Privacy Policy

Last revision: 3 March 2026

1. Introduction

Founderz Emprendimiento, S.L. (“Founderz”) in its capacity as Data Controller, aims to respect the privacy of its Users and protect the personal data that they may provide to Founderz.

In compliance with Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter, the “LOPDGDD”) and the General Data Protection Regulation of the European Union (hereinafter, the “GDPR”), the collection and processing of personal data on this Website shall be governed by the terms described below in this Privacy Policy.

2. What type of personal data do we collect?

Founderz will collect the following personal data from:

Users: First name, last name and email address and, if accepted by the User, voice and/or image. The User must ensure that the information provided is accurate and up to date.

Visitors and Users: IP address and other browsing characteristics derived from the use of cookies on the Website. More information is available in our Cookies Policy regarding the Website’s use of cookies.

3. Purposes of Processing, Legal Basis, and Data Retention

Founderz collects and processes the personal data indicated in accordance with the purposes, legal bases, and retention periods detailed below:

Purpose	Legal basis	Retention period
Browsing behavior analysis and statistics: Information collected through cookies and other similar tracking technologies that allow analysis of the User’s browsing behavior	Consent provided through the cookie banner when starting to browse. The User may withdraw consent by following the steps indicated in the Cookies Policy. Legitimate interest: Cookies categorized as technical are necessary for the functioning of the Website.	Retention periods depend on each specific cookie. For more information on retention periods for each type of cookie, Users may consult the Cookies Policy.
Managing User registration on the Website and enrollment in the Program	Performance of the Terms of Use governing this Website.	The indicated personal data will be retained for as long as the User maintains their status as a registered User, that is, until the User notifies Founderz of their intention to unsubscribe or Founderz proceeds to deregister the User.
Ensuring the development, compliance, and execution of the contractual relationship between Founderz and the User	Performance of the Terms of Use governing this Website.	The indicated personal data will be retained for as long as necessary to manage the contractual relationship, including potential complaints or claims associated with enrollment in the Program.
Providing Users with appropriate tools to enhance learning of Program content, such as Mi Fellow, videoconferences, Virtual Rooms, and/or assessment activities in which User data appears, specifically the User’s image and voice	User consent* (see Section 4).	In relation to Mi Fellow, the User’s voice and/or image are used exclusively in real time during interaction with Mi Fellow and are not stored, recorded, or retained on Founderz’s servers or those of its technology providers. In relation to other functionalities requiring the use of the User’s voice and/or image, such data will only be retained while the User maintains consent for such processing. The User may withdraw consent at any time. Where applicable, Founderz will block the data to comply with its legal obligations and, once the applicable retention periods have elapsed, will permanently delete the data.
Using recordings of activities carried out by Users during the Program for inclusion in promotional campaigns for Founderz programs via the Website and social media	User consent* (see Section 4).	User data will be retained for as long as the User maintains consent for such processing. The User may withdraw consent at any time. Where applicable, Founderz will block the data to comply with legal obligations and, once those periods have elapsed, permanently delete the data.
Recording telephone calls (and possible transcriptions) held with Users who contact Founderz through the Website contact form, for the purpose of preparing notes and internal evaluations of such calls	User consent* (see Section 4).	User data (voice and transcription) will be stored for as long as the User’s consent remains valid or, in any case, until the processing is no longer necessary to fulfill its purposes, without prejudice to subsequent blocking to comply with legal obligations, after which it will be permanently deleted.
Training artificial intelligence tools to improve Founderz’s services, thereby offering enhanced features to support User learning during the Program	Legitimate interest.	For as long as the User maintains an active account on the Platform and, once deactivated, Founderz will delete such data without prejudice to the anonymization referred to below.
Anonymization of data for the purpose of obtaining analytical information about User interactions with artificial intelligence tools	Legitimate interest.	Not applicable (anonymized data is not considered personal data).
Sending the User commercial communications related to the Program, as well as Founderz newsletters	For non-users, Founderz will process the User’s personal data based on their consent. Where there is a prior contractual relationship with the User, and Founderz has lawfully obtained the recipient’s contact details and uses them to send commercial communications about Founderz Services similar to those initially contracted, the legal basis for processing will be legitimate interest.	Data will be retained until the User withdraws consent or objects to receiving commercial communications. In the case of newsletters, the User may unsubscribe at any time by clicking the link included at the end of the update message received by email.
Managing inquiries and contact communications	Consent.	To address and respond to requests, comments, and suggestions, as well as to provide support to the User while browsing the Website and using the Services.
Managing enrollment in invitation-based Programs and communicating User progress/completion to the Inviting Organization	Performance of the Terms of Use and/or legitimate interest, as applicable.	For the duration of the account/Program and for the legally established limitation periods applicable to potential liabilities.

Asimismo, Founderz podrá tratar los datos de carácter personal del Usuario durante el periodo de tiempo en que pudieran surgir responsabilidades civiles, mercantiles, administrativas, penales o fiscales, en cumplimiento con la normativa vigente según corresponda. Una vez superados estos plazos, Founderz suprimirá estos datos de carácter personal.

4. Processing of Users’ Image and Voice*

a) Processing of Image and Voice through the Programs

In accordance with Founderz’s Terms and Conditions, during their participation in the Programs (for example, through Virtual Rooms, training and assessment activities, or live sessions), Users may share their image and/or voice with Founderz, as well as with other Program Users, provided that the User has given their express consent as described in this section.

At the end of the Program Modules, the User may be required to complete activities that may involve recording their image and/or voice. In such cases, these activities may be shared with other Program Users in order to enhance the learning experience and to enable the sharing and receiving of feedback, comments, or suggestions aimed at expanding the knowledge acquired during the Program.

These images may also be used by Founderz for promotional campaigns related to Founderz Programs, carried out through Founderz’s website and social media channels. Therefore, images of the User captured during participation in Program activities may be publicly shared with third parties who are interested in Founderz Programs and who view promotional videos. At any time, the User may withdraw their consent for this purpose through the “More Settings” panel under the “Privacy” section.

In all cases where the processing of the User’s image and/or voice is required, Founderz will provide tools with the camera and microphone disabled by default. When the User activates the microphone and/or camera, this will be considered a clear affirmative action providing express consent to process their voice and image for the purposes described in this section. Accordingly, such data will not be processed unless expressly enabled by the User.

In any event, although Founderz strongly recommends that the User share these activities with other Program participants, Founderz provides the option not to share such activities. This option can be enabled in the “More Settings” panel under the “Privacy” section.

If a User under the age of 14 is registered on the Platform, the parent or legal guardian must contact Founderz at hola@founderz.com to manage and sign the corresponding authorizations regarding the processing of the minor’s personal data by Founderz.

b) Processing of Voice through Founderz Telephone Calls

If Users contact Founderz through the form available on the Website, Founderz may contact them by telephone as part of the user support process. Such calls may be recorded and transcribed exclusively for internal purposes, such as note-taking, service quality improvement, and internal evaluation of user support processes.

Before starting any recording, Founderz will request the User’s express consent at the beginning of the call. If the User does not provide consent, the call will not be recorded. The User may also withdraw their consent at any time; however, this will not affect the lawfulness of processing carried out prior to the withdrawal.

c) Processing of Voice and/or Image through Mi Fellow

During the Program(s), the User may be supported by an artificial intelligence (AI)-based virtual assistant tool called “Mi Fellow.”

When accessing the “Mi Fellow” chat, the User may interact via written conversation or, if they wish, initiate a call. If the User chooses to initiate a call, they must expressly enable microphone access; if they initiate a video call, they must activate the camera. Both actions are entirely voluntary and will be considered express consent for the processing of their voice and/or image for the purposes described in this section. Accordingly, such data will only be processed if the User expressly enables these functionalities.

The processing of these personal data is strictly limited to providing the service in real time. The User’s voice and image are not stored, recorded, or retained on Founderz’s servers or those of its technology providers (including Azure OpenAI).

The User may deactivate audio and/or video access at any time from their own device, which will constitute the immediate withdrawal of consent, without affecting their participation in the Program.

5. Programs by Invitation from Organizations (Partners)

In certain Programs, the User may enroll by invitation from an organization (for example, a company or Partner) or through a link/code provided by that organization (hereinafter, the “Inviting Organization”).

(a) What does this modality involve?

In these Programs, in addition to managing access and providing the training service, Founderz may share with the Inviting Organization certain User data strictly necessary for the administration and monitoring of the training. The identity of the Inviting Organization will be displayed during the registration process and/or within the Program itself.

(b) What data is shared with the Inviting Organization?

Data shared (by default): first and last name, email address and/or participant identifier, enrollment status, and progress/completion of the Program (including completion date and certificate issuance status, where applicable).

Additional data (only if expressly enabled): for example, detailed results beyond “pass/fail,” time spent per module/lesson, qualitative feedback, or participation in community features. If such additional data sharing is enabled, the User will be clearly informed during the registration process or within the Program itself.

(c) Role of the Inviting Organization

The Inviting Organization will process the data it receives as an independent data controller for its own purposes of administering and monitoring the Program. Accordingly, Founderz does not control any subsequent processing carried out by the Inviting Organization in its capacity as controller (without prejudice to any contractual limitations agreed upon regarding the use of such data).

(d) Purpose of the disclosure

The disclosure of this data is intended to allow the Inviting Organization to:

(i) administer the Program and the participation of invited Users;

(ii) monitor attendance/progress and completion; and

(iii) manage certifications or internal training reporting, where applicable.

(e) Legal basis

The disclosure and related processing in connection with these Programs are based on:

(i) the performance of the User’s relationship with Founderz for the provision of the Program (Art. 6(1)(b) GDPR); and/or

(ii) the legitimate interest of Founderz and the Inviting Organization in managing and evaluating participation in the Program (Art. 6(1)(f) GDPR), as applicable.

(f) Data retention periods

Founderz will retain the data in accordance with the retention periods indicated in this Policy for account and Program management. The Inviting Organization will retain the disclosed data for as long as necessary for monitoring purposes and, in general, for a maximum period of twelve (12) months after completion of or withdrawal from the Program, unless a legal obligation or the need to retain data for claims management applies.

(g) User Rights

The User may exercise their rights with respect to Founderz as indicated in this Policy. Additionally, regarding data disclosed to and processed by the Inviting Organization as an independent controller, the User may also exercise their rights directly with that Organization through the channels it makes available.

6. Data Disclosure

Founderz informs you that, in order to fulfill the purposes described above, it will generally not transfer the User’s personal data to third parties. Notwithstanding the foregoing:
(i) Founderz may grant access to such personal data to technology service providers with whom it has entered into a data processing agreement;
(ii) in the case of Programs in which the User enrolls by invitation from an organization, as indicated in Section 5 (e.g., a company or Partner), Founderz may share certain participation data in the Program with that organization (for example, identifiers and progress/completion data) for the purpose of administering and monitoring the training.

The aforementioned providers may be located in jurisdictions that generally do not offer adequate safeguards regarding the processing of personal data. For all entities located outside the European Economic Area (EEA), Founderz has entered into agreements that include such safeguards, including the European Commission’s Standard Contractual Clauses.

Users may obtain more information about the technology service providers by requesting it from Founderz through the contact details provided in this Privacy Policy.

Users who have provided personal data for processing by Founderz may exercise their rights of access, rectification, erasure, restriction, and objection as established under the LOPDGDD by sending a communication to the address indicated in Section “6. Contact” below.

Likewise, Users have the right to lodge a complaint with the Spanish Data Protection Agency if they believe that the rights set out in this Privacy Policy have been violated or if they consider that the processing of their personal data infringes applicable regulations.

• Additionally, Founderz may disclose your data to:
• Other companies that are part of the Founderz group.
• Companies interested in purchasing or acquiring the company or part of its business and, consequently, may grant access to any national or international auditor to carry out their due diligence.
• Authorities to investigate suspected fraud, harassment, or other violations of any law, rule, regulation, or of the Website and/or Platform policies.

7. Users’ Rights

Link to Data Privacy Request Form

8. Contact

Responsible for Data Treatment: Founderz Emprendimiento, S.L.
CIF: B06944375
Address: Avenida Diagonal, 545 – 5. 08029, Barcelona.
Email: hola@founderz.com