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Privacy Policy

Our Company Privacy Policy

Advanced Economic Solutions Ltd (hereinafter ‘Our Company’) is the company behind the brand Empathy Sales Group with headquarters in Sofia, Bulgaria. This Privacy Policy will explain how our organization uses the personal data we collect from you when you use our website.


Pursuant to the General Data Protection Regulation (GDPR) (EU) 2016/679 this Privacy Policy is aimed at informing you (the customer) of his/her rights, the use of his/her personal information and how such information is collected, and what rules apply to the personal information and the obligations imposed to Our Company in relation to collecting, use and processing of that personal information. The Privacy Policy is to make sure that the customers fully enjoy their rights under the GDPR and to ensure that Our Company is fully compliant with the rules under the GDPR when delivering its services. This Privacy Policy applies to all Our Company-owned websites, domains, and services. Personal information concerning Our Company and its customers collected and processed offline is also governed by this Privacy Policy except where the contract with a covered individual defines different requirements which will take precedence over this Privacy Policy.



  • What data do we collect?

  • How do we collect your data?

  • How will we use your data?

  • How do we store your data?

  • Marketing

  • What are your data protection rights?

  • What are cookies?

  • How do we use cookies?

  • What types of cookies do we use?

  • How to manage your cookies

  • Privacy policies of other websites

  • Changes to our Privacy Policy

  • How to contact us

  • How to contact the appropriate authorities


What data do we collect?

Our Company collects the following data:

  • Personal information is any information that personally identifies an individual or from which an individual could be identified. This will include a name, address, telephone number, email address and other private personal attributes.

  • Personal identification information (Name, email address, phone number, age, gender, nationality and specific interest towards particular analyses and/or different content offered on our website etc.)

  • Information about your purchase of products or services – such as product/service identifying information and enrollment status.

  • Customer satisfaction and feedback data – such as results of customer satisfaction and feedback surveys.

  • Data collected when you are visiting our website – such as data collected through cookies and other automatically collected data to provide you with our website, or information that you provide you with our websites, or information that you provide us with when visiting our websites (such through contact forms etc.)

  • Your personal data will be used for developing better educational materials, new individual reports and will further be part of creating our personalized coaching service in the future. This aims to improve our overall services as a company and to raise the quality of the provided content. You will be asked to provide your consent for each of the aspects, for which your personal data will be used.

  • Optional: Previous investing experience of the clients, any professional qualifications, business occupation, annual income, liquid capital, net worth, investment goals

  • Our Company collects, uses, stores and transfers (collectively “processes”) personal information to manage its relationship with its customers, employees, business partners and other third parties (“covered individuals”) and better serve covered individuals by personalizing their experience and interaction with Our Company. Such processing is done in compliance with applicable laws, including appropriate notice and consent, along with required filings with data protection authorities, where required.

  • Our Company will collect and process personal information through a variety of means, including, as examples, access to Our Company sites or services, or other ordering channels, during conversations or correspondence with Our Company representatives, through purchase of goods or services or in the course of an online application.

  • We will keep a record of the places on our emails that you have clicked on and use that information to target advertising on this website to you that is relevant to your interests, which we have identified based on the clicks you have made.

  • We will retain your shopping history and use details of the products you have previously purchased to make suggestions to you for other products which we believe you will also be interested in.

  • We will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive.

  • We will retain data with regard to trends among our clients, purchasing behavior and overall points of interest based on the places where they click, what they purchase, what they read on our website, what articles they observe, in order to make statistically important decisions for our business practices and the way forward to improve those for the benefit of our clients.

How do we collect your data?

You directly provide Our Company with most of the data we collect. We collect data and process data when you:

  • Register online or place an order for any of our products or services.

  • Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.

  • Use or view our website via your browser’s cookies.

  • Voluntarily participate in one of our marketing campaigns

  • Voluntarily consent your data to be used in terms of research and analysis for the improvement of business practices aimed at providing better client experience, better products, personalized products, such as high-priced personal coaching courses, which will be made available through a live webinar. To offer such coaching the personal data described above will be necessary to be used by Our Company.

How will we use your data?

We use the personal information we hold about you for a number of different purposes, which we list below. Under GDPR (General Data Protection Regulation) we need to have a valid legal basis for using personal information, we also set out below the legal bases which will be relying upon.

We will use the personal information we hold about you for the following reasons:

  • To enforce the contract with you and inform you of any changes to the contract.

To offer you any additional products and services as part of marketing outreach, we have to receive your consent first and we will ask you and inform you explicitly about those products and services as part of our marketing outreach.

In both of these cases the legal basis we will be relying upon to process your personal information will be because it is necessary for the performance of the contract between us.

Our Company collects your personal data so that we can:

  • Process your order and manage your account.

  • Email you with special offers on other products and services we think you might like.

  • If we receive any requests related to, for example, a product or service, a callback, or specific marketing materials, we will use your personal information to fulfill your request. In this context, we may share information with others, for instance, Our Company and business partners, involved in fulfillment. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes subject to applicable laws and regulations.

  • We will use information we collect about you to provide you with a personalized experience on our Web sites, such as providing you with content in which you may be interested and making navigation on our sites easier.

  • The information you provide to Our Company, as well as the information we have lawfully collected about you indirectly, may be used by Our Company for marketing purposes. We will offer you the opportunity to opt-in to Our Company using your information in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, or by contacting Our Company directly at

  • Some of our offerings may be co-branded, that is sponsored by both Our Company and third parties. If you sign up for these offerings, be aware that your information will also be collected by and shared with those third parties. We encourage you to familiarize yourself with their privacy policies to gain an understanding of the manner in which they will handle information about you. If you would like to review, rectify or request deletion of any Personal Information we have about you, you can submit a request by emailing Our Company’s privacy office at

In these cases our legal bases for processing your personal information will be because the processing is in our legitimate interests, namely to provide you with a high level of service, resolve complaints and to promote our business.

We will also use the personal information we hold about you to comply with any regulatory requirements and applicable laws and our legal basis for doing so will be that it is necessary for us to so to comply with legal obligations to which we are subject.

Some of the personal data we request will be because we have a legal or contractual requirement to obtain and use the information or it is necessary for us to obtain the information to be able to enter into a contract with you. Failure to provide such information will prevent us from providing you with your requested information or processing your complaint.

If you agree, Our Company will share your data with our partner companies so that they may offer you their products and services.

  • Those companies may include such in the educational and/or financial sector. The sharing of the data will be made only when you provide your consent for it. We will analyse your data gathered, in order to offer you the option to share your data with the companies from the sectors mentioned above, based on your interests. We will gather data, that analyses your interests only by receiving consent from you. Upon realizing that a particular company from another sector might offer something of interest for you, we will inform you about it and provide you with the choice whether you consent to us sharing your data to that other company.

  • Without your consent Our Company will not sell, rent or lease your personal information to other.

  • Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, law enforcement or legal process. We may also share your information to protect the rights or property of Our Company, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

When Our Company processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.

Choices and Privacy Preferences

Registration is not required to gain access to Our Company website. However, if you choose to receive certain services, specific material and information your subscription is required on Our Company website.

In this regard, Our Company will collect personal information from you including your name, phone number, email address, or other information you choose to provide at various times, for example, when you complete an online form or request or participate in an online community.

You can make or change your choices about receiving either subscription or general communications at the data collection point, within your account preference settings or by using other methods, which are listed in this Privacy Policy. You may opt-out at any time using the links at the bottom of any email or by contacting us via email at

Please note, this option does not apply to communications primarily for the purpose of administering business relationships, including contracts, support, or other administrative and transactional notices where the primary purpose of these communications is not promotional in nature.

How do we store your data?

Our Company securely stores your data on our servers, which are serviced and protected by our domain and host service provider.

Our Company will keep your personal information on file. We could delete your data upon a request on your side.

Our Company has implemented technology, management processes and policies aimed to maintain data accuracy. According to applicable laws, Our Company provides individuals with reasonable access to personal information that they provided to Our Company and the reasonable ability to review and correct the data or ask for anonymization, blockage, or deletion, as applicable. To protect your privacy and security when submitting an access request, we will take reasonable steps to verify your identity, such as requiring a password and user ID, and/or other unique personal identifiers before granting access to your data. To submit your access request, please contact us at

Monitoring or Recording of Calls, Chats and Other Interactions

Certain online transactions may involve communication between us and you. They may also involve online chats. Please be aware that it is Our Company’s general practice to monitor and, in some cases, record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction.

Use of Information in the Social Computing Environment

Our Company also provides social computing tools on some of its websites to enable collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms.

When using and registering to use these social computing tools, you may be asked to provide certain personal information. These applications and tools may also include supplemental privacy statements with specific information about collection and handling practices. We encourage you to read those supplemental statements to understand how the tools may process your data.

Any other content you post, such as pictures, information, opinions, or any other type of personal information that you make available to other participants on these social platforms or applications, is not subject to this Privacy Policy. Rather, such content is subject to the terms of use of those applications or platforms, and any additional guidelines and privacy information provided in relation to their use, as well as the process by which you can remove your content from such tools. You should be aware that the content you post on any such social computing platforms may be made broadly available to others inside and outside Our Company.

Providing Support

We will use your personal information to support Our Company products or services you have purchased from us, including technical support, where we may sometimes have incidental access to data that you have provided to us or data that is not gathered. This data may contain information about you. This Privacy Policy does not apply to our access to or handling of this data; We will not gather such data, nor make a use of such data. The data used, processed and handled by us will be the data that is covered by the applicable terms of this Privacy Policy.

Protect the Rights and Property

We may also use or share your information to protect the rights or property of Our Company, our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, law enforcement or legal process.


Our Company would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.

Our Company makes use of third party advertising systems to promote content on this website. These services will often make use of cookies and pixel tags to provide targeted advertisements based on your activities and interests. Our Company does permit third parties to advertise on this site but we do use external sites to advertise our products and services. Please visit these third-party sites for additional details regarding their privacy policies and practices.

The marketing tools and websites that we use for our marketing purposes, to which you have expressly consented to and can opt out at any time are:

Website/App - Tool Use - Advertising & Information - Advertising & Information - Advertising & Information

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop Our Company from contacting you for marketing purposes or giving your data to other members of the Our Company Group.

If you no longer wish to be contacted for marketing purposes, please click here or get in touch with us.

What are your data protection rights?

Our Company would like to make sure you are fully aware of all of your data protection rights pursuant to the GDPR. Every user is entitled to the following:

The right to access – You have the right to request Our Company for copies of your personal data. We have one moth to respond to your request. We may charge you a small fee for this service.

The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete. We have one calendar month to respond to your request.

The right to erasure, right to be forgotten – You have the right to request that Our Company erase your personal data, under certain conditions. We have one month to respond to your request. We have the obligation to erase your personal data that is no longer necessary in relation to the purposes for which it was collected or otherwise processed.

The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions. The processing is restricted, we may still store the data, but not use it.

The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Right to object – You have the right to object to the processing of your personal data under certain circumstances. You have the absolute right to stop your data being used for direct marketing.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email:

Write to us:


Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology

For further information, visit

A cookie is a string of information that a web site saves on a visitor’s computer and then the visitor’s browser provides to the web site operator each time the visitor returns to the information collecting web site. When Our Company collects cookies or makes use of a browser's local storage capabilities, they help Our Company identify visitors, their usage of the site, and their Web site access preferences. Our Company may also use information derived from cookies or local storage to direct the visitor to information similar to what they visited and thereby market Our Company products and services by personalizing the experience on the visitor’s web page on Our Company’s site. Visitors will be offered the opportunity to control cookie placement. Visitors who do not wish to have any cookies placed on their computers should set their browsers to refuse cookies before using Our Company’s web site, with the drawback that certain features of the web site may not function properly without the aid of cookies. Visitors that want to limit third party advertising cookies can enable their browser’s “Do Not Track” functionality.

It must be noted, pages on Our Company’s web site will occasionally embed content from third party sites, for example such as YouTube for videos. Our Company’s web site also allows for content to be shared through social networks but only at your request. Embedding and sharing content may result in as cookies being set by those third party sites. Our Company does not control the dissemination of those cookies. Please visit these third-party sites if you wish to learn more about their use of cookies and similar tools

Please note that the web site is constantly being updated and this list will change over time. If you have any additional questions about the use of a particular cookie please do not hesitate to email

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in

  • Understanding how you use our website

  • Improving your overall user experience

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

  • Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

  • Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

  • Session Cookies – used to remember the product placed in cart by the user, to keep users logged in, and to calculate each user session for analytical purpose.

  • Persistent cookies – stay longer on our website. Persistent cookies are used by ус to track a single user and his/her interaction with their website. Again we will use them for analytical purpose.

  • Secure Cookies - Only HTTPS websites can set secure cookies, i.e., cookies with encrypted data. We use these cookies for the purpose of security of our clients. For example, the checkout or payment pages of our website have secure cookies to facilitate safer transactions.

How to manage cookies?

You can set your browser not to accept cookies, and the above website ( tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Information Security, Accuracy and Retention

Security is a high priority for Our Company and to protect the personal data and other confidential information and maintain its accuracy and integrity we have implemented appropriate administrative, technical and physical safeguards to prevent unauthorized access, use or disclosure. We require the same high standard of information security and information management of any third parties we share your data with.

We will retain personal information only for as long as legally required or permitted and in accordance with Our Company records and information management policies. We respect your right to privacy and upon your request Our Company will no longer use your personal information unless required to provide you services or as necessary to comply with Our Company’s legal obligations, resolve complaints and disputes, and enforce our agreements.

Children’s Privacy

This site is intended for adult use only. Our Company does not knowingly collect information from children as defined by local law, and does not target its websites, social computer tools or mobile applications to children under these ages. We encourage parents and guardians to take an active role in their children’s online and mobile activities and interests and ask that minors should not submit any personal information.

Dispute Resolution

Our Company is committed to resolve any complaints you may have in relation to your privacy and Our Company’s collection and use of your personal information. Please send any privacy related complaints or requests, including request for access to information to

EU/Swiss individuals may also reach out their national privacy authorities and ask for their support. Our Company is committed to coordinate and collaborate with foreign regulators, including EU member state privacy authorities.

Privacy policies of other websites

The Our Company website contains links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should read their Privacy Policy.

Our Company sites or services may provide links to third-party applications, products, services, or websites for your convenience and information. Our Company does not control those third party sites or their privacy practices, which may differ from Our Company’s practices. We do not endorse or make any representations about third-party sites and privacy practices. The personal data you choose to provide to or that is collected by these third parties is not covered by this Our Company Privacy Policy. We encourage you to review the Privacy Policy of any site you interact with before allowing the collection and use of your personal information.

We may also provide social media features that enable you to share information with your social networks and to interact with Our Company on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites.

Changes to our Privacy Policy

Our Company keeps its Privacy Policy under regular review and places any updates on this web page. We will post a notice for 30 days at the top of this page notifying users when this Privacy Policy is updated or modified in a material way. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you, and you will have, subject to legal and/or contractual provisions, a choice as to whether or not we can use your personal information in such a way.

How to contact us?

If you have any questions about Our Company’s Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at:

How to contact the appropriate authority?

We value your opinion, if you have any comments or question about this Privacy Policy, Our Company’s handling of your personal information, or a possible breach of your privacy you can send an email to our team.

Individuals living inside the EU and Switzerland seeking further information, guidance and advice may also contact their local privacy authorities.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to address your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.


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