Privacy Policy
Last updated: Aug 18, 2025
At Strategy Consulting Circle, S.L., we understand the importance of protecting your personal data. This Privacy Policy explains clearly and transparently how we process your information, who manages it, and for what purposes.
This Privacy Policy applies exclusively to personal data collected through the website joinmbb.com and does not apply to data collected by third parties, even if linked from this site.
Data controller
· Corporate Name: Strategy Consulting Circle, S.L.
· Tax ID (NIF/EIN): B22778955B22778955
· Registered Address: Calle Bravo Murillo 66, 4A, 28003, Madrid, Spain
· Contact Email: [email protected]
· Business Activity: Coaching and training services in consulting, interview preparation, and executive coaching.
Strategy Consulting Circle, S.L. guarantees compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the Spanish Data Protection Act (LOPDGDD), and all other applicable regulations.
1. Principles of Data Processing
We apply the principles required by the GDPR:
· Lawfulness, fairness, and transparency: We always request clear and informed consent when required.
· Data minimization: We only request the data strictly necessary.
· Storage limitation: We keep data only as long as necessary and in accordance with legal obligations.
· Integrity and confidentiality: We implement appropriate technical and organizational measures to protect your data.
2. Purpose, Legal Basis, and Processing
2.1 Purposes
Personal data is collected and processed for the following purposes:
· Delivering one-to-one and group coaching sessions.
· Managing enrollment in training programs.
· Providing access to digital educational content.
· Managing subscribers and registered users.
· Sending newsletters, updates, and service-related communications.
2.2 Legal Basis
The legal bases for processing your data are:
· Execution of a contract (Art. 6.1.b GDPR): to provide coaching services, manage enrollment, issue invoices, and deliver purchased content.
· Legal obligation (Art. 6.1.c GDPR): to comply with accounting, tax, and consumer regulations.
· Consent (Art. 6.1.a GDPR): to send newsletters, promotional communications, or to use testimonials. Consent is obtained via explicit opt-in and may be withdrawn at any time.
· Legitimate interest (Art. 6.1.f GDPR): to send communications to existing clients about similar services, always with the option to object.
2.3 Minors
Our services are intended exclusively for adults (18+). We do not knowingly process data of minors. If the PROVIDER becomes aware that data from a minor has been collected, the account will be terminated and the data erased immediately.
2.4 Categories of Data
We only process identifying data (e.g., name, email, IP address). We do not collect special categories of data.
2.5 Data Retention
Data is stored according to the following criteria:
· Client data: duration of the contractual relationship and at least 5 years thereafter for tax and legal purposes in Spain.
· Newsletter subscribers: until consent is withdrawn.
· Contact inquiries: up to 12 months after last communication.
2.6 Accuracy of Data
The CLIENT is responsible for the accuracy of the data provided. Strategy Consulting Circle, S.L. is not liable for errors or false information supplied by users.
3. International Transfers and Compliance
Your data may be stored in systems of Strategy Consulting Circle, S.L. or processed by third-party providers listed below. If data is transferred outside the European Economic Area, appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission will be implemented to ensure adequate protection.
Non-EU clients may have additional statutory rights under their local law (e.g., the California Consumer Privacy Act, “CCPA”). These rights will be respected where mandatory.
You may object at any time to the processing of your data for advertising purposes by writing to [email protected].
4. Security Measures
We apply appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, misuse, or alteration. The WEBSITE is protected with SSL encryption.
In case of a personal data breach, the PROVIDER will notify the Spanish Data Protection Agency (AEPD) within 72 hours and, when legally required, affected users.
5. User Rights
You may exercise your rights of:
· Access
· Rectification
· Erasure
· Restriction
· Objection
Requests must be sent to [email protected].
You also have the right to file a complaint with the Spanish Data Protection Agency (AEPD) if you believe your rights have been violated.
6. Third-Party Links
This site may contain links to third-party websites. We are not responsible for their privacy policies or their content.
7. Changes to this Policy
We reserve the right to amend this Privacy Policy, with at least 10 days’ prior notice before changes take effect.
8. Data Processors
We may engage third-party companies and individuals to facilitate the Program (“Data Processors”), to provide the Program on our behalf, to perform Program-related services, or to assist us in analyzing how our Program is used. These Data Processors will have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Some providers may operate servers outside the EU. In such cases, we adopt appropriate safeguards to ensure compliance with GDPR.
9. Data Collection Methods
· Subscription and contact forms
· Cookies (see our Cookie Policy)
· Purchase of coaching services and programs
· Analysis of browsing patterns for service improvement and personalized advertising
10. Intellectual Property
Personal data provided by users does not grant any right over the intellectual property of the WEBSITE. All content on joinmbb.com remains the exclusive property of Strategy Consulting Circle, S.L. or its licensors.
11. Withdrawal of Consent
You may withdraw your consent by writing to [email protected] or using the unsubscribe links included in our emails. Withdrawal will not have a retroactive effect and shall not affect processing necessary for the execution of a contract or compliance with legal obligations.
12. Testimonials and Image Rights
With separate, explicit consent, the CLIENT authorizes the PROVIDER to use testimonials (including name, image, and voice) for promotional purposes of its coaching services. This consent may be revoked at any time by written request to [email protected].
13. International Clients
While the relationship between the CLIENT and the PROVIDER is governed by Spanish law and jurisdiction, any mandatory consumer rights in the CLIENT’s country of residence remain unaffected.