Privacy notice / statement

Privacy notice/statement

At Net Real Solutions S.L.U., we are part of LINK, and we take privacy very seriously. We want to inform you about how we process your personal data at LINK. LINK is a global CPaaS company, with customers and more than 30 offices worldwide. Our approach to regulatory compliance is global. Learn more about how and why we collect data and how we manage it.

LINK MOBILITY PRIVACY STATEMENT

For the purposes of this statement, LINK Mobility (“LINK”) refers to all companies that are part of the LINK Mobility Group (either individually or collectively).

The updated list of all LINK entities can be found at here.

Responsibility for Personal Data

Each subsidiary is responsible for the processing of Personal Data in accordance with this Privacy Statement.

The data controller for this site is:
Net Real Solutions S.L.U.
B12550877
Avda. Arcadi García Sanz, 19 - 1ºA
Vila-real, Castellón, 12540
Spain
+34 964 523 331
compliance.es@linkmobility.com

LINK headquarters in the EU/EEA

LINK’s headquarters in the EU/EEA is the legal and registered office of Link Mobility Group Holding ASA (registration no. 920 901 336), located in Norway.

Data processing and transfer

LINK is responsible for the processing of a wide range of Personal Data, as described below in the sections 'Data Controller' and 'Data Processor'.

LINK processes Personal Data in accordance with applicable laws and regulations.

LINK Mobility Group is composed of numerous entities, and personal data may be shared and transferred between the aforementioned LINK entities.

Terminology

We will use certain terms that are common within this privacy statement and should be understood as defined in Article 4 of the GDPR:

A data subject is an identifiable natural person;
The Data Controller is the legal entity that, alone or jointly with others, determines the purposes and means of the processing of personal data;
A Processor is the legal entity that processes personal data on behalf of the Controller;
A Personal Data is any data linked directly or indirectly to a natural person (Data Subject).
Processing of personal data means any use of personal data, including collection, storage, modification, transfer, or deletion.
Traffic Data refers to data generated through the use of a network. For example, when a person uses the mobile network, information is generated about who sends and receives a message or call, the start and end time, and the mobile phone’s location. If the traffic data can be directly or indirectly linked to you as a person, it is classified as Personal Data. Traffic Data can be used, for example, for billing purposes.
Anonymous data refers to data from which all identifying elements have been removed, making it impossible to associate them with an individual.

Privacy Notice and Personal Data Processing at LINK Mobility

When you (or your company/employer) use LINK’s products and services, we process the following general types of personal data:

If you (or your company/employer) have already signed an agreement with us to use one or more of our services, we will process your Personal Data as a Client or Supplier (as the contact person/representative/employee of a Client or Supplier, respectively).
If you or your company or employer have not yet signed an agreement with us and contact us through one of the channels (such as visiting this website), we will process your data as a prospective Client or Supplier (as the contact person/representative/employee of a prospective Client or Supplier, respectively).
Personal data of end users that LINK Clients share with LINK when processing is carried out using LINK’s services are referred to as End User Data.

The nature of the processing depends on the type of data you (or your company/employer, as applicable) have provided to us.
LINK offers numerous products and solutions to its clients. This document provides a general overview of Personal Data Processing at LINK Mobility, which may be broader or more limited depending on the specific solution used by the LINK Client. Please refer to the specific Privacy Notices for each product on the respective product web page or the Data Processing Agreement.

Data retention

LINK will retain Personal Data for as long as necessary to fulfill the purposes of the processing and, as a general rule, will retain it until the termination of the contract or until end users request its deletion.

Please note that legal obligations, such as statutory accounting retention requirements or anti-terrorism or national security laws, may require the retention of Personal Data after contract termination.

Continued storage may also occur when necessary for LINK’s legitimate interests, including, but not limited to, the establishment, exercise, or defense of legal claims.

LINK as Data Controller

The way LINK processes Personal Data as a Data Controller is defined and described in this privacy notice and explained in the following sections.

Where applicable, the processing of your personal data is based on one or more of the following legal grounds:

your consent (ref. GDPR Art. 6.1.a), in relation to the marketing of LINK's services
your agreement (or your employer's agreement) with LINK as a Customer or Supplier of LINK or as an employee, other contracted personnel, consultant, or management of the Customer or Supplier (ref. GDPR Art. 6.1.b or GDPR Art. 6.1.f); To fulfill the agreement for use of a service provided by LINK to the end user, for example, in connection with the management of the user profile or memberships, and to notify end users of changes or respond to inquiries related to the services, terms and conditions, or this privacy notice.
legal obligation(s) to which LINK is subject, e.g., continued storage due to legal archiving rules for accounting purposes, retention of traffic data for national security purposes (ref. GDPR Art. 6.1.c, f);
Other legitimate interests of LINK (ref. GDPR, art. 6.1.f). To pursue LINK's legitimate interests (provided the data subjects' interests do not override them), for example, in relation to improving services or user experience, to establish, exercise or defend legal claims, to prevent loss or damage to LINK or third parties, or to prevent any action that may compromise LINK’s or a third party’s property, or the personal data of other service users.

Business contacts, hereinafter representatives of Suppliers, Clients, or Investors and their Employees

LINK may obtain your data as a business contact when, for example, you reach out to our sales or investor relations team, or when registering on our website or contracting our web or email services.

We may request personal information from you, such as your name, address, postal code, city or country, phone number, or email address.

We may also collect and process additional personal data or information you provide when contacting us with specific requests and/or to apply for vacancies, inquiries about job offers, or unsolicited applications.

Data processing activities

Processing activity	Legal basis	Data retention	Description
Develop and manage sales proposals, offers and quotations, Manage customer accounts	Based on GDPR Art. 6.1(a), (b), (c), or (f)	Data retention during the term of the contract and after its expiration for a reasonable consultation period (up to 6 years, depending on applicable law)	LINK's processes for the purpose of signing and managing agreements with employees, other contracted personnel, consultants or management of LINK’s Customers; Notifying Customers/Suppliers and their representatives and employees of: Changes to terms and conditions, payments, other regulations or privacy policy; Changes directly related to service provision within LINK’s services, such as service updates, technical condition updates and documentation; The payment status of performed services (invoicing and payment status), including discount codes for services; Other operational matters
Manage customer service, investor, or supplier issues, requests, and inquiries.	Based on Art. 6.1(b), (c), or (f)	Data retention during the term of the contract and after its expiration for a reasonable consultation period (up to 12 months, depending on applicable law)	LINK contacts the Client regarding their inquiries; to respond to questions related to services, investments, applicable terms and conditions, or this privacy notice; regarding the operation of the LINK service; or related to service quality.
Measure customer satisfaction with issue handling, requests, and inquiries (NPS)	Based on Art. 6.1(f) GDPR	Data retention up to 1 month after the NPS round has ended	Customer Satisfaction Surveys

Website Visitors

LINK may also collect information about your visit to this or another corporate website through the use and installation of cookies. This includes, but is not limited to, IP address, browser type and version, pages visited within the website, visit duration, and pages viewed on your computer.

We use cookies for this purpose. You can find more information about cookies in the "Cookies" section below.

By visiting our website, you accept our Privacy Policy. If you do not accept it, we recommend that you do not interact with us in any way.

Processing activity	Legal basis	Data retention	Description
websites / website analytics	Based on Art. 6.1(a) or (f) of the GDPR.	Up to 12 months from the last visit	In order to manage and analyze the website, improve and evaluate our website and services; obtain information about the use of our website, as described below in the cookies section;
Manage leads/opportunities through contact from the website	Art. 6.1(a) or (f) of the GDPR	Up to 12 months from the last contact	In order to respond to inquiries from potential and current clients · Contact, or to keep visitors to our website informed about information that LINK believes may be of interest to them (marketing), after a visitor has submitted a web form on our website or by other means (opt-in);

How do we use cookies?

LINK uses cookies and similar technologies on our websites. Cookies help us identify the most popular sections of our websites, which pages are visited, and for how long. The data is used for service development and analysis, as well as for ad targeting on our partners' websites.

Cookies are small text files that contain a string of characters and are stored on your computer or mobile device to identify your browser or device. They do not damage your computer or files. They simply allow a website or service to know whether your computer or device has visited it before. Cookies help understand how a website or service is used. They also help you navigate between pages more efficiently, remember your preferences, and, in general, enhance your browsing experience.

We use cookies for:

Enable the use of services available through the service, for example, authentication cookies used to log in to the site and maintain login sessions within the site.
Adapt the website content to the user’s individual preferences by “remembering” the settings chosen by the user and customizing the user interface, for example, for the selected language or region.
Create statistics to help understand how website users use the websites, allowing better personalization of the website based on users' needs.
To offer website users advertising content better tailored to their interests

Use of Cookies by LINK

Cookie Name	Purpose	Expiration date	Type
1P_JAR	Transfer data to Google	1 month	Analytics / Third Parties
_ga	It is used to differentiate between users and sessions. The cookie is created when the javascript library is loaded and there is no previous version of the _ga cookie. The cookie is updated every time you send the data to Google Analytics.	2 years	Analytics / Third Parties
_gat_UA-47548157-4	It is used to limit the percentage of requests.	1 minute	Analytics / Third Parties
CONSENT	Google Adwords. These cookies serve advertising purposes. They contain a unique randomly generated value that allows the Platform to distinguish browsers and devices. This information is used to measure ad performance and provide product recommendations based on statistical data.	Permanent	Publicity
_gid	These cookies have an advertising purpose. They contain a randomly generated unique value that allows the Platform to distinguish browsers and devices. This information is used to measure ad performance and provide recommendations regarding products based on statistical data.	Persistent	Publicity
__adroll_fpc	This cookie is used to identify the visitor across visits and devices. We use it to display relevant ads to users based on their interests and preferences.	2 years	Publicity
__ar_v4	This cookie is associated with Google’s DoubleClick advertising service. Help with tracking ad conversion rates.	Persistent	Publicity
hubspotutk	This cookie does tracking to the identity of your visitor. It passes to HubSpot in the sending of forms and it is used to remove the duplication of contacts.	13 months	Functionality
__hssc	This cookie does tracking of the sessions.	30 minutes	Functionality
__hstc	It contains the domain, utk, initial time mark (first visit), most recent time mark (last visit), current time mark (this visit) and number of session (increase for each later session)	13 months	Functionality
__hssrc	When HubSpot changes the cookie of the session, this cookie is also set to determine if the visitor has reset his browser.	End of the session	Functionality

What happens if cookies are disabled?

Some features of the Services and areas of this website may not work properly if cookies are disabled.

User settings to avoid Cookies

At LINK, and in compliance with current legal regulations, we provide you with information that allows you to configure your Internet browser(s) to maintain your privacy and security regarding cookies.

Therefore, we provide you with information and links to the official support sites of major browsers so that you can decide whether or not to accept the use of cookies.

Thus, you can block cookies using your browser’s settings tools or configure your browser to alert you when a server wants to store a cookie:

If you use Microsoft Internet Explorer, in the menu option Tools > Internet Options > Privacy > Settings. Further information
If you use Firefox, in the menu option Tools > Options > Privacy > Cookies. Further information
If you use Chrome, in the Options section > Advanced options > Privacy. Further information
If you use Opera, in the Security and Privacy option, you can configure the browser. Further information
If you use Safari, you can configure the browser under Preferences > Security or Privacy. Further information

If you use another browser, see its policy of installation, use and blocking of cookies.

Mobile phone owners [end users]

As a provider of electronic communications services under the European Electronic Communications Code (EECC), LINK sends messages such as SMS, various OTT formats, emails, or others from our Client to the end user (the recipient of the communication, the data subject) via the channel chosen by the Client of LINK.

Processing activity	Legal basis	Data retention	Description
Messaging (GSM/OTT): message transmission	Art. 6.1(f) GDPR	Up to 72 hours	To send and route messages through various messaging channels such as SMS, OTT, and others from our Customer to the end user (the data subject).
Messaging (GSM/OTT): retention of telecommunications metadata	Art. 6.1(c) GDPR	Up to 12 months, depending on applicable law	Comply with laws and regulations related to sending and routing messages through various messaging channels such as SMS, OTT, and others from our client to the end user (the data subject).

LINK Employees

Employees at all levels of LINK Mobility are familiar with the purpose of the GDPR and how to comply with applicable regulations. LINK employees must refer to internal documentation regarding data processing.

LINK candidates and applicants

LINK Mobility stores personal data of candidates and job applicants for LINK's recruitment processes.

Personal data of candidates participating in any selection process or who consent to the processing of their data by LINK for future recruitment are stored in the selection process.

Personal Data of candidates/recruits is contained in: CV and attached documents – certificates, certificates of legal capacity, diplomas, photo (for identification during an interview), cover letter, references, previous experience; answers, solutions and results related to tests, case studies, assignments, exams, surveys/questionnaires, notes and/or interviews, and others.

Please note that the personal data we process about you may vary depending on local legal requirements and the specific processing we perform. We only process your personal data when we have a legitimate business reason or a legal obligation to do so.

The following table describes the main purposes of the processing and the types of data involved.

Processing activity	Legal basis	Data retention	Description
Recruitment process	Art. 6.1(a), (c) GDPR	During the duration of the selection process	LINK processes personal data of potential new employees (applicants, candidates) in accordance with local legislation. Information about potential new employees will be stored in Emply.
Recruitment – post-recruitment	Art. 6.1(a), (c) GDPR	Up to 36 months, depending on applicable law	LINK is processing personal data of prospective new employees (applicants, candidates) in accordance with local legislation if consent is given for future recruitment processes or as otherwise permitted by applicable law.

How do we protect Personal Data?

The protection of Personal Data is fundamental to LINK. Therefore, we work continuously to protect them. Our information security and personal data protection policy covers the protection of personnel, data, IT infrastructure, internal and public networks, as well as office buildings and technical facilities. The specific technical and organizational measures can be found in our Data Processing Agreement. We pay special attention to information such as Personal Data.

Our security efforts aim to balance risk exposure, business value, available technology, vulnerabilities, and threats to comply with applicable laws and regulations, as well as contractual requirements.

LINK strives to implement security measures by establishing appropriate levels of protection for Personal Data and thus preventing the disclosure of Personal Data to unauthorized parties, both externally and internally.

Our technical and organizational measures are described here: Security Policy | 360NRS

Who do we share data with?

LINK may disclose personal data to external providers and hosting partners that provide services to LINK, in order to deliver such services. The list of our data sub-processors can be found here. These external providers will only use the Personal Data for the purposes for which they were collected and to provide their services to LINK. The relationship with these external providers shall be governed by a Data Processing Agreement.

LINK may disclose the personal data of its business contacts and website visitors among all entities listed as affiliates within LINK. LINK also has affiliates located outside the EU/EEA area. Access to the personal data of subsidiaries is protected by the EU Standard Contractual Clauses signed between LINK Mobility Group and all its subsidiaries.

The disclosure of Personal Data to public authorities may occur if and to the extent required by current law and regulations.

How does LINK ensure the transfer to third countries in accordance with the requirements set out in EDPB Recommendations 01/2020?

Following the judgment of the Court of Justice of the European Union (“CJEU”) of July 16, 2020, Data Protection Commissioner v. Facebook Ireland LTD, Maximillian Schrems, C-311/18 (“Schrems II”), and the Recommendations 01/2020 of the European Data Protection Board (“EDPB”) adopted on November 10, 2020, the measures required for the transfer of personal data outside the European Economic Area (“EEA”) require a higher level of specificity and care by the entities responsible for such transfers to comply with the GDPR.

LINK Mobility implements the specified requirements according to the steps below: Step 1: At LINK Mobility we know our data transfers. LINK Mobility ensures, through its contracts with third parties and internal processes, that transfers to countries outside the EEA are not carried out without LINK Mobility’s knowledge and documentation of such transfer. Step 2: At LINK Mobility we verify the security of our data transfers. LINK Mobility does not rely on legacy safeguards for transfer (Privacy Shield and Safe Harbor). If any transfer is required, only the European Commission’s adequacy decisions and current safeguards apply, as set out in Article 46 of the GDPR. Step 3: Transfer according to the law of the country in question. The transfer is carried out only if the laws of the country in question, including the applicable supplementary measures, do not prevent processing in accordance with the applicable transfer requirements.

Contact information

If you are a direct customer of LINK, please contact our customer service. Our service can also assist you in getting in touch with LINK’s Data Protection Officer (DPO), Jan Wieczorkiewicz, at dpo@linkmobility.com.
If you are an end user of a LINK client, please contact the corresponding LINK client directly.
If you are not a direct customer of LINK and have received a message through its systems, please note that this could only occur on behalf of one of our customers. In that case, you should contact the sender of the message directly. Each LINK customer declares they have the right to process the personal data of the end users/recipients to whom the message is sent.
All external security investigations must send their findings to: compliance.es@linkmobility.com

Modification of this Privacy Statement

LINK reserves the right to modify this privacy statement. The most recent revision shall prevail over any previous version. The current version of the privacy notice will be available on the LINK website or may be requested at any time. We recommend that you review the privacy notice periodically to stay informed. We will notify you of any changes to the privacy notice that you are entitled to be informed of or that require your consent.

Last update of the privacy policy: December 10, 2024

Adaptation to Net Real Solutions S.L.U: July 15, 2025