so. Specifically, your data will be communicated to the Tax Authority and to banks and financial entities for collection for the service provided or product acquired and to those in charge of data processing, as necessary to perform the agreement.

In the event of purchase or payment, if you choose an application, platform, bank card, or another online service, your data will be transferred to that platform or will be processed in its environment, always with the utmost security.

All third party companies that we work with and who may have access to this data will have signed a service provision agreement that obliges them to uphold the same privacy standards as we do.

When US applications are used, any international transfer will be made with the guarantees established in the GDPR. This ensures that the US software company complies with European data protection policies on data privacy.

You have specific rights as a ‘data subject’ under Chapter III (Articles 12-25) of Regulation (EU) 2018/1725, in particular the right to access your personal data, and, to rectify them, in case your personal data are inaccurate or incomplete.

More specifically, you have the right to:

• Know whether we are processing your data or not.
• Access your personal data.
• Request rectification of your data if the information we hold is incorrect.
• Request suppression of your data if it is no longer necessary for the purposes for which it was collected or if consent is withdrawn.
• Request limited processing of your data, in certain situations, in which case we will keep it only in accordance with the regulations in force.
• Port your data, which will be supplied to you in a structured, commonly used or mechanical reading form. If you prefer, we can send it to the new manager you designate. This is valid only in certain cases.
• File a claim with the Spanish Data Protection Agency or competent control authority, if you feel that we have not treated you properly.
• Withdraw your consent for any processing for which you previously gave your consent, at any time.

If any of your data changes, we would be grateful if you would let us know, so we can keep it updated.

How can you exercise your rights?

You can exercise your rights by contacting dpo@empathy.co

We have specific forms for you to exercise your rights. You can request them by email or if you prefer you can use the forms prepared by the Spanish Data Protection Agency or third parties.

These forms must be electronically signed or accompanied with a photocopy of your ID document. If someone represents you, you must attach a copy of their ID document, or they must sign with their electronic signature.

Forms can be submitted in person or sent by letter or by email to the address of the Data Controller as indicated at the beginning of this Privacy Policy.

How long do we take to reply to the exercise of your rights?

In one month following the receipt of your request, and two months if the issue is very complex. If there is a delay, we will explain the reason for the delay to you within ONE month of receipt of the request.

This privacy policy is governed by Spanish law. The parties waive any other jurisdiction that may correspond to them, subject irrevocably and unconditionally to the exclusive jurisdiction of the Courts and Tribunals of Gijón to resolve any conflict or issue arising or related to this agreement.