1. Data controller
Identity: MASTERMINDS STUDIO, S.L.
Tax ID (CIF): B19859990
Registered office: Avenida Menéndez Pelayo, nº 8, 3rd floor, 41004 Seville, Spain.
General contact email: admin@vess.digital.
Privacy contact: business@vess.digital.
Data Protection Officer (DPO): No DPO has been appointed as it is not currently required. For any data protection matter, please contact business@vess.digital. If a DPO is appointed in the future, this Policy will be updated with their identity and contact details.
This section applies to personal data processing carried out through the Founders Hub Platform for registered users and candidates participating in the evaluation and access processes (the "User").
2. Personal data processed
MASTERMINDS STUDIO, S.L. processes the following categories of the User's personal data within the Founders Hub Platform:
a) Data provided directly by the User
- Full name.
- Email address.
b) Data obtained from publicly accessible sources
- Information contained in public professional profiles (LinkedIn), to the extent relevant to the suitability evaluation process.
c) Data generated automatically by the Platform
- Results of the scoring system and compatibility with sector opportunities.
- Platform usage information (access logs, internal navigation, interactions with content and opportunities).
d) Data derived from the contractual relationship
- Communications between the User and the MASTERMINDS STUDIO, S.L. team.
- Preferences regarding sector verticals or specific opportunities.
Special categories of personal data (such as ethnic origin, political opinions, religious beliefs, or health data) will not be requested or processed, unless the User voluntarily includes them in their profile — in which case they will not be processed or used for evaluation.
3. Purposes of processing
a) Managing access and use of the Founders Hub Platform
- Enabling User registration and authentication.
- Administering access to Platform features and content.
- Maintaining the contractual relationship arising from acceptance of the Terms of Service.
b) Suitability and compatibility evaluation
- Applying the automated scoring system and analysis methodologies that determine the User's suitability to access the Platform and participate in sector opportunities.
- Analyzing the User's technical and professional fit with specific projects.
c) Necessary operational communications
- Informing the User about technical incidents, changes to the Terms of Service or the Privacy Policy, and any aspect strictly necessary for the operation of the Platform.
d) Service improvement
- Performing statistical analyses and internal studies on Platform use, always in aggregated and anonymized form, to optimize methodologies, algorithms, and services.
e) Commercial communications (with the User's prior express consent)
- Sending newsletters, event information, and other promotional communications related to Founders Hub and the vess ecosystem.
- The User may withdraw consent at any time, without affecting the lawfulness of prior processing.
4. Legal basis for processing
Processing is based on the following legal grounds under Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD):
a) Performance of a contract (Art. 6.1.b GDPR)
Necessary to perform the contractual relationship arising from acceptance of the Terms of Service, including:
- User registration and access.
- Management of the account and Platform features.
- Application of the scoring system and suitability evaluation.
- Communications necessary for service provision.
b) Compliance with legal obligations (Art. 6.1.c GDPR)
Processing certain data may be necessary to comply with tax, commercial, or record-keeping obligations applicable to MASTERMINDS STUDIO, S.L., always within the User's reasonable privacy expectations given the professional purpose of such networks.
c) Controller's legitimate interest (Art. 6.1.f GDPR)
MASTERMINDS STUDIO, S.L. may process Platform usage data for internal analysis and aggregated, anonymized studies (from which Users cannot be identified) to continuously improve services and algorithms, provided the User's fundamental rights do not override such interest.
d) User's express consent (Art. 6.1.a GDPR)
Consent is required for:
- Sending commercial communications and newsletters related to the Platform.
- Specific processing activities not essential for the performance of the contract.
The User may withdraw consent at any time, without affecting the lawfulness of prior consent-based processing.
5. Automated decisions and profiling
Access to the VESS Platform and to the Founders Hub Platform is conditioned on an automated scoring system based on publicly available professional information (e.g., professional profiles, corporate websites, public databases) and on the data provided directly by the User.
This constitutes profiling under Article 22 of Regulation (EU) 2016/679 (GDPR), as it may automatically determine whether the User is admitted to the Platform. It is also subject to the obligations of Regulation (EU) 2024/1689 (AI Act) insofar as it affects the assessment of the professional profile and financial viability of natural persons.
- The access decision based on scoring is made in an automated manner following MASTERMINDS STUDIO, S.L.'s proprietary methodology. The system does not make exclusion or denial decisions with significant legal effects on a purely automated basis: every algorithmic result is actively supervised by qualified human personnel before it takes effect.
- The User has the right to request human intervention, express their point of view, and contest the automated decision.
- A dedicated channel is available at business@vess.digital, with a response time of up to one (1) month.
The purpose of the scoring system is to ensure an objective, consistent, and professionally grounded process, avoiding subjective bias in candidate evaluation.
6. Data sharing and processors
6.1 Sharing with third parties
The User's personal data will not be shared without prior consent, except in the following cases:
- Compliance with a legal obligation applicable to MASTERMINDS STUDIO, S.L.
- Requests from administrative, tax, or judicial authorities acting within their competence.
- When strictly necessary for events, activities, or training carried out jointly with a company or public administration.
Although absolute protection against intrusions cannot be guaranteed for internet transmissions, both MASTERMINDS STUDIO, S.L. and its providers apply appropriate technical and organizational measures, including encryption, access controls, and security procedures under current regulations.
6.2 Data processors
To provide the Founders Hub services, MASTERMINDS STUDIO, S.L. may rely on technology providers acting as data processors, such as hosting, cloud storage, communications, analytics, or technical support, which only process data on the controller's instructions. Article 28 GDPR processing agreements are signed with each provider.
7. International data transfers
In principle, MASTERMINDS STUDIO, S.L. does not carry out international data transfers outside the European Economic Area (EEA). If needed for certain technology services, the User will be informed and transfers will only occur:
- To countries with a European Commission adequacy decision.
- Under Standard Contractual Clauses approved by the European Commission or other GDPR-recognized safeguards.
- With the User's express and informed consent.
8. Data retention periods
- Registration and account data: while the contractual relationship lasts and the account remains active.
- Data used in the scoring system: as long as necessary for the initial evaluation and throughout the relationship.
- Communications and Platform usage data: during service provision and, where applicable, blocked during the legal limitation periods.
- Data used for commercial purposes (with consent): until consent is withdrawn or deletion is requested.
Once the relationship ends or consent is withdrawn, the data will be blocked and only available to address legal responsibilities, claims, or requests from authorities for the strictly necessary period. Data will then be securely deleted.
9. User rights
- Right of access: confirmation of whether we process your data and access to it.
- Right of rectification: correction of inaccurate or incomplete data.
- Right of erasure ("right to be forgotten"): deletion when data are no longer necessary.
- Right to object: for reasons related to your particular situation.
- Right to restriction of processing.
- Right to data portability: receive your data in a structured, commonly used, machine-readable format.
- Right not to be subject to automated decisions: including profiling, with the right to request human intervention.
You can exercise these rights by written request to:
- Email: business@vess.digital
- Postal address: Avenida Menéndez Pelayo, nº 8, 3rd floor, 41004 Seville, Spain.
The request must include your full name, a copy of an ID document, and the right you wish to exercise. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD).
10. Security measures
MASTERMINDS STUDIO, S.L. has adopted the technical and organizational measures needed to ensure the security of personal data and prevent alteration, loss, unauthorized processing or access, under the GDPR and LOPDGDD. In particular:
- Encryption of communications and secure storage of information.
- Restricted access control protocols to personal data.
- Periodic backups and disaster-recovery systems.
- Regular audits and technical reviews of security systems.
- Access limited to authorized personnel bound by contractual confidentiality.
No internet security measure is completely infallible. MASTERMINDS STUDIO, S.L. commits to notifying the User and the competent supervisory authority of any security breach affecting personal data when required by applicable regulations.
11. Provision of data and consequences of not providing it
Providing certain personal data (e.g., name, email, and minimum professional information) is necessary to register and access the Founders Hub Platform and to participate in the scoring evaluation. Refusing to provide such data will prevent account creation and/or the delivery of services linked to the Platform. Where data collection is mandatory, this will be expressly indicated in the corresponding form.
Seville, June 24, 2026.
