PRIVACY POLICY

Last updated: november 14, 2025

Pro Commons Developers S.L. (hereinafter “we”, “us”, “our”, or “the Company”), with CIF ESB55412076 and registered office at Gran Via de les Corts Catalanes, 490, 08015 Barcelona, Spain, is committed to protecting and respecting your privacy in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights Guarantee (LOPDGDD).

This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our services, including our website https://procom.dev and our applications and services.

Data Controller
Data Protection Contact
What Personal Data We Collect
Purposes and Legal Bases for Processing
Data Recipients and Sharing
Data Retention Periods
International Data Transfers
Security Measures
Your Rights
Cookies
Minors
Updates to This Policy
Contact Information

1. DATA CONTROLLER

Pro Commons Developers S.L.
CIF: ESB55412076
Address: Gran Via de les Corts Catalanes, 490
08015 Barcelona, Spain
Email: [email protected]
Website: https://procom.dev

2. DATA PROTECTION CONTACT

For all matters related to the processing of your personal data and the exercise of your rights under this policy, you may contact our data protection representative at:

Email: [email protected]
Postal Address: Pro Commons Developers S.L., Data Protection, Gran Via de les Corts Catalanes, 490, 08015 Barcelona, Spain

3. WHAT PERSONAL DATA WE COLLECT

We collect and process different types of personal data depending on how you interact with our services:

3.1 Data You Provide Directly

Account Information: Name, email address, username, password
Contact Information: Email address, phone number, postal address
Billing Information: Name, billing address, payment card details (processed securely through Stripe or PayPal)
Professional Information: Company name, job title, professional email
Communication Data: Messages, inquiries, support requests
Social Login Data: If you use social login features (Facebook, Google, etc.), we receive basic profile information authorized by you

3.2 Data Collected Automatically

Technical Data: IP address, browser type and version, operating system, device information
Usage Data: Pages visited, features used, interaction with our services, access times and dates
Cookie Data: As detailed in our Cookie Policy

3.3 Data from Our Applications

When you use our applications (Moderator, WhaChat, WhaSharer, WhaSolutions products, chatbots, and custom developments), depending on the specific application and your configuration, we may process:

Application usage data
Device identifiers
Performance and diagnostic data
Location data (only with your explicit consent and when necessary for the service)
Push notification tokens (if you enable notifications)

Important: The specific data collected varies by application. Each application provides detailed information about its data processing at the point of collection or in its specific privacy settings.

4. PURPOSES AND LEGAL BASES FOR PROCESSING

We process your personal data for the following purposes and based on the following legal bases under GDPR Article 6:

Purpose	Type of Data	Legal Basis
Provide and manage our services	Account data, technical data	Contract execution (Art. 6.1.b GDPR)
Process payments and billing	Billing data, transaction data	Contract execution (Art. 6.1.b GDPR)
Customer support	Contact data, communication data	Contract execution / Legitimate interest (Art. 6.1.b/f GDPR)
Legal compliance and accounting	Billing data, transaction records	Legal obligation (Art. 6.1.c GDPR)
Marketing communications	Contact data, preferences	Consent (Art. 6.1.a GDPR) or Legitimate interest for existing customers (Art. 6.1.f GDPR)
Service improvement and analytics	Usage data, technical data	Legitimate interest (Art. 6.1.f GDPR)
Security and fraud prevention	Technical data, usage patterns	Legitimate interest (Art. 6.1.f GDPR)

4.1 Legitimate Interests

When we rely on legitimate interests, we have conducted a balancing test to ensure that our interests do not override your fundamental rights and freedoms. Our legitimate interests include:

Improving and optimizing our services
Ensuring network and information security
Preventing fraud and abuse
Direct marketing to existing customers (with opt-out option)
Efficient business management and operations

5. DATA RECIPIENTS AND SHARING

We may share your personal data with the following categories of recipients:

5.1 Service Providers

We work with trusted third-party service providers who process data on our behalf:

Google Cloud: Cloud hosting and infrastructure (EU data centers)
Stripe and PayPal: Payment processing (PCI-DSS compliant)
Google Analytics: Website analytics (anonymized data)
Meta (Facebook/Instagram/WhatsApp): Social media integration and advertising
Pusher: Real-time communication services

5.2 Legal Requirements

We may disclose your data when required by law, including:

To comply with legal obligations
To respond to lawful requests from public authorities
To protect our rights, privacy, safety, or property
In connection with legal proceedings

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protection standards.

5.4 With Your Consent

We may share your data with other parties when you have given us explicit consent to do so.

6. DATA RETENTION PERIODS

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

Type of Data	Retention Period	Justification
Account data	Until account deletion by user + 30 days	Service provision and recovery period
Billing and transaction data	6 years	Legal obligation (Spanish tax law)
Marketing communications	Until withdrawal of consent	Based on consent
Technical logs	90 days	Security and troubleshooting
Cookie data	As specified in Cookie Policy	Various purposes
Support communications	3 years after resolution	Service quality and legal defense

After the retention period expires, we will securely delete or anonymize your personal data.

7. INTERNATIONAL DATA TRANSFERS

We store and process your data within the European Economic Area (EEA). We do not transfer personal data outside the EEA.

Some of our service providers (Google, Meta, Stripe, PayPal) are based in the United States but provide adequate safeguards through:

EU-approved Standard Contractual Clauses (SCCs)
Appropriate technical and organizational measures
Compliance with GDPR requirements for data processors

You can request more information about these safeguards by contacting us.

8. SECURITY MEASURES

We implement appropriate technical and organizational measures to protect your personal data, including:

Technical measures: Encryption of data in transit and at rest, secure servers, firewalls, access controls, regular security updates
Organizational measures: Limited access on a need-to-know basis, confidentiality agreements, regular training, security policies and procedures
Incident response: Procedures to detect, investigate, and respond to security incidents, including notification obligations under GDPR Article 33-34

While we strive to protect your personal data, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but commit to notifying you and the relevant authorities of any breach as required by law.

9. YOUR RIGHTS

Under GDPR and LOPDGDD, you have the following rights regarding your personal data:

9.1 Your Rights Include:

Right to Access (Article 15 GDPR): Obtain confirmation of whether we process your data and access to it
Right to Rectification (Article 16 GDPR): Correct inaccurate or incomplete personal data
Right to Erasure/”Right to be Forgotten” (Article 17 GDPR): Request deletion of your personal data in certain circumstances
Right to Restriction (Article 18 GDPR): Request limitation of processing in certain circumstances
Right to Data Portability (Article 20 GDPR): Receive your data in a structured, commonly used format
Right to Object (Article 21 GDPR): Object to processing based on legitimate interests or for direct marketing
Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
Right Not to be Subject to Automated Decision-Making (Article 22 GDPR): Not to be subject to decisions based solely on automated processing

9.2 How to Exercise Your Rights

You can exercise your rights by:

Email: [email protected]
Postal mail: Pro Commons Developers S.L., Data Protection, Gran Via de les Corts Catalanes, 490, 08015 Barcelona, Spain

Please include:

Proof of identity (copy of ID or passport)
Specific right you wish to exercise
Clear description of your request

We will respond within one month of receipt, extendable by two additional months for complex requests.

9.3 Right to Lodge a Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with:

Spanish Data Protection Agency (AEPD)
C/ Jorge Juan, 6
28001 Madrid, Spain
Website: www.aepd.es
Phone: 901 100 099 / 91 266 35 17

10. COOKIES

Our website uses cookies and similar technologies. We use:

Necessary cookies: Essential for website functionality
Functional cookies: Remember your preferences
Analytics cookies: Understand how you use our services
Marketing cookies: Deliver relevant advertisements

For detailed information about the cookies we use, how to manage them, and your choices, please see our Cookie Policy.

11. MINORS

Our services are not directed to persons under 16 years of age. We do not knowingly collect personal data from minors under 16. If you become aware that a minor has provided us with personal data, please contact us immediately.

In accordance with Article 8 of GDPR and Article 7 of LOPDGDD, if we need to process minors’ data, we will obtain consent from parents or legal guardians.

12. UPDATES TO THIS POLICY

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. We will notify you of any material changes by:

Posting the new policy on our website
Updating the “Last updated” date
Sending notification to registered users via email for significant changes

We encourage you to review this policy periodically. Continued use of our services after changes constitutes acceptance of the updated policy.

13. CONTACT INFORMATION

For questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

Pro Commons Developers S.L.
Data Protection Department
Gran Via de les Corts Catalanes, 490
08015 Barcelona, Spain
Email: [email protected]
Website: https://procom.dev

This Privacy Policy is provided in English. In case of any discrepancy between language versions, the Spanish version shall prevail for Spanish users, in accordance with LOPDGDD requirements.

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