Basic Information on Data Protection

Controller of treatment: COUNTERGROGWISE S.L.
Purposes of treatment:

  • Informative website.
  • Management of selection processes.

Legitimacy of treatment

  • Express consent of the person concerned.
  • Execution of a contract or implementation of pre-contractual measures.
  • Legitimate interest in data processing.
  • Compliance with legal obligations.

Data retention

  • The data will be kept for the time strictly necessary to fulfil the purposes collected; provided that the person concerned does not revoke his/her consent, as well as for the fulfilment of legal obligations.

Target group

  • Personal data collected through the Website will not be transferred to third parties. Without prejudice to those third parties that provide services to  COUNTERGROGWISE S.L. with the purpose of managing the provision of services, the contractual and/or pre-contractual relationship with the interested parties or processing requests made by them.

Rights of the interested parties

  • Access, rectify and delete data, as well as other rights, as explained in the additional information.

Additional information

  • Additional and detailed information on Data Protection can be found in the attached clauses below.


In compliance with the provisions of Articles 13 and 14 of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as ‘PGN’), and articles 6 and 11 of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter, “LOPDGDD”), which regulates the right to information in the collection of data, we inform you of the following.

Who is responsible for processing your personal data?

The personal data that you have provided to us through the website, our social networks or through any other communications maintained with you shall be subject to the Registry of Processing Activities for which COUNTERGROGWISE S.L is responsible, with a postal address at C/Aribau 230-240, 6th floor, Barcelona (08008) and an e-mail address of


  • Social network profiles:
    • Twitter
    • LinkedIn

What is your presence in social networks?

COUNTERGROGWISE S.L. has the following profiles in the main social networks of the Internet (Twitter and LinkedIn)

It is recognized as responsible for processing the data of its users, followers, or persons who make comments through them. Likewise, in compliance with the Law on Information Society Services and Electronic Commerce, COUNTERGROGWISE S.L. is exonerated from any type of responsibility derived from comments made by users and followers on its social networks.

COUNTERGROGWISE S.L. may use the profiles described above to inform its users about topics it considers of interest.

What personal data do we collect?

The personal data that the user may provide:

  • First and last name.
  • E-mail address.
  • CV data.
  • Any other information or data you decide to share with us.
  • Children Policy

COUNTERGROGWISE S.L.’s website is for users age 13 and over and we do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us at

Why and for what purpose do we process your data?

Depending on the purposes we will need to treat some data or others, which in general will be, according to the case, the following:

  • The website is fully informative about the services offered by COUNTERGROGWISE S.L.
  • The collection and automated processing of data through the website will be done via email, to collect all the data necessary to study the possibility to work with us.
  • Deal with questions, complaints, claims and suggestions submitted to us.
  • Make internal analysis to improve our service according to our users’ preferences.
  • Comply with all legal, regulatory and administrative obligations we are subject to.

We inform you that the personal data obtained as a result of the registration as a candidate in any job opportunity published in the website will be part of the Registry of Processing Activities and Operations (RAT), which will be periodically updated in compliance with the provisions of the RGPD, given that all relevant security measures have been adopted in this regard.

The user is informed of the possibility of withdrawing consent in the event that it has been given for a specific purpose, without this affecting the lawfulness of processing based on consent prior to its withdrawal.

What is the legitimacy for the processing of your data?

The processing of your data can be based on the following legal bases:

  • Express consent by users when contacting us by electronic means through any of the channels provided for this purpose.
  • Necessary for the execution of a contract with COUNTERGROGWISE S.L.. or for the application of pre-contractual measures.
  • Compliance with legal obligations for fraud prevention, communication with Public Authorities and third-party claims.

How long do we keep your data?

The processing of data for the purposes described will be maintained for the time necessary to comply with the purpose of their collection, as well as to comply with legal obligations arising from the processing of data. Without prejudice to the fact that the conservation is necessary for the formulation, exercise or defence of potential claims and/or whenever permitted by the applicable legislation.

COUNTERGROGWISE S.L. undertakes to cease the processing of personal data when the conservation period has expired, as well as to block them properly in our databases.

To which recipients are your data communicated?

In general, COUNTERGROGWISE S.L, will not transfer the personal data to third parties, except in those situations in which the data can be transferred to other collaborators that provide services to COUNTERGROGWISE S.L with the purpose of managing the provision of services, the contractual and/or pre-contractual relationship with the interested parties or processing requests made by them.

COUNTERGROGWISE S.L tries to guarantee the security of personal data when it is sent outside the company and ensures that third party service providers respect confidentiality and have adequate measures to protect personal data. These third parties have the obligation to guarantee that the information is treated in compliance with data privacy regulations. In some cases, the law may require that personal data be disclosed to public bodies or other parties, but only what is strictly necessary to meet such legal obligations will be disclosed.

Where is your data stored?

Your data is principally stored in our servers, in the European Economic Area. However, we use some non EEA third-party services in order to provide our services. These companies are part of the USA-EU Privacy Shield.

For more information, please, visit:

Furthermore, we will require all third parties to guarantee the confidentiality and security of your personal data and to process them in accordance with the data protection law.

What rights do you have and how can you exercise them?

You may address your communications and exercise your rights by sending a written communication to the following e-mail address:

By virtue of what is established in the regulations on data protection you can request:

  • Right of access: you can ask for information about the personal data we have about you.
  • Right of rectification: you can communicate any change in your personal data.
  • Right to delete and forget: you can request the deletion of your personal data after they have been blocked.
  • Right of limitation to the treatment: it supposes the restriction of the treatment of the personal data.
  • Right to oppose: you can withdraw your consent to the processing of your data by opposing their further processing.
  • Right to portability: in some cases, you can request a copy of the personal data in a structured, commonly used, machine-readable format for transmission to another manager.
  • Right not to be subject to individual decisions: you can request that decisions not be taken on the basis of automated processing alone, including profiling, which produces legal effects or significantly affects the data subject.

In some cases, the request may be refused if you ask for the deletion of data necessary for the fulfilment of legal obligations. Also, if you have a complaint about the processing of your data, you can file a claim with the data protection authority.

Who is responsible for the accuracy and truthfulness of the data provided?

The user is solely responsible for the truthfulness and correctness of the data communicated to the company, exonerating COUNTERGROGWISE S.L. from any responsibility in this regard. The users guarantee and are responsible, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user accepts to provide complete and correct information. COUNTERGROGWISE S.L. is not responsible for the veracity of the information that is not of its own making and of which another source is indicated, and therefore neither does it assume any responsibility for hypothetical damages that could arise from the use of said information.

What security measures do we apply to protect your personal data?

COUNTERGROGWISE S.L. has adopted the legally required personal data protection security levels, and tries to install those additional technical means or measures within its reach to prevent the loss, misuse, alteration, unauthorized access and theft of the personal data provided to COUNTERGROGWISE S.L.

How do we use cookies?

The website and the COUNTERGROGWISE S.L. HR use cookies in order to optimize and personalize your navigation. Cookies are physical information files that are stored in the user’s own terminal. The information collected through cookies serves to facilitate the user’s navigation through the portal and to optimize the browsing experience. The data collected through cookies may be shared with the creators of the same, but in no case will the information obtained by them be associated with personal data or data that can identify the user. However, if the user does not wish to have cookies installed on his or her hard drive, he or she has the possibility of configuring the browser in such a way as to prevent the installation of these files. For more information, see our Cookie Policy.

Internal security policy

Security breaches can be caused by employees, third parties or computer errors. Therefore, we are legally obliged to notify the persons concerned if their personal data have been seriously affected within a maximum of 72 hours. In addition, users will be notified as soon as the security breach is resolved.

Modification of the privacy policy

This privacy policy is subject to change. We encourage you to review the privacy policy from time to time.