Last Updated: 8/8/25

This Privacy Policy explains how HWDR The Closing School Limited (“we,” “our,” or “us”), operating as The Empath Closing School, collects, uses, stores, and protects your personal data when you visit our website, apply for or use our services, or interact with us in any way.

We are committed to protecting your privacy and handling your data in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Cypriot data protection laws.

1. Who We Are

Company Name: HWDR The Closing School Limited
Registered Address: Sparta, 4, , SANTHEMIS, Floor 2, Flat/Office 201, 4002, Limassol, Cyprus
Email Address: hello@theempathclosingschool.com
Company Registration Number: HE445215

EU VAT Registration Number: CY60014928W

2. What Personal Data We Collect

We may collect and process the following categories of personal data:

Identity Data: Full name, date of birth, nationality

Contact Data: Email address, phone number, postal address

Professional Data: CV/resume details, experience, skills, LinkedIn profile

Usage Data: Pages visited, interaction with content, browser type

Technical Data: IP address, device information, cookies

Call Data: Audio and video recordings of demo or consultation calls (see section 7)

Payment Data: (If applicable) Billing details, transaction info, payment details like card details through Stripe payment processor

3. How We Collect Your Data

We collect data through:

Web forms and applications you complete on our site

Booked calls via third-party scheduling platforms (e.g., Calendly, GoHighLevel)

Interaction with our customer support

Participation in trainings, demos, or workshops

Cookies and analytics tools (see Section 9)

4. Legal Basis for Processing

We process your personal data under the following legal bases:

Consent – when you give explicit permission (e.g., subscribing to our newsletter)

Contractual necessity – to fulfil services you request (e.g., online communities and training access)

Legitimate interests – to operate and improve our business, provide support, and evaluate service usage

Legal obligation – where required by applicable law

5. How We Use Your Data

We use your data to:

Provide training and career support services

Schedule and conduct demo calls and consultations

Assess program eligibility and suitability

Communicate with you regarding your application or contract

Send updates, educational content, or marketing (with your consent)

Improve our website and user experience

Fulfil legal and regulatory obligations

6. How We Share Your Data

We do not sell your personal data. We may share your data with:

Contracted team members and trainers involved in program delivery

Reputable third-party platforms for CRM, scheduling, communication, and storage (e.g., GoHighLevel)

Partner companies or recruiters (only with your permission)

Legal authorities where required by law

All third-party providers are required to comply with GDPR and data security standards.

7. Call Recording Policy

Calls (audio and/or video) may be recorded for the following purposes:

Training and quality assurance

Skill assessment and feedback

Internal documentation and performance review

By booking and participating in calls with us, you consent to the recording of these sessions. You will be informed at the time of booking or prior to the call if recording will occur.

Recordings are stored securely and only accessible to authorised personnel. You may request access to or deletion of recordings that include your personal data, subject to our legal obligations.

8. International Data Transfers

Your data may be processed or stored outside the European Economic Area (EEA) in jurisdictions that do not offer the same level of data protection. In such cases, we implement appropriate safeguards such as:

Standard Contractual Clauses (SCCs) approved by the EU

Data Processing Agreements with service providers

Secure cloud infrastructure compliant with GDPR (e.g., [Insert tool name])

9. Cookies & Tracking

We use cookies and similar technologies for analytics, functionality, and marketing purposes. By using our site, you consent to our use of cookies. You can control cookie preferences through your browser settings.

10. Your Rights Under GDPR

You have the right to:

Access the personal data we hold about you

Correct inaccurate or incomplete data

Request deletion of your data ("right to be forgotten")

Restrict or object to certain types of processing

Withdraw consent at any time (without affecting prior lawful processing)

File a complaint with a supervisory authority (e.g., Office of the Commissioner for Personal Data Protection in Cyprus)

To exercise any of your rights, contact us at: hello@theempathclosingschool.com

11. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy or to comply with legal obligations. This may include:

Up to 2 years after last contact for sales or marketing purposes

Call recordings retained for 2 years unless otherwise requested

Contract or financial information retained in accordance with tax or accounting laws

12. Changes to This Policy

We may update this Privacy Policy occasionally. Changes will be posted on this page with an updated effective date. Continued use of our services constitutes acceptance of the updated terms.

13. Contact Us

For questions, concerns, or to exercise your rights, contact us at:

Email: hello@theempathclosingschool.com
Address: Sparta, 4, , SANTHEMIS, Floor 2, Flat/Office 201, 4002, Limassol, Cyprus