1. Data Controller

The data controller is Hooki Pro de Daniele Pisu, NIF ESZ1872544G, Calle Tinguafaya, 90C, Arona, Spain. Contact: info@hooki.pro

2. Types of Data Collected

2.1 Data provided voluntarily by the user

Personal data: first name, last name, company name
Contact data: email address, phone number
Access credentials: authentication details (password stored as hash)
Commercial data: billing information, VAT number

2.2 Automatically collected data

Technical data: IP address, browser type, operating system, timezone
Usage logs: pages visited, access times, actions performed on the platform
WhatsApp messages: content of messages sent and received through WhatsApp sessions managed on the platform, retained for 90 days (see section 5)

3. Purposes and Legal Bases for Processing

Purpose	Legal basis (GDPR)
Provision of the Hooki service	Art. 6.1.b — Contract performance
Account management and authentication	Art. 6.1.b — Contract performance
Service communications (disconnections, expiries, technical alerts)	Art. 6.1.b — Contract performance
Transactional email sending	Art. 6.1.b — Contract performance
Tax and accounting obligations	Art. 6.1.c — Legal obligation
Platform security and fraud prevention	Art. 6.1.f — Legitimate interest
Service improvement via anonymous aggregate analytics	Art. 6.1.f — Legitimate interest
Responding to support requests	Art. 6.1.b — Contract performance

4. Processing Methods

Data is processed using IT and telematic tools, with organizational and logical methods strictly related to the stated purposes. Processing is carried out to ensure data security and confidentiality through appropriate technical and organizational measures (AES-256 encryption, access control, encrypted backups). Servers are located in Madrid, Spain.

5. Data Retention

Account data: for the duration of the contract + 10 years for tax obligations
Technical access logs: 90 days
WhatsApp messages (content included): 90 days from the date of sending/receipt
Billing data: 10 years (legal obligation)
Contact/demo requests: 24 months

Upon expiry of the retention period, data is permanently deleted or anonymized.

6. Data Sharing and Transfer

Personal data may be shared with:

IONOS SE — VPS server hosting the platform (Madrid, Spain). Acting as Data Processor under Art. 28 GDPR. DPA available at ionos.com
Vercel Inc. — website infrastructure for hooki.pro. Data is processed in the eu-central-1 region (Frankfurt, Germany), within the European Union. DPA available at vercel.com/legal/dpa
Scaleway SAS — encrypted off-site backups (fr-par, Paris, France). Acting as Data Processor under Art. 28 GDPR. Privacy policy: scaleway.com/en/privacy-policy
MailerSend — transactional email service. Data processed in the EU. Privacy policy: mailersend.com/legal/privacy-policy
Competent authorities — when required by law or judicial order

Data is never sold or disclosed to third parties for marketing purposes. All processing takes place within the European Union: no transfer of data to third countries is performed under Arts. 44–49 GDPR.

7. Your Rights (Arts. 15–22 GDPR)

You have the right to:

Access (Art. 15): obtain confirmation of processing and a copy of your data
Rectification (Art. 16): correct inaccurate or incomplete data
Erasure (Art. 17): request deletion («right to be forgotten»), subject to legal obligations
Restriction (Art. 18): restrict processing in certain circumstances
Portability (Art. 20): receive your data in a structured, machine-readable format
Objection (Art. 21): object to processing based on legitimate interest
Withdrawal of consent: where processing is consent-based, withdraw it at any time

To exercise your rights, write to info@hooki.pro. We will respond within 30 days of receiving your request. You also have the right to lodge a complaint with the Agencia Española de Protección de Datos (AEPD) (www.aepd.es), as the Controller is established in Spain.

8. Cookies

For detailed information on cookie usage, please see our Cookie Policy.

9. Updates to this Privacy Policy

The Controller reserves the right to modify this Privacy Policy at any time. Material changes will be communicated via email to registered users. The updated version will always be available on this page with the last updated date.

10. Contact

For any questions regarding the processing of your personal data:
Email: info@hooki.pro
Subject: Privacy Request — [your name]