Privacy Policy
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, LinkedIn profile, work history, skills
- Account Data: Login credentials, preferences, platform activity
- Technical Data: IP address, browser type, device information, cookies
- Financial Data: Payment information (processed securely via third-party providers)
- Communication Data: Emails, call recordings, chat messages, support tickets
3. How We Collect Data
We collect data through:
- Direct input (e.g., account registration, form submissions, emails)
- Automated collection (e.g., cookies, analytics, pixel tracking)
- Third-party integrations (e.g., CRM platforms, payment processors)
4. Why We Collect and Use Your Data
We process your data for the following lawful purposes:
- To provide and manage our services (contract performance)
- To communicate with you regarding your account or applications
- To match candidates with relevant opportunities
- To improve our training content, tools, and platform experience
- To send you updates, marketing, or promotional content (with consent)
- To comply with legal or regulatory obligations
5. Data Retention
We retain personal data only as long as necessary to fulfil the purposes described above, or as required by law. If you request deletion, we will process your request promptly unless we are legally required to retain certain data.
6. Data Sharing
We may share your personal data with:
- 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). Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) or data processing agreements with GDPR-compliant providers.
9. Your Rights Under GDPR
You have the following rights regarding your personal data:
- Access — Request a copy of the data we hold about you
- Rectification — Request correction of inaccurate or incomplete data
- Erasure — Request deletion of your personal data ("right to be forgotten")
- Restriction — Request that we limit processing of your data
- Portability — Request your data in a structured, commonly used format
- Objection — Object to processing based on legitimate interest or direct marketing
- Withdraw Consent — Where processing is based on consent, you can withdraw at any time
To exercise any of these rights, please contact us at: hello@theempathclosingschool.com
10. Cookies & Tracking Technologies
Our Site uses cookies and similar technologies to enhance your experience. These may include:
- Essential cookies (required for Site functionality)
- Analytical cookies (e.g., Google Analytics)
- Marketing cookies (e.g., Meta Pixel, conversion tracking)
You can manage or disable cookies via your browser settings. For details, see our Cookie Policy (if applicable).
11. Security
We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, or destruction. This includes encryption, secure hosting, and access controls.
12. Children's Privacy
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a child has submitted personal data to us, please contact us immediately.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be reflected by updating the "Last Updated" date at the top. We encourage you to review this page periodically.
14. Contact Us
If you have questions or concerns about your personal data or this policy, contact us at:
The Empath Closing School
HWDR The Closing School Limited
Sparta, 4, SANTHEMIS, Floor 2, Flat/Office 201, 4002, Limassol, Cyprus
Email: hello@theempathclosingschool.com