top of page
Pink Poppy Flowers

​

Privacy Policy

ClearPath Partners
Effective Date: 01/01/2026

​

​​

  • 1. Introduction

  • ClearPath Partners (“we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy.

  • This Privacy Policy explains how we collect, use, store and protect personal information when you visit our website, book a call, or engage our services.

  • We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Spanish data protection laws.

  • 2. Data Controller

  • ClearPath Partners is operated by:

  • John Wineberg
    Self-employed professional registered in Spain
    Email: hello@clearpathpartners.net

  • For the purposes of data protection law, we act as the “data controller” of your personal information.

  • 3. What Personal Data We Collect

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

  • A. Information You Provide Directly

  • Name

  • Business name

  • Email address

  • Phone number

  • Website URL

  • Information submitted via contact or booking forms

  • B. Booking & Appointment Data

  • When you schedule a call via our booking system, we may collect:

  • Name

  • Email address

  • Availability

  • Any notes or information you provide during booking

  • C. Client Service Data

  • Where we provide services to clients, we may process:

  • Business contact details

  • Qualification criteria

  • Prospect information submitted through booking systems

  • D. Automatically Collected Data

  • When you visit our website, we may collect:

  • IP address

  • Browser type

  • Device information

  • Pages visited

  • This information may be collected via cookies or analytics tools.

  • 4. How We Use Your Information

  • We use personal data to:

  • Respond to enquiries

  • Schedule and manage discovery calls

  • Deliver our services

  • Communicate with clients and prospects

  • Improve our website and service performance

  • Comply with legal and regulatory obligations

  • We do not sell personal data to third parties.

  • 5. Legal Basis for Processing

  • Under GDPR, we rely on one or more of the following lawful bases:

  • Consent – where you submit a form or book a call

  • Contractual necessity – where processing is required to deliver services

  • Legitimate interests – to operate, improve and grow our business

  • Legal obligation – where required by law

  • 6. Data Sharing

  • We may share data with trusted third-party service providers necessary to operate our business, including:

  • Scheduling software providers

  • CRM systems

  • Email service providers

  • Website hosting providers

  • Analytics providers

  • These providers process data on our behalf and are required to implement appropriate security measures.

  • We do not sell or trade personal information.

  • 7. International Data Transfers

  • Some of our service providers may process data outside the European Economic Area (EEA).

  • Where this occurs, we ensure appropriate safeguards are in place in accordance with GDPR requirements.

  • 8. Data Retention

  • We retain personal data only for as long as necessary to:

  • Deliver our services

  • Maintain business and accounting records

  • Comply with legal obligations

  • When data is no longer required, it will be securely deleted or anonymised.

  • 9. Your Rights

  • Under GDPR, you have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request deletion of your data

  • Object to processing

  • Restrict processing

  • Withdraw consent where applicable

  • To exercise your rights, contact us at:
    hello@clearpathpartners.net

  • 10. Data Security

  • We implement reasonable technical and organisational measures to protect personal data from:

  • Unauthorised access

  • Loss

  • Misuse

  • Disclosure

  • However, no online system can be guaranteed to be completely secure.

  • 11. Cookies

  • Our website may use cookies and analytics tools to improve user experience and analyse website traffic.

  • You may control cookie preferences through your browser settings.

  • 12. Updates to This Policy

  • We may update this Privacy Policy from time to time. The updated version will be published on this page with a revised effective date.

Privacy Policy

bottom of page