Effective Date: September 17, 2026
Last Updated: September 17, 2026
Happy Whole Human Spain, S.L. (“HWH,” “we,” “us,” or “our”) is the data controller responsible for the personal data processed under this Policy.
Happy Whole Human Spain, S.L. is the sole legal entity operating the Happy Whole Human® ecosystem, including its services, platforms, assessments, applications, and websites.
By using HWH services, you acknowledge that you have read and understood this Privacy Policy.
This Privacy Policy applies to personal data collected through:
This Policy does not apply to third-party platforms or services that you may access separately (for example, external video, scheduling, or AI providers), which are governed by their own privacy policies.
We may collect the following categories of personal data.
We process personal data only where lawful and necessary, including to:
We do not sell personal data.
We process personal data in accordance with the EU General Data Protection Regulation (GDPR, Regulation 2016/679) and the Spanish Ley Orgánica 3/2018 de Protección de Datos Personales y garantía de los derechos digitales (LOPDGDD), relying on one or more of the following lawful bases:
Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
Coaching and assessment data are treated as confidential and handled in accordance with:
Individual coaching content and assessment results are not shared with employers, sponsors, or third parties unless:
For sponsored programs, only non-identifying administrative or aggregate information may be shared, as described in our Terms.
AI-enabled tools within HWH are used solely to support reflection, learning, and continuity. They do not replace human coaching or professional judgment.
AI interactions are subject to the same privacy and security protections as other platform data.
AI Training Clarification. Happy Whole Human® does not use identifiable personal data, including coaching conversations, assessment responses, session recordings, transcripts, or AI interactions, to train or fine-tune foundation artificial intelligence models or agents without explicit user consent.
Where fully anonymized and aggregated data is used to improve platform functionality, such data does not identify individual users and is processed in accordance with applicable law and ethical standards.
We may share personal data only with:
We do not share personal data for advertising purposes.
Service providers include secure cloud infrastructure, database, payment, monitoring, and AI vendors operating as data processors under contractual confidentiality and data protection obligations. A current list of primary processors is available on request.
We implement reasonable administrative, technical, and organizational safeguards to protect personal data against unauthorized access, loss, misuse, or disclosure. These include, among others, encrypted storage of conversation content and user memory at rest, access controls, and observability practices designed to avoid content leakage to external monitoring systems.
Personal data is retained in an encrypted, GDPR-compliant database as long as necessary to:
Users are encouraged to download or retain copies of content they wish to keep.
Under GDPR and LOPDGDD, and depending on your location, you have the right to:
Requests may be submitted to contact@happywholehuman.com. We will respond in accordance with applicable law, typically within one month of receipt.
HWH uses cookies and similar technologies to operate and improve our platforms. You may manage cookie preferences through your browser settings or through the cookie banner where applicable.
HWH services are intended for individuals 18 years of age or older. We do not knowingly collect personal data from minors.
Personal data is primarily processed within the European Economic Area (EEA), specifically in Spain. Some processing may occur in third countries, including the United States, where certain of our service providers operate (for example, our AI service provider).
Where personal data is transferred outside the EEA, we implement appropriate safeguards required by Chapter V of the GDPR, including:
You may request a copy of the safeguards applied to any specific transfer by contacting us at contact@happywholehuman.com.
You have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data infringes applicable data protection law.
The competent supervisory authority for Happy Whole Human Spain, S.L. is:
Agencia Española de Protección de Datos (AEPD) C/ Jorge Juan, 6, 28001 Madrid, Spain www.aepd.es
You may also contact the supervisory authority in your EU member state of residence, place of work, or place of the alleged infringement.
We may update this Privacy Policy from time to time. Material changes will be communicated via our website or direct notice where required. Continued use of HWH services after updates constitutes acceptance of the revised Policy.
Happy Whole Human Spain, S.L. Carrer del Bruc 5, #312, 08010 Barcelona, Spain NIF / VAT: ESB21889415 Email: contact@happywholehuman.com Website: www.happywholehuman.com