Privacy Policy
Last updated: April 2026
This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you. We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
1. Interpretation
and Definitions
Interpretation
The words of which the
initial letter is capitalized have meanings defined below. These definitions
have the same meaning regardless of whether they appear in singular or plural.
Definitions
For the purposes of this
Privacy Policy:
•
Account — a unique account created for you to access
our Service or parts of our Service.
•
Company (referred to as “we”, “us” or “our”) — DWYER
PARTNERS SL, Carrer Balmes 129Bis 1r 1a A, 08008, Barcelona, Spain.
•
Cookies — small files placed on your device by a
website, containing details of your browsing history among its many uses.
•
Country — Spain.
•
Device — any device that can access the Service, such
as a computer, cellphone or digital tablet.
•
Personal
Data — any information that
relates to an identified or identifiable individual.
•
Service — the Website (Dwyer Partners, accessible from
https://www.dwyerpartners.com and https://www.fmcgguys.com/).
•
Service
Provider — any third-party
company or individual employed by the Company to facilitate, provide or assist
with the Service.
•
Usage
Data — data collected
automatically from the Service or its infrastructure (for example, the duration
of a page visit).
•
You — the individual accessing or using the
Service, or the legal entity on whose behalf they act.
2. Your Rights Under
GDPR
As a company based in
Spain and operating within the European Union, Dwyer Partners SL is subject to
the General Data Protection Regulation (EU) 2016/679 (“GDPR”). We are committed
to ensuring that your personal data is processed lawfully, fairly, and transparently.
Legal basis for
processing
We process your personal
data on one or more of the following legal bases:
•
Consent — you have given clear consent for us to
process your data for a specific purpose.
•
Contract — processing is necessary to fulfil a contract
with you, or to take steps at your request before entering into a contract.
•
Legal
obligation — processing is
necessary to comply with EU or member state law.
•
Legitimate
interests — processing is
necessary for our legitimate business interests, provided these are not
overridden by your rights.
Your GDPR rights
Under the GDPR, you have
the following rights regarding your personal data:
•
Right
of access — you may request a
copy of the personal data we hold about you.
•
Right
to rectification — you may ask
us to correct inaccurate or incomplete data.
•
Right
to erasure — you may request
deletion of your personal data where there is no compelling reason for its
continued processing.
•
Right
to restriction — you may ask
us to restrict processing of your data in certain circumstances.
•
Right
to data portability — you may
request your data in a structured, commonly used, machine-readable format.
•
Right
to object — you may object to
processing based on legitimate interests or for direct marketing purposes.
•
Rights
related to automated decision-making
— you have the right not to be subject to decisions based solely on automated
processing that significantly affect you.
Right to withdraw
consent
Where we process your
personal data on the basis of consent, you have the right to withdraw that
consent at any time. Withdrawing consent does not affect the lawfulness of any
processing carried out before the withdrawal. To withdraw consent, please contact
us at contact@dwyerpartnters.com.
Data breach
notification
In the event of a
personal data breach that is likely to result in a risk to your rights and
freedoms, we will notify the relevant supervisory authority within 72 hours of
becoming aware of the breach, in accordance with Article 33 of the GDPR. Where
the breach is likely to result in a high risk to your rights, we will also
notify you directly without undue delay.
Data processor
agreements
Where we engage
third-party service providers (processors) to process personal data on our
behalf, we ensure that such processors are bound by a data processing agreement
that complies with the GDPR, and that they provide sufficient guarantees as to
the security and lawful handling of your data.
Supervisory
authority
You have the right to
lodge a complaint with the Spanish Data Protection Authority: Agencia Española
de Protección de Datos (AEPD), www.aepd.es.
3. Collecting and
Using Your Personal Data
Types of data
collected
Personal data
While using our Service,
we may ask you to provide personally identifiable information that can be used
to contact or identify you, including but not limited to:
•
Email
address
•
First name
and last name
•
Phone
number
Usage data
Usage data is collected
automatically when using the Service and may include your device’s IP address,
browser type and version, the pages you visit, the time and date of your visit,
time spent on those pages, unique device identifiers, and other diagnostic
data. When you access the Service via a mobile device, similar diagnostic data
may also be collected.
4. Event Sign-Up and
Data Sharing
When you register for an
event organised by Dwyer Partners SL, we collect your name and company name as
part of the sign-up process.
How this data is
shared
By completing an event
registration form, you consent to your name and company name being shared with
other registered attendees of that event. This is done to facilitate
professional networking and introductions among participants.
Your contact details
(such as email address or phone number) are never shared with other attendees
without your separate, explicit consent.
Opt-out right
If you do not wish your
name and company to be shared with fellow attendees, you may opt out at any
time before the event by contacting us at contact@dwyepartners.com. Opting out
does not affect your ability to attend the event.
Legal basis
We process this data on
the basis of your consent, given at the point of registration, and our
legitimate interest in facilitating meaningful professional connections at our
events, in accordance with our GDPR obligations.
5. Photography and
Image Rights at Events
Dwyer Partners events
may be photographed or filmed for promotional and marketing purposes. Images
and recordings may be posted on our website, social media channels,
newsletters, and other marketing materials.
Consent
By registering for a
Dwyer Partners event, you acknowledge and agree that you may appear in
photographs or video recordings taken during the event, and that these may be
published across our digital and printed communications. This consent covers
use of your image for promotional purposes by Dwyer Partners SL.
Opt-out right
If you do not wish to be
photographed or filmed, you may opt out at any time before the event by
contacting us at contact@dwyerpartners.com. On the day, please inform the event
organiser on arrival and we will take reasonable steps to ensure you are not
included in any photography or footage.
Removal of images
If you have been
photographed at an event and wish to have an image removed from our channels,
please contact us and we will action your request promptly. This is in line
with your right to erasure under the GDPR, as set out in Section 2.
Legal basis
We process your image on
the basis of your consent, given at the point of event registration, and our
legitimate interest in promoting our events and business activities. You may
withdraw consent at any time as described above.
6. Tracking
Technologies and Cookies
We use cookies and
similar tracking technologies (beacons, tags, and scripts) to track activity on
our Service and store certain information. Technologies we use may include:
•
Browser
cookies — small files placed
on your device. You can instruct your browser to refuse all cookies, though
some parts of the Service may then be unavailable.
•
Flash
cookies — local stored objects
used to collect information about your preferences or activity, not managed by
the same browser settings as browser cookies.
•
Web
beacons — small electronic
files in pages and emails used to count visitors, track email opens, and gather
related website statistics.
Cookie types we use
•
Necessary
/ Essential cookies (Session)
— essential to provide the Service and authenticate users. Without these, the
services you have requested cannot be provided.
•
Cookie
acceptance cookies
(Persistent) — identify whether users have accepted cookie use on the Website.
•
Functionality
cookies (Persistent) —
remember choices you make, such as login details or language preference, to
provide a more personalised experience.
7. Use of Your
Personal Data
The Company may use
personal data for the following purposes:
•
To provide
and maintain our Service, including monitoring usage.
•
To manage
your requests and attend to enquiries.
•
To
organise and administer events, including sharing attendee information as
described in Section 4.
We may share your
personal information in the following situations:
•
With
other users — when you share
information or interact in public areas of the Service, that information may be
viewed by all users.
•
With
event attendees — your name
and company name, where consent has been given at the point of event
registration.
8. Retention and
Transfer of Your Personal Data
We retain your personal
data only for as long as necessary for the purposes set out in this Privacy
Policy, or as required by law to resolve disputes and enforce our legal
agreements. Usage data is generally retained for a shorter period unless
required for security, functionality improvements, or legal obligations.
Your data may be
processed at our operating offices or in other locations where parties involved
in processing are based. By submitting your information, you consent to this
transfer. We take all reasonably necessary steps to ensure your data is treated
securely and that no transfer takes place unless adequate controls are in
place.
9. Disclosure of
Your Personal Data
Business
transactions
If the Company is
involved in a merger, acquisition or asset sale, your personal data may be
transferred. We will provide notice before such a transfer takes place and
before your data becomes subject to a different privacy policy.
Law enforcement
We may be required to
disclose your personal data in response to valid requests by public authorities
(e.g. a court or government agency).
Other legal
requirements
We may disclose your
data in good faith where necessary to:
•
Comply
with a legal obligation
•
Protect
and defend the rights or property of the Company
•
Prevent or
investigate possible wrongdoing in connection with the Service
•
Protect
the personal safety of users of the Service or the public
•
Protect
against legal liability
10. Security of Your
Personal Data
The security of your
personal data is important to us. While we strive to use commercially
acceptable means to protect it, please be aware that no method of transmission
over the Internet or electronic storage is 100% secure, and we cannot guarantee
absolute security.
11. Children’s
Privacy
Our Service does not
address children’s data. We do not knowingly collect personally identifiable
information from children.
12. Links to Other
Websites
Our Service may contain
links to other websites not operated by us. We strongly advise you to review
the privacy policy of every site you visit. We have no control over and assume
no responsibility for the content, privacy policies or practices of any third-party
sites or services.
13. Changes to This
Privacy Policy
We may update this
Privacy Policy from time to time. We will notify you of any changes by posting
the new Privacy Policy on this page and updating the “Last updated” date. You
are advised to review this policy periodically. Changes are effective when posted.
14. Contact Us
If you have any
questions about this Privacy Policy or wish to exercise your rights under GDPR,
you can contact us by email: contact@dwyerpartners.com