PRIVACY POLICY

Last updated: 2 March 2026

1. Data Controller

For the purposes of Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”) and applicable Spanish data protection law (LOPDGDD), the data controller is: Emese Antal acting as atëmier, Pl. d'Urquinaona, 6, 8th Floor, Barcelona, 08010, Spain
Email: hello@atemier.com
We have not appointed a Data Protection Officer, as this is not required under applicable law. For privacy-related matters, please contact us at the email above.

2. Personal Data We Collect

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

Information You Provide Directly

Name
Email address
Business name (if applicable)
Billing details
Information
submitted via contact forms, information shared during consulting engagements

Transaction Data

Purchase history
Order details
Payment confirmations
Payment card information is processed securely by third-party payment providers and is not stored by us

Technical and Usage Data

IP address
Browser type and version
Device information
Pages visited
Time spent on pages
Referring URLs

Marketing Data

Newsletter subscription details
Email engagement data (opens and clicks)

Information Submitted Through Forms, Quizzes, or Questionnaires

We may collect personal and business-related information that you voluntarily provide when completing application forms, quizzes, waitlists, or brand questionnaires.

This may include:

  • Name and email address

  • Business information

  • Brand positioning details

  • Goals, challenges, and preferences

  • Responses to open-ended questions

3. Legal Bases for Processing

We process personal data under the following legal bases:

Contractual Necessity (Art. 6(1)(b) GDPR)

To provide consulting services
To deliver digital products
To manage payments and contractual communications

Consent (Art. 6(1)(a) GDPR)

To send marketing communicationsTo use non-essential cookiesTo activate Google AnalyticsYou may withdraw consent at any time.

Legitimate Interests (Art. 6(1)(f) GDPR)

To improve our website and services
To respond to inquiries
To prevent fraud and misuseTo maintain internal records
To analyse questionnaire responses to develop, refine, and improve products and services
To conduct internal market research
To assess suitability for consulting services

Legal Obligation (Art. 6(1)(c) GDPR)

To comply with Spanish tax and accounting requirements

4. How We Use Your Data

We use personal data to:

Deliver consulting services
Provide digital products
Communicate with clients and subscribers
Process payments
Improve website functionality and performance
Send marketing communications (where consent has been given)
Comply with legal obligations

Additional Purposes

We may also use information submitted through waitlists, quizzes, and questionnaires:

  • To assess client needs and determine suitability for our services

  • To develop, refine, and improve digital products and consulting offers

  • To conduct internal market research and better understand customer preferences

  • To personalise recommendations and communications

  • To analyse trends and improve overall service delivery

Where such processing is not directly necessary for the performance of a contract, it is based on our legitimate interest in improving and developing our services (Art. 6(1)(f) GDPR) or on your consent where required.

5. Service Providers

We do not sell personal data.We share personal data only with trusted service providers necessary to operate our business:

Squarespace (Website Hosting)

Our website is hosted by Squarespace. Squarespace may process technical data such as IP address, browser information, and usage data to operate and secure the website.

Google Analytics

We use Google Analytics to analyse website usage and improve performance. Google Analytics collects technical and interaction data such as IP address (anonymised where applicable), browser type, and pages visited.Google Analytics is activated only after you provide explicit consent through our cookie banner.

Kit (Email Marketing)

We use Kit (formerly ConvertKit) to manage newsletters and email communications. If you subscribe, your name, email address, and engagement data may be processed by Kit.

Typeform (Forms and Questionnaires)

We use Typeform to collect information submitted through waitlists, quizzes, questionnaires, and application forms.

When you complete a Typeform form, personal data such as your name, email address, business information, and questionnaire responses may be processed on our behalf.

Typeform acts as a data processor and processes personal data in accordance with applicable data protection laws. Typeform may use sub-processors located outside the European Economic Area (EEA). Where international transfers occur, appropriate safeguards such as Standard Contractual Clauses are implemented.

Professional Advisers

We may share necessary data with accountants, legal advisers, or authorities where required by law.All service providers process data under contractual agreements in compliance with GDPR.

6. International Data Transfers

Some service providers (including Squarespace, Google, and Kit) may process personal data outside the European Economic Area (EEA), including in the United States.Where personal data is transferred outside the EEA, appropriate safeguards are implemented in accordance with Article 46 GDPR, including: Standard Contractual Clauses approved by the European CommissionTransfers to countries subject to adequacy decisions, where applicableYou may request further information regarding these safeguards by contacting us.

7. Data Retention

We retain personal data only as long as necessary:
Client and transaction data: up to 6 years to comply with Spanish tax obligations
Contact inquiries: up to 12 months after last communication
Newsletter data: until you withdraw consent
Analytics data: according to Google Analytics retention settings
After the applicable retention period, data is securely deleted or anonymised.

8. Your Rights Under GDPR

If you are located in the European Union, you have the right to:
Access your personal data
Request rectification of inaccurate data
Request erasure of your data
Restrict processing
Object to processing
Data portability
Withdraw consent at any time
To exercise your rights, contact: hello@atemier.comY
ou also have the right to lodge a complaint with the Spanish Data Protection Authority: Agencia Española de Protección de Datos (AEPD) https://www.aepd.es

9. Cookies

We use essential cookies necessary for the proper operation of the website.Non-essential cookies, including analytics cookies (Google Analytics), are placed only after you provide explicit consent via our cookie banner.You may withdraw or modify your consent at any time through your cookie preferences settings.

10. Marketing Communications

Marketing emails are sent only if you have provided explicit consent. You may unsubscribe at any time by: Clicking the unsubscribe link in any email or contacting hello@atemier.com. Withdrawal of consent does not affect the lawfulness of processing before withdrawal.

11. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration. However, no method of electronic transmission or storage is completely secure.

12. Children’s Privacy

Our Services are not directed at individuals under 18 years of age. We do not knowingly collect personal data from minors. If such data is discovered, it will be deleted promptly.

13. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those websites.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised “Last updated” date. Continued use of the Services after changes are published constitutes acceptance of the updated Policy.