Legal
Last updated: August 31, 2026.
This policy explains how FINE PROGRAMS SL It processes the personal data of the visitor. https://wallion.com (the «Site»). The Site is the corporate website of the software studio that operates under the brand Wallion. It is not a customer area, it does not collect data from third-party employees, and it does not operate payroll or mobility products.
1. Data Controller
| Company name | FINE PROGRAMS SL |
| Trade name | Wallion |
| NIF | B13790043 |
| Home | Aribau Street, 168, 1st floor, door 1, 08036 Barcelona, Spain |
| Commercial Registry | Barcelona, volume 48806, folio 128, sheet B-596954, entry 1 |
| hello@wallion.com |
We have not appointed a data protection officer. For any questions regarding privacy, please write to hello@wallion.com.
2. What data do we process and where does it come from?
We only process what is necessary for each purpose:
- Navigation and safety. IP address, technical identifiers of the device and browser, date and time, requested URL, and response codes. These are generated by accessing the Site itself and by the hosting logs.
- Contact. If you write to us at hello@wallion.com Or you can use the contact form: name, email, company or organization, company size, type of problem or need, budget range, expected timeframe, message, and any other information you voluntarily provide. The form displays a top-level notice explaining that Fine Programs SL will process this data to address your inquiry and refers you to this policy for more information. Required fields are marked on the form.
- Call reservation. The Site may display an exit link to HubSpot Meetings in https://meetings-eu1.hubspot.com/oleon. By using it, you leave the Site. HubSpot, Inc. collects booking data (identity, email, date, and any other information you request in their workflow) in accordance with their policy. We do not embed the calendar or load the HubSpot script (portal 148716913) on wallion.com.
- Cookies and measurement. Today the Site does not place analytics or marketing cookies and does not load HubSpot. It does use Vercel Web Analytics (
@vercel/analytics), which Vercel declares to be cookie-free. Details: /legal/cookies.
We do not collect special categories of data under Article 9 of the GDPR (health, ideology, etc.) or data relating to infringements through this Site. We also do not create profiles for legal purposes or make automated decisions of this kind.
If you send us data from third parties, you guarantee that you can do so and that those people are aware of this policy.
3. Purposes and legal bases
| Purpose | Data | Basis (Art. 6 GDPR) |
|---|---|---|
| To provide the Site, keep it available and protect it against abuse, fraud or security incidents | Navigation and technical logs | Legitimate interest (6.1.f): operating and securing a corporate website |
| Measure aggregate Site usage (page views, referrer, country, device) | Technical data of the request processed by Vercel Web Analytics | Legitimate interest (6.1.f): understanding what is being consulted on a corporate website, without persistent identifier or advertising |
| To handle inquiries and requests for information or service proposals | Contact (form or email) | Pre-contractual measures (6.1.b) if you request a quote or open a service relationship; otherwise, legitimate interest (6.1.f) in responding to the person who writes to us |
| Schedule a call if you use the booking link | Data you provide in HubSpot Meetings | Pre-contractual measures (6.1.b) upon completion of the booking; HubSpot handles this flow on its own site |
Legitimate interest is weighed against your rights: the Site is informative, the volume of data is the minimum technical amount and is not used for advertising without consent.
If in the future the Site loads HubSpot or another similar tool, the processing of Site usage measurement and association of visits to business contacts through cookies and third-party identifiers will be based on consent (6.1.a), which you can withdraw at any time without affecting the processing already carried out.
4. How long do we keep them?
- Technical records: the time necessary to operate and secure the Site. As a general rule, no more than 12 months, unless they must be retained due to an incident or a legal obligation.
- Business correspondence: for as long as the conversation or relationship lasts and afterwards, the statute of limitations for actions (in particular that of art. 1964 of the Civil Code) and, if there is a contract, the corresponding commercial and tax periods.
When the deadline is over, we delete or anonymize them.
5. With whom do we share them?
We do not sell data. We only share it with:
- Vercel, Inc., which hosts and serves the Site (infrastructure, CDN and technical access logs).
- Vercel Web Analytics (same provider): aggregated measurement of visits, without cookies according to their documentation.
- Lead generation channel On the server side, if a form submission is delivered via webhook or integration into an external management system (independent of cookie consent).
- Mail notification of sending the form, if activated, to the corresponding mailbox.
- HubSpot, Inc., If you use the booking link to HubSpot Meetings: HubSpot processes the meeting data on its site (meetings-eu1.hubspot.com) and we receive it as hosts. This does not load the HubSpot tracker on the Site.
- Mail provider associated with hello@wallion.com, to receive and store messages.
- Administrations and judges, when a rule requires us to.
- Professional advisors (for example, lawyers or auditors) subject to a duty of secrecy, if necessary to defend or fulfill obligations.
HubSpot, Inc. You only receive meeting details if you use the booking link. The tracking script (portal 148716913, the organization's account) It won't load Today; if it loads, cookie consent for that category will be required.
Any other data processor will be contracted with the guarantees of art. 28 GDPR.
6. Transfers outside the EEA
Vercel is based in the United States. When your data leaves the European Economic Area, the transfer to Vercel is covered by the standard contractual clauses adopted by the Commission (Vercel's Data Processing Addendum, March 2026 version), with supplementary measures where appropriate. Vercel claims to be certified under the EU-U.S. Data Privacy Framework (DPF); this is a claim made by the provider that we have not independently verified.
If you use the link of HubSpot Meetings, HubSpot, Inc. receives the booking data. The destination is meetings-eu1.hubspot.com (EU region). HubSpot claims to be EU-US DPF certified; this is a vendor claim that we have not independently verified.
If in the future we load the HubSpot script (portal 148716913) with your cookie consent, that transfer of identifiers will be covered by the DPF certification if it is valid at the time of the upload.
You can request more details at hello@wallion.com.
7. Your rights
You can exercise your rights of access, rectification, erasure, objection, restriction of processing, and data portability, and withdraw your consent when processing is based on it. You also have the right not to be subject to automated decisions with legal effects, which this Site does not carry out.
Write to us at hello@wallion.com from an account that allows you to identify yourself, or to the postal address in section 1. If we ask, we may request additional information to verify your identity.
If you believe we have not addressed your request, you can file a complaint with the Spanish Data Protection Agency (www.aepd.es, electronic headquarters sedeaepd.gob.es).
8. Minors
This website is intended for professionals and businesses. It is not intended for users under the age of 14 (Article 7 of Organic Law 3/2018, on the Protection of Personal Data and Guarantee of Digital Rights). If we detect data belonging to a minor under that age, we will delete it.
9. Changes
We may update this policy. The date of the last version appears at the top. If the change is significant, we will indicate it on the Site or through the appropriate channel.