DRAFT — not legal advice — review by a solicitor before use

Hopwall: Privacy Notice

This notice explains what data Trendiing Ltd (company 14895321), trading as Hopwall ("we", "us"), handles when an agency uses the Service, when someone visits our website, and when someone visits a link page served on an agency's domain. It describes what the software actually does today.

1. Visitors to link pages (agency domains)

1.1 When someone opens a link page, we record aggregated click analytics only:

the step of the page the visit reached (view, gate, click out) and the time;
the platform or app the visit came from (for example Instagram, TikTok or X), worked out from the browser's user agent;
device type (iPhone, Android or desktop);
country, worked out by Cloudflare from the connection;
network number (ASN) and its operator name, used to tell automated crawlers from people;
the first 80 characters of the referring address, where the app sends one;
for Instagram's in-app browser, the app version.

1.2 The analytics store no IP addresses, no cookies and no identifier for the visitor. Link pages set no cookies. The Instagram escape page keeps one temporary flag in the browser's session storage so a visitor is not sent round in a loop; it is deleted when the tab closes and never leaves the device.

1.3 We do not build profiles of individual visitors, and we do not sell or share visitor data for advertising.

1.4 For link-visitor analytics the agency is the controller and we are its processor. The terms are in our draft Data Processing Agreement.

1.5 Avatar images. An agency can upload its creator's avatar, or give the address of an image hosted on another site. We fetch a linked image once, from our servers, when the agency saves it, and store it like an upload. Link pages show only that stored copy, from the link page's own domain, so a visitor's browser never contacts the site the image came from: that site sees only our server's request when the agency saves the address, and nothing about visitors. Link pages also tell the browser to load images from nowhere else.

2. Agencies (portal users)

2.1 For agency accounts we hold: the account email and name; the creators, domains and destination links the agency adds; each creator's page settings (display name, tagline, button label, accent colour, avatar); the agency's reporting time zone; billing status; and an audit log of sign-ins, security changes, domain changes, skin changes and billing events, which the agency can see in the portal.

2.2 Sign-in. We email one-time sign-in links. Links, session identifiers and two-step recovery codes are stored only as one-way hashes. If an agency turns on two-step sign-in, we hold the authenticator secret so we can check codes.

2.3 Security and abuse prevention. To limit sign-in abuse we count requests per salted hash of the IP address and of the email address, for about a minute. Cloudflare Turnstile checks that the sign-in form is used by a person; Cloudflare receives the visitor's IP address and browser signals for that check. When an agency signs up we keep a salted hash of the sign-up IP address, used only to detect self-referral under the referral programme.

2.4 Payments are handled by Stripe. We do not store card numbers. For the referral programme we compare a hash of the card fingerprint Stripe provides, only to detect self-referral.

2.5 Email is sent through Resend.

2.6 We use this data to run the Service, send sign-in links and alerts, bill the account, run the referral programme and keep the Service secure. We are the controller for agency account data under UK GDPR. Lawful bases: performance of our contract with the agency, and our legitimate interest in keeping the Service secure and free from fraud.

2.7 Service logs. Our servers keep diagnostic log lines (for example "lockout alert not sent", or a scheduled job's counts) for up to 7 days (3 days at present) so we can find faults. A log line never contains an IP address, a link destination, a sign-in link or any other secret, and an email address in one is shortened to its first character and domain (for example a***@example.com). Logs do not record the web addresses visitors or agencies request.

3. Our website and portal

3.1 The marketing website (hopwall.com) sets no cookies and runs no analytics or advertising tags.

3.2 The portal (app.hopwall.com) sets one strictly necessary cookie, __Host-hw_session, only after you sign in. It keeps you signed in for up to 12 hours of inactivity and at most 30 days, and is deleted when you log out.

3.3 If you press the light/dark switch, your choice is saved in your browser's local storage (hw-theme). It is set only when you press the switch, stays on your device and is never sent to us.

3.4 Our website and portal load nothing from third-party font or file services. The fonts and the portal's reporting map files are served from our own site, hosted by Cloudflare (section 4), so no other provider receives your IP address when one of these pages loads. The one exception is the Cloudflare Turnstile check on the portal's sign-in page (section 2.3). The portal's link-page preview shows the avatar's stored copy (an upload, or a linked image we fetched when it was saved) and never loads an image from another site. Link pages on agency domains are covered in 1.5. More detail is in our Cookie Statement.

4. Where data is processed

We use Cloudflare (hosting, storage, analytics, Turnstile), Stripe (payments) and Resend (email). Some of these process data outside the UK. [Solicitor to confirm: international transfer mechanism and the full subprocessor list.]

5. Retention

5.1 An agency can download all its account data as JSON from the portal at any time, and can delete its account from the portal. Deletion removes its creators, domains, link pages, avatars, sessions and audit log at once and cancels billing. We keep only the Stripe customer reference needed to find invoices Stripe holds for UK record-keeping (normally six years), and referral credit records needed for accounting.

5.2 Sign-in links expire after 15 minutes. Sessions end after 12 hours idle or 30 days. [Solicitor/commercial to confirm retention periods for click analytics.]

6. Your rights

You can ask for access to, correction of or deletion of personal data we hold about you, and you can complain to the Information Commissioner's Office. Contact hello@hopwall.com. Link-page visitors should contact the agency that runs the link; we will help it respond.

Trendiing Ltd (company 14895321), trading as Hopwall.