Legal information

Privacy Policy

Last updated: 18 May 2026 Version: 2.1

Who is the data controller of this website?

Data Protection Officer (DPO)

RICARDO ALFONSO NOVO NOVO is not legally required to designate a Data Protection Officer under article 37 of the GDPR, as none of the circumstances set out in that article apply. Nevertheless, for any matter related to personal data protection, you can contact the controller directly at legal@4linking.com.

What personal data is collected on this website and in the plugin?

For the purposes set out in this Privacy Policy, RICARDO ALFONSO NOVO NOVO collects and processes the personal data detailed below, which will depend on the different products or services requested on this Website or in the 4Linking plugin:

Data collected through the website www.4linking.com

• Identification data: name, surname.
• Contact data: postal address, email address, mobile phone number.
• Contract data: contractual transaction data, national ID, products and services purchased, financial transactions, payment data.
• Browsing data: IP address, device type and identification, browser type, domain through which you access the Website, browsing data, activity on the Website.

Data processed through the 4Linking plugin

The 4Linking plugin is software that the customer installs on their own WordPress site. Therefore, the data of the customer's end users (visitors to the customer's website) is NOT stored on servers belonging to RICARDO ALFONSO NOVO NOVO. The plugin operates under a "Bring Your Own Key" (BYOK) model, described below.

The data processed by the plugin is:

• Plugin license key, associated with the site where it is activated.
• URL of the site where the plugin is activated, for license validation purposes.
• Text content of articles, knowledge base entries, prompts and templates that the customer voluntarily chooses to process using artificial intelligence features.

This data is NEVER transmitted to servers belonging to RICARDO ALFONSO NOVO NOVO. License validation is performed through a technical service (Easy Digital Downloads) and transmission to OpenAI occurs directly from the customer's server, without our intermediation.

On what legal basis is this data processed?

We process your personal data on the following legal bases:

• The performance of a contract with RICARDO ALFONSO NOVO NOVO, for the provision of services and/or products and the management of the requested services.
• The user's consent regarding contact, content subscription and the sending of commercial communications, by email, cookies or messaging systems.
• The legitimate interest of the data controller to protect the users of the RICARDO ALFONSO NOVO NOVO website from abuse and fraud in the use of our services.
• Compliance with applicable legal obligations (tax, accounting, anti-money laundering).

For what purposes will your data be processed?

This website may contain different forms. In each of them, the information collected will be used as follows:

Contact form: in forms for queries, suggestions or professional contact, the email address will be used to respond to them and send the information the user requests through the website.

Content subscription form (newsletter): the data provided will be used exclusively to activate the subscription, send the newsletter and keep you updated on news and occasional offers, exclusive to our subscribers. The technical delivery of emails is carried out through Mailchimp (more information in the recipients section).

Comments form: the personal data entered in the form to add these comments will be used exclusively to moderate and publish them.

Registration form: we will request your personal data so you can create an account in our system and access its features, including the management of your 4Linking plugin licenses.

Sales form: we will process your data to manage the purchase of our products and/or services, including order management, payment, generation of the plugin license and all operations related to the contract. This includes sending follow-up emails, responses, invoices, receipts and technical notifications regarding the license (renewal, expiration, etc.).

How the 4Linking plugin works and integration with artificial intelligence services

This section describes how the 4Linking plugin works in relation to third-party artificial intelligence services and what implications it has for your data.

BYOK model (Bring Your Own Key)

The 4Linking plugin operates under a model known as BYOK ("Bring Your Own Key"). This means that the plugin's artificial intelligence features are executed using a personal OpenAI API key provided by the customer themselves.

Practical implications of this model:

• The customer contracts AI services directly with OpenAI. The invoice for AI usage is issued in the customer's name, not in RICARDO ALFONSO NOVO NOVO's name.
• Communications with OpenAI servers are carried out directly from the server where the customer has WordPress installed, without intermediation by RICARDO ALFONSO NOVO NOVO.
• RICARDO ALFONSO NOVO NOVO has no technical access to the content processed by the artificial intelligence, nor does it store any copy of such content.
• The customer's OpenAI API key is stored exclusively in the customer's own WordPress database, on their server.

Data transfer to OpenAI

When the customer uses the plugin's artificial intelligence features (content generation, image generation, translation, semantic analysis and knowledge base processing), the textual content selected by the customer is sent to the servers of OpenAI, L.L.C. (a US company with registered office at 3180 18th Street, San Francisco, CA 94110, United States) for processing.

The data transferred may include:

• Text of the articles the customer wishes to generate, translate or link.
• Content of the knowledge base entries created by the customer.
• Documents (PDF, DOCX, TXT) that the customer voluntarily uploads to the plugin.
• URLs and content extracted from websites indicated by the customer.
• Instructions or "prompts" entered by the customer.

International data transfer

OpenAI processes data on servers located in the United States. This international transfer outside the European Economic Area (EEA) is covered by:

• The Standard Contractual Clauses (SCC) approved by the European Commission in accordance with art. 46.2.c) of the GDPR, signed by OpenAI.
• OpenAI's data processing policy, available at openai.com/policies/privacy-policy/.
• The technical and contractual safeguards that OpenAI publishes at openai.com/policies/data-processing-addendum/.

By activating the plugin's artificial intelligence features, the customer declares that they are aware of and accept this international transfer and states that they have read OpenAI's privacy policy.

Customer's responsibility for processed content

The customer is solely responsible for the content they choose to process through the plugin. RICARDO ALFONSO NOVO NOVO recommends that the customer:

• Does not enter into the plugin personal data of third parties without having previously obtained adequate consent or without having a legitimate basis for processing it.
• Does not process through artificial intelligence especially sensitive data (health, ideology, racial origin, sexual orientation, etc.) unless the customer has a clear legal basis to do so and has implemented the additional measures required by the GDPR for special categories of data.
• Reviews content generated by the artificial intelligence before publishing it, since AI may produce inaccurate, biased information or information that infringes third-party rights.
• Informs their own users and visitors (where applicable) that their site uses artificial intelligence to process content.

Relationship between RICARDO ALFONSO NOVO NOVO and the plugin customer

With regard to the use of the 4Linking plugin by a customer who installs it on their website, responsibilities are as follows:

• RICARDO ALFONSO NOVO NOVO acts as software provider. It is neither data controller nor data processor with respect to the data the customer processes through the plugin, since it has no technical access to such data.
• The customer is the data controller with respect to the data of their own visitors and subscribers.
• OpenAI acts as data processor for the customer when the latter uses the artificial intelligence features, under the terms of its Data Processing Addendum.
• If the customer is in turn a service provider to third parties (SEO agency, marketing company, etc.), it is the customer's responsibility to sign the necessary data processor agreements with their own end customers.

Personal data retention period

The personal data provided will be kept for the shortest possible time taking into account the reasons why data processing is needed, as well as legal obligations to retain data for a certain time, such as labour, tax or anti-fraud legislation that require the retention of personal data for a defined period or for as long as the data subject does not withdraw their consent.

Subsequently, the data will be deleted in accordance with the provisions of data protection regulations, which involves blocking, being available only at the request of Judges and Courts, the Public Prosecutor's Office or the competent Public Administrations during the limitation period of the actions that may arise and, once this has elapsed, they will be deleted completely.

Specific retention periods by type of data

Customer data: the retention period for personal data will vary depending on the service contracted by the customer. In any case, it will be the minimum necessary, and may be kept for up to:

• 4 years: Arts. 66 et seq. of the Spanish General Tax Law (accounting books).
• 5 years: Art. 1964 of the Spanish Civil Code (personal actions without special term).
• 6 years: Art. 30 of the Spanish Commercial Code (accounting books, invoices).
• 10 years: Art. 25 of the Spanish Law on the Prevention of Money Laundering and Terrorist Financing.

Subscriber or registration data: from when the user gives their consent until they withdraw it.

Plugin license data: kept while the license is active. After cancellation or final expiration (without renewal), the data is kept for 6 years to comply with accounting and tax obligations, and is subsequently deleted.

Browsing and analytics data: data collected through web analytics tools is kept according to each provider's policies, generally between 14 and 26 months.

To which recipients will your data be communicated?

To carry out certain tasks strictly necessary for the development of the activity, RICARDO ALFONSO NOVO NOVO shares personal data with the following data processors, all of whom have signed or are subject to the legal agreements required by the GDPR:

All these processors have signed a service provision agreement that obliges them to maintain the same level of privacy that applies to the processing carried out on this website in accordance with current data protection regulations. RICARDO ALFONSO NOVO NOVO has verified the existence of adequate safeguards for international transfers outside the EEA, in accordance with art. 44 et seq. of the GDPR.

Beyond these processors, RICARDO ALFONSO NOVO NOVO does not transfer personal data to third parties for its own commercial purposes, except:

• When there is a legal obligation (Public Administrations, Judges and Courts, Public Prosecutor's Office, Security Forces).
• When the data subject gives their express consent.

What are your rights regarding the use of your data?

Anyone has the right to obtain confirmation as to whether RICARDO ALFONSO NOVO NOVO is processing personal data concerning them.

Interested persons have the right to:

• Request access to the personal data relating to the data subject.
• Request its rectification or erasure.
• Request its cancellation.
• Request the restriction of its processing.
• Object to the processing.
• Request data portability.
• Withdraw consent given, without affecting the lawfulness of processing based on consent prior to its withdrawal.
• Not to be subject to automated individual decision-making, including profiling.

If you have given your consent for a specific purpose, you have the right to withdraw the consent given at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.

If you feel that your rights regarding the protection of your personal data have been infringed, especially when you have not obtained satisfaction in the exercise of your rights, you may lodge a complaint with the Supervisory Authority for Data Protection. In Spain, this authority is the Spanish Data Protection Agency (AEPD).

To exercise these rights, you can write to legal@4linking.com. Forms can also be submitted in person or sent by post to the controller's contact addresses indicated above.

If you act through legal representation, you must also provide a national ID document and a document proving the representative's authority.

It will be necessary to provide a copy of the national ID or equivalent document proving identity and considered legally valid, in those cases where the data controller has doubts about your identity.

Notification and reporting of data breaches

At RICARDO ALFONSO NOVO NOVO we adopt security measures appropriate to the level of risk to protect personal information against loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of the personal information.

However, if RICARDO ALFONSO NOVO NOVO determines that the personal data it processes has been misappropriated, exposed by a security breach or improperly acquired by a third party, RICARDO ALFONSO NOVO NOVO will act in accordance with the GDPR:

• It will notify the breach to the competent Supervisory Authority (AEPD) within a maximum period of 72 hours from becoming aware of it.
• If the breach poses a high risk to the rights and freedoms of those affected, it will communicate the incident directly to the affected persons without undue delay.
• It will take all reasonable technical and organisational measures to mitigate the effects of the breach and prevent recurrence.

Secrecy and security of data

RICARDO ALFONSO NOVO NOVO undertakes to use and process the user's personal data, respecting its confidentiality, in accordance with the purpose thereof; as well as to comply with its obligation to safeguard them and adopt all measures to prevent alteration, loss, unauthorised processing or access, in accordance with the provisions of current data protection regulations.

RICARDO ALFONSO NOVO NOVO cannot guarantee the absolute impregnability of the Internet, nor, therefore, the breach of data through fraudulent access to it by third parties.

With regard to the confidentiality of processing, RICARDO ALFONSO NOVO NOVO will ensure that any person authorised by RICARDO ALFONSO NOVO NOVO to process customer data (including its staff, collaborators and service providers) is under a duly applicable obligation of confidentiality (whether a contractual or legal duty).

Specific technical and organisational measures

Without prejudice to continuous improvement, the security measures currently applied include:

• TLS (HTTPS) encryption in all communications between the user's browser and the www.4linking.com site.
• Password storage using one-way hash functions with salt.
• Regular backups of the database and the website.
• Regular security updates of the base software (WordPress, plugins, server operating system).
• Security audits of the 4Linking plugin code prior to each release.
• Restricted access to the administration panel through two-factor authentication when available.
• Least-privilege policy for external collaborators.

Accuracy and truthfulness of data

As a user, you are solely responsible for the truthfulness and correctness of the data you submit to us, exempting RICARDO ALFONSO NOVO NOVO from any liability in this regard. Users warrant and are liable, in any case, for the accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated.

Personal data of third parties

In the event that the personal data provided belongs to a third party, as a user you warrant that you have informed said third party of this Privacy Policy and have obtained their authorisation to provide their data to RICARDO ALFONSO NOVO NOVO for the indicated purposes. You also warrant that the data provided is accurate and up to date, being liable for any direct or indirect damage that may arise as a result of breach of this obligation.

This clause is especially relevant in the case of the 4Linking plugin, since the customer may enter into the plugin content that includes personal data of third parties (for example, when uploading a PDF with employee information, or when generating content about identifiable persons). In these cases, the customer must ensure they have the appropriate legal basis for such processing, in accordance with art. 6 of the GDPR.

Automated decisions and artificial intelligence

RICARDO ALFONSO NOVO NOVO does not make automated individual decisions, including profiling, about website users or plugin customers, within the meaning of article 22 of the GDPR.

The use of artificial intelligence within the 4Linking plugin is a tool to assist the customer in generating and processing content. It does not produce legal effects nor significantly affect the end user of the customer's website. In any case, the customer is responsible for reviewing and approving the content generated by the AI before publishing it.

Data of minors

The services provided through www.4linking.com and the 4Linking plugin are intended exclusively for adults. RICARDO ALFONSO NOVO NOVO does not intentionally collect or process data from children under 14 years of age. If you become aware that a child under 14 years of age has provided us with personal data without the consent of their parents or legal guardians, please contact us to proceed with its immediate deletion.

Cookie policy

This website uses technical cookies necessary for its operation and Google Analytics analytical cookies. Analytical cookies are not loaded until the user gives express consent through the cookie banner that appears when accessing the site for the first time.

For more information on the specific type of cookies used, their purpose and retention periods, please refer to our Cookie Policy. The Cookie Policy forms an integral part of this Privacy Policy.

Changes to the Privacy Policy

RICARDO ALFONSO NOVO NOVO reserves the right to modify this policy to adapt it to legislative or jurisprudential developments, as well as to industry practices. In such cases, the changes introduced will be announced on this page with reasonable notice before their implementation.

When the changes are substantial (affecting the purposes of processing, the legal basis, the recipients or the user's rights), RICARDO ALFONSO NOVO NOVO will again seek the user's consent where appropriate and will communicate the changes by proportionate means (prominent notice on the website, email communication to registered customers, etc.).

We recommend that you review this policy periodically. The date of the last update appears at the beginning of the document.

Additional information on data protection

If you need additional information on data protection, you can send us an email to legal@4linking.com or a communication addressed to Calle XECA, 6, 15174 Vigovidin (San Xian De Almeiras-Culleredo), A Coruña, Spain and, depending on the type of relationship you have with our entity and the processing of personal data we carry out, we will provide you with the appropriate additional information.