Privacy policy.
Empthrive Ltd.
This policy is effective from 28 February 2025.
Data controller
Empthrive Ltd (hereinafter “Empthrive,” “we,” “our,” “us”) provides a platform that allows users (hereinafter “User,” “you,” “your”) to access consultation services focused on professional growth. Through the website and social media accounts, users may engage with our services, connect with others for support, and share experiences. Users may also have the option to follow others, view updates, and connect with peers via their social media accounts.
Empthrive is registered as a limited liability company (“LTD”) in Ireland under company registration number (CR) 781647. Our contact details are:
Address: Ground Floor, 71 Baggot Street Lower, Dublin 2, D02 P593, Ireland
Email: hello@empthrive.com
Contact form: https://www.empthrive.com/contact
This privacy policy (hereinafter “Privacy Policy”) applies to all use of our website; www.empthrive.com, (hereinafter “Web”). The Web forms our Services (hereinafter “Platform”).
We will process your personal data in compliance with European General Data Protection Regulation (Hereinafter “GDPR”). This Privacy Policy covers our processing of personal data collected when you register and access the Platform and use our Services.
Empthrive is the data controller of the personal data we collect from our Users in accordance with GDPR. This Privacy Policy describes how and when Empthrive collects, processes, discloses and shares your personal data when you use our Platform. If you have any questions or comments about this Privacy Policy, please contact us using one of the methods provided above..
Please note, that website visitors may use our Platform without signing up, in which case we will only collect data based on the visitors consent in accordance with the information provided by our Consent Management Platform.
Purpose and legal basis User Relationship Management
We process your personal data to manage our user relationship with you, including managing your account, providing you with access to our Platform and communicating with you in regard to updates, policies and updated terms and conditions.
As part of this activity, we process personal data, which includes:
Identification and contact information such as name, email address, and postal address, country of origin, username, and preferred language.
Information related to our relationship, including correspondence.
If you choose to register or sign in via a third-party application (Facebook, Apple and Google), you authorize us to access and collect certain account information, including your name, profile picture, and optionally, your email address and current city.
The processing of your personal data is performed on the legal basis of:
Your personal data is stored for as long as your account is active. Upon deletion of your profile, the identification and contact information will be stored for 6 months after the date of deletion. Reviews shared about our services will not be deleted, as they are an important part of evaluating and improving our services, which is essential for both the Platform and the Services we provide. Empthrive retains these reviews in line with our commitment to offering a credible and factually accurate service.
Disclosure of User Feedback for Interaction
We process and disclose your feedback or written testimonials regarding our consultation services to allow other users to engage with and learn from your experiences. As part of this process, we may handle personal data, including:
This disclosure is carried out on the legal basis of:
You may withdraw your consent at any time by emailing us at wecare@empthrive.com. This will anonymize your username, which would otherwise be displayed with your testimonial.
If a User requests the deletion of their testimonial, they may ask to have their username removed, ensuring the testimonial remains anonymous. However, the original text of the testimonial will be preserved. If the testimonial is factually accurate and the User does not provide compelling individual reasons for deletion, Empthrive will retain the testimonial in line with our commitment to providing a credible and factually accurate service. Therefore, Empthrive generally does not delete testimonials, as we do not want them to be subject to manipulation or external pressure – regardless of whether the feedback is positive or negative. The testimonial may have already been used in other contexts, and we aim to maintain the original text to preserve Empthrive’s credibility as a service provider.
Purchase of Services
To facilitate your purchase of consultation services or related offerings via the Platform, we process your personal data as necessary to fulfill our contractual obligations or those of any third-party service providers. This includes collecting the following personal data when you place an order:
Contact information such as first name, surname, email address, and phone number, to notify you of any order-related updates or changes
Billing information
Shipping information, if different from your billing information
Our legal basis for processing this personal data is:
Fulfilling Empthrive’s contractual obligations with you, or with third-party service providers, as outlined in GDPR Article 6(1)(b). This allows us to process data necessary for the performance of a contract or to take steps at your request before entering into a contract.
Your personal data will be stored for up to 2 years following the purchase to comply with relevant legal obligations, including warranty claims or consumer rights regulations under Irish and EU law. Any personal data processed for accounting or bookkeeping purposes will be retained in accordance with applicable legal requirements, typically for the current year plus 5 years, in compliance with relevant tax and accounting laws.
Analysis and Development
When visiting our Platform, cookies are collected in the same way as they apply elsewhere on the internet.
All information related to our use of cookies is provided by our Consent Management Platform. Our basis for processing is consent in accordance with the cookie regulation.
We also process your personal data to deliver, develop and improve the Platform. This includes enhancing our offerings, developing new features and updates, and creating personalized services. Additionally, we implement algorithms and machine learning for these purposes to optimize our business and Services.
This data is used for routine analysis, audits, development, identifying popular products, assessing the effectiveness of marketing campaigns, and planning operational activities. As part of this processing activity, we process ordinary personal data, which includes:
Our legal basis for processing personal data for these statistical and analytical purposes is:
Our legitimate interest in improving our platform and services cf. GDPR Article 6(1)(f), which allows processing necessary to pursue a legitimate interest. As a company, we have a legitimate interest in developing our Services. We balance these interests by employing the best practice anonymization techniques to protect your personal data to the greatest extent possible.
We store analyses in a depersonalized form.
Marketing and Advertising
We use your personal data to display personalized marketing messages and advertising on our Platform. As part of this processing activity, we process personal data, which includes:
Our legal basis for processing your personal data is:
Your freely given consent to receive marketing communications via email, provided when signing up to the Platform, in accordance with GDPR Article 6(1)(a), which allows processing based on consent, and in compliance with the Irish Consumer Protection Act 2007 and the EU ePrivacy Directive (Directive 2002/58/EC) as implemented in Irish law (SI 336/2011), which requires explicit opt-in for direct marketing communications.
You can withdraw your consent at any time by contacting us using the details provided above or by following the opt-out instructions in our marketing communications.
Children's privacy
The Platform is intended for use by individuals aged 18 or over. If we become aware that a person under this age has provided us with personal data, we will take steps to delete the account and any associated personal information in accordance with applicable data protection laws.
Sharing of data
The protection of our users’ personal data is essential to our business. To operate our services securely and efficiently, we work with carefully selected, security-compliant data processors to store and process personal data.
When engaging data processors, we ensure that appropriate data processing agreements are in place in accordance with applicable data protection laws. These agreements define the scope, duration, nature, and purpose of processing, the types of personal data involved, and the rights and obligations of all parties.
Your personal data is only shared with third-party processors when necessary to provide and operate specific services, such as sending email communications.
We do not sell, distribute, or lease your personal data to third parties unless required by law or with your explicit consent.
For payments, we use third-party payment providers, who act as independent data controllers. Your personal data will be processed in accordance with their respective privacy policies.
Transfer of data to third countries
In connection with IT operations, including hosting, development, and support, we may, in certain cases, transfer personal data to companies located outside the EU/EEA. When Empthrive transfers your personal data to third parties in countries that do not provide an adequate level of data protection, we ensure that appropriate safeguards are in place to protect your rights, including:
Transfers to countries that the European Commission has deemed to have an adequate level of data protection;
The use of standard contractual clauses (SCCs) approved by the European Commission; and
The implementation of additional measures where necessary, in accordance with GDPR requirements.
If you would like further information about how we transfer personal data outside the EU/EEA, you can contact us at hello@empthrive.com.
Protecting our users’ personal data is essential to our business. To operate our services securely and efficiently, we work with carefully selected, security-compliant data processors to store and process personal data in accordance with Irish and EU data protection laws.
Where we engage data processors, we ensure that appropriate data processing agreements are in place, outlining:
The purpose, nature, and duration of processing;
The types of personal data involved; and
The rights and obligations of both parties in compliance with GDPR.
Your personal data is only shared with third-party processors when necessary for providing and maintaining our services, such as processing email communications.
We do not sell, distribute, or lease your personal data to third parties unless required by law or with your explicit consent.
For payments, we use third-party payment providers who act as independent data controllers. Your personal data is processed in line with their respective privacy policies.
Security
In order to prevent unauthorized access or disclosure, we have put in place technical and organizational procedures to safeguard the information we collect.
User accounts including personal data are protected by a password for your privacy and security. You should ensure no unauthorized access to your account and personal data by choosing and protecting your password appropriately, and by signing off when finishing accessing your account. When signing in via a third-party application provider your password is solely managed by such third-party.
We do our best to ensure that User accounts are kept private. However, various instances such as unauthorized entry/use, hardware or software failure, and other factors, may compromise the security of the personal data.
This Privacy Policy only governs information collected on the Platform.
Your rights as a User
As provided by the GDPR, you have the right to:
Right of Access – the right to be informed of and request access to the Personal Data we process about you;
Right to Rectification – the right to request that we amend or update your Personal Data where it is inaccurate or incomplete;
Right to Rectification – the right to request that we amend or update your Personal Data where it is inaccurate or incomplete;
Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your Personal Data;
Right to Object – the right, at any time, to object to us processing your Personal Data on grounds relating to your particular situation; the right to object to your Personal Data being processed for direct marketing purposes;
Right to Data Portability – the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party's service; and
Right not to be subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
When we receive a request to access, rectify, erase or port data, we may ask you for additional information in order to confirm your identity and ensure data security. You can send a request at the contact details presented in the section “Data Controller”
You have the right to complain regarding the processing of personal data concerning you to the supervisory authority, which in Ireland is the Data Protection Commission (DPC):
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2, D02 RD28
Phone no.: +353 (01) 765 01 00
https://www.dataprotection.ie/en/contact/how-contact-us
Ireland and EU Privacy Rights Addendum
This Ireland and EU Privacy Rights Addendum (“Addendum”) supplements the Privacy Policy of Empthrive Ltd and applies to individuals within the European Economic Area (EEA), including Ireland, in accordance with the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018. Any terms defined in the GDPR have the same meaning when used in this Addendum.
Your Rights Under GDPR and Irish Data Protection Law
As an individual within the European Economic Area (EEA), including Ireland, you have the following rights regarding your personal data under the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018:
Right to Access:
You have the right to request:
Confirmation of whether we process your personal data
Access to the personal data we hold about you
Information about how we process your personal data, including the purposes of processing, categories of data processed, and recipients of your data
Right to Rectification:
You have the right to request that we correct inaccurate or incomplete personal data about you.
Right to Erasure ("Right to be Forgotten"):
You have the right to request that we delete your personal data, subject to certain exceptions, such as compliance with legal obligations.
Right to Restriction of Processing:
You have the right to request that we limit how we process your personal data in certain circumstances, such as when you contest its accuracy or object to processing.
Right to Data Portability:
You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible.
Right to Object:
You have the right to object to the processing of your personal data where it is based on our legitimate interests or for direct marketing purposes.
Right to Withdraw Consent:
Where we rely on your consent for processing, you have the right to withdraw it at any time.
Right to Lodge a Complaint:
You have the right to lodge a complaint with the Data Protection Commission (DPC) in Ireland if you believe your data protection rights have been violated. You can contact the DPC at www.dataprotection.ie.
Empthrive is committed to upholding these rights. To exercise any of your rights, you can contact us using the details provided in this Privacy Policy.
Submitting Requests
To exercise your rights, you may contact us by:
Do Not Sell or Share My Personal Information
Empthrive does not sell your personal information. However, if we share personal information for targeted advertising purposes, you can opt-out by contacting us using the methods outlined above.
Categories of Personal Information We Collect
The categories of personal information we collect and use include:
Identifiers (e.g., name, email address, IP address).
Commercial Information (e.g., purchase history).
Internet or Other Electronic Network Activity (e.g., browsing behavior on our website or app).
Geolocation Data (e.g., precise location, with your consent).
Retention of Personal Information
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, accounting, or reporting obligations. For more details, see the “Data Retention” section of our Privacy Policy.
We may update this section from time to time. When we do, we will notify you in accordance with applicable Irish and EU data protection laws.
