Privacy Policy

1. Data controller

The data controller of personal data processed through https://happylinx.com is Real Estate Hub S.L., CIF B13886080, with address at Calle de Rodríguez San Pedro 2, floor 6, office 606, 28015 Madrid, Spain, registered in the Commercial Registry of Madrid, Volume 45529, Folio 150, Sheet M-800765, Inscription 1ª. Happylinx is the commercial brand under which Real Estate Hub S.L. provides an online service to create, personalize and share collaborative digital cards. General contact: hola@happylinx.com. Support: soporte@happylinx.com. Privacy and exercise of rights: privacidad@happylinx.com. Happylinx currently does not have a formally appointed Data Protection Officer.

2. Scope of this policy

This Privacy Policy explains how Happylinx processes the personal data of card buyers or managers, guests who leave messages or photos, card recipients, people who contact support, users who browse the web and people who interact with Happylinx on social networks, without prejudice to the Social Network Policy.

3. Categories of data we may process

Happylinx may process different personal data depending on your use of the service. The specific categories are detailed in the following sections.

3.1. Buyer or card manager data

• Name or identifier indicated by the user.
• Email.
• Data of the created card: title, recipient, occasion, deadline, design, contracted plan and configuration.
• Management, guest and recipient links.
• Information about purchases, extensions and extras.
• Technical data associated with the use of the service.
• Communications with support.

3.2. Guest data

We can process the name or alias entered to sign the message, the written message, the photo if the guest decides to upload it and the function is available, and the email when necessary, for example if the message is pending, if you purchase a premium extra, if you contact support or if we need to communicate an incident related to your participation.

In general, the guest may leave a normal message without providing an email, unless the specific functionality requires it.

3.3. Recipient data

The buyer or manager can enter recipient data, such as name, nickname, occasion or reason for the card, messages or personal references included on the card. The buyer or manager declares that he or she has a legitimate basis or sufficient authorization to include said data on the card.

3.4. Data included in messages and photos

Users can include their own or third-party personal data in texts or photos. Whoever uploads content declares that he or she has the necessary rights, permissions or authorizations to do so, especially when the content includes an image, voice, name, personal data or references to other people. If the content includes data or images of minors, the uploader declares that they have sufficient authorization from their legal representatives or sufficient legitimacy to share it in the context of the card.

3.5. Support data

• Name.
• Email.
• Reason for the consultation.
• Information included in the message.
• Data necessary to identify a card, purchase, message or incident.
• History of communications necessary to resolve the query.

3.6. Payment data

Payments are processed through Stripe. Happylinx does not store complete bank card details or payment credentials. Yes, we can process or retain information associated with the operation.

• Stripe session identifier.
• Payment identifier.
• Payment status.
• Subtotal amount.
• Tax amount.
• Total amount.
• Currency.
• Billing country.
• Product, plan, extension or extra purchased.
• Buyer's email when necessary for the operation.

3.7. Technical and security data

We may process technical data necessary for the operation and security of the service. Happylinx may use Google Analytics 4 on public pages only with prior analytics consent and keeps analytics tools blocked on private routes or routes with tokens.

• IP address.
• Technical identifiers.
• Browser and device information.
• Date and time of access.
• Activity logs necessary for security, diagnosis or abuse prevention.
• Technical or necessary cookies.

4. Purposes of processing

• Create, configure and manage digital cards.
• Allow guests to add messages or photos.
• Show the card to the manager, authorized guests or recipient.
• Manage plans, message limits, upgrades and premium extras.
• Process payments and confirm purchases.
• Provide technical support or user service.
• Send transactional emails necessary for the operation of the service.
• Manage pending messages, full cards or extension requests.
• Allow downloading or temporary storage of the card.
• Apply retention and deletion policies.
• Ensure security, prevent fraud, abuse, spam or unauthorized access.
• Comply with legal, tax, accounting or regulatory obligations.
• Defend the rights and legitimate interests of Happylinx, users or third parties.

5. Legal bases for processing

The main legal bases for processing are the execution of a contract or pre-contractual measures, consent, legitimate interest and compliance with legal obligations, depending on the specific purpose.

5.1. Performance of a contract or steps prior to entering into a contract

• Create and manage a card.
• Hire a plan.
• Process an extension or extra.
• Allow access to the manager.
• Provide the contracted service.
• Manage service-related support.

5.2. Consent

Consent will apply when the user voluntarily uploads a photo, when a guest provides their email in cases that are not strictly necessary, when specific authorization is requested, or when Google Analytics 4 analytical cookies are activated on public pages. Analytical cookies are optional, disabled by default and can be accepted, rejected or withdrawn from the cookie preferences. Consent may be withdrawn where applicable, without affecting the lawfulness of processing previously carried out.

5.3. Legitimate interests

• Maintain service security.
• Prevent fraud, abuse or spam.
• Resolve technical incidents.
• Preserve basic evidence of activity.
• Protect the rights of Happylinx, users or third parties.
• Manage complaints or improper uses.

5.4. Compliance with legal obligations

This basis will be applicable when we must retain or communicate data to comply with tax, accounting, legal, administrative obligations or requirements of competent authorities.

6. Transactional emails

Happylinx may send transactional emails related to the service, such as confirmation of card created, purchase confirmation, important capacity notices, extension requests or confirmations, communications about pending messages, notices about deadline, download or deletion, support received or responded to, and relevant service incidents. These emails have no advertising purpose and will be sent only when they are necessary for the provision, security or management of the service. Happylinx will try to limit the number of emails sent and will prioritize, where reasonable, the information available in the card management panel.

7. Service providers and data processors

To provide the service, Happylinx uses technology providers that can process personal data on behalf of Real Estate Hub S.L., including Stripe as a payment provider, Resend as a provider for sending transactional emails, Supabase as a provider of database and storage of content such as messages and photos, and hosting or deployment providers where the website or part of its infrastructure is hosted. These providers must only process the data in accordance with Happylinx's instructions and for the provision of the contracted service.

8. International data transfers

Some technology providers may be located outside the European Economic Area or provide services through international infrastructures. When international data transfers occur, Happylinx will ensure that they are carried out in accordance with guarantees recognized by applicable regulations, such as standard contractual clauses, adequacy decisions or other valid mechanisms.

9. Data retention

The data will be kept for the time necessary to provide the service and fulfill the purposes described. The following sections detail the main deadlines and assumptions.

9.1. Active cards

The card will be available until the deadline set by the buyer or manager.

9.2. Additional download period

After the deadline, Happylinx may keep the card and its contents for an additional period of 30 days so that the manager can access, review or download the card.

9.3. Permanent deletion

After the additional period of 30 days, Happylinx may proceed to permanently delete the card and the associated contents, including messages, photos and audios if they exist, unless there is a legal obligation to preserve them or a pending incident.

Photos included in a contracted plan and photos or audio added as extras will not be kept indefinitely. Happylinx may apply technical limits on size, format, security and storage, and delete associated files when applicable due to expiration or automatic deletion.

9.4. Expired pending messages

Pending messages that could not be incorporated into a card may be kept internally for additional 7 days for support, incident review and technical control, before being deleted.

9.5. Payment and billing data

Data related to payments, taxes, accounting or billing may be retained for the applicable legal periods.

9.6. Support

Support communications may be kept for the time necessary to resolve the incident and, subsequently, for the reasonable period necessary to address possible liabilities.

9.7. Technical logs

Technical and security logs will be retained for the period necessary to ensure security, diagnose incidents or prevent abuse, and will be deleted or anonymized when they are no longer necessary.

10. Disclosure of data to third parties

Happylinx will not sell personal data to third parties. We may communicate data when necessary to provide the service through technology providers, process payments, comply with a legal obligation, meet the requirements of competent authorities or protect the rights, security or legitimate interests of Happylinx, users or third parties.

11. Data provided by third parties

In Happylinx, a person can enter another person's personal data, for example the recipient's name or personal references, within a message. Whoever enters third party data declares that they have authorization, legitimate basis or sufficient relationship to do so in the context of the card and undertakes not to include particularly sensitive or unnecessary data. Happylinx may remove content or respond to deletion requests when an affected person requests it and there are reasonable grounds for doing so.

12. Security

Happylinx will apply reasonable technical and organizational measures to protect personal data against loss, unauthorized access, alteration, disclosure or destruction. No system is completely foolproof, but Happylinx works to maintain a level of security appropriate to the risk.

• Access control.
• Private links or tokens.
• Use of safe providers.
• Private photo storage.
• Backend validations.
• Limitation of permissions.
• Activity logs required for security.
• File size and type restrictions.

13. Data subject rights

Interested persons can exercise the rights of access, rectification, deletion, opposition, limitation of processing, portability and withdrawal of consent when appropriate. To exercise them, you can write to privacidad@happylinx.com indicating the right you wish to exercise and including sufficient information to identify the requesting person and locate the data related to the request. When necessary, Happylinx may request additional information to verify identity or complete the request. You can also file a claim with the Spanish Data Protection Agency if you consider that the processing of your data does not comply with the applicable regulations.

14. Children

The buyer or manager of a card must be over 18 years old. Minors may be recipients of a card or appear in messages and photos if the person who enters or uploads the content has sufficient authorization from their legal representatives or sufficient legitimacy to do so. Happylinx may remove content related to minors when it receives a reasonable request from its legal representatives or detects inappropriate use.

15. Social media

Happylinx may have profiles on Instagram, Facebook and LinkedIn. The processing of data on those profiles is governed by the Happylinx Social Media Policy and is also subject to each platform’s terms and privacy policies. The fact that Happylinx runs ads on social networks does not imply that advertising pixels or social media tracking tools such as Meta Pixel are installed on happylinx.com.

16. Cookies

Information about cookies is set out in the Cookie Policy, available at /politica-de-cookies. Happylinx uses technical or necessary cookies for operation, security, session, payments or essential preferences. It may also use Google Analytics 4 on public pages only when the user has expressly accepted the analytics category. No advertising or marketing cookies are installed on happylinx.com. If additional advertising measurement tools or tracking pixels are incorporated in the future, the Cookie Policy, this Privacy Policy and the corresponding consent system will be updated.

17. Changes to this Privacy Policy

Happylinx may update this Privacy Policy to adapt it to legal, technical, operational or commercial changes. The applicable version will be the one published on the website at all times. When changes are relevant, Happylinx may inform by reasonable means.