Privacy Policy

1. Data controller

FHORT MANAGEMENT, S.L. (hereinafter, "FHORT"), with tax ID (NIF) B01623776 and registered office at Carrer Salmerón, 165, 08222 Terrassa (Barcelona), Spain, registered with the Barcelona Commercial Registry, Volume 47359, Folio 23, Sheet 549568, Entry 1, is the controller of the personal data processing described in this Policy.

Privacy contact: hello@fhorttextile.tech · Phone: +34 618 191 220.

2. Scope

This Policy applies to personal data processed by FHORT as controller in connection with the corporate website — including its contact form — and the FHORT Textile Tech SaaS platform ("FTT"), including user accounts, contracting, billing, support, security and commercial relationships.

It does not govern personal data that customers enter into their own tenants where they determine the purposes and means of the processing. In those cases, the customer generally acts as controller and FHORT as processor, in accordance with the applicable Data Processing Agreement ("DPA").

3. Personal data we process

• Website contact form data: name, company, email address, message, language, the page from which the enquiry is sent, IP address, date and time of submission, and the version of this Policy accepted at that time.
• Account and professional profile data: first name, surname, professional email address, job title, company, role, internal identifiers, preferences and the data needed to manage authentication.
• Usage and security data: IP address, date and time, device, authentication events, activity, and technical, audit and security logs.
• Contracting and billing data: company name, NIF/VAT number, address, contact person, contracted plan, billable usage, invoices, payments and non-payments.
• B2B commercial data: name, job title, company, professional email and phone, source of the contact, relationship history, opportunities and commercial preferences.
• Support data: enquiries, incidents, communications and files provided to resolve a request.
• Browsing data: IP, cookies, identifiers and browsing data where technologies governed by the Cookie Policy are used.

FHORT does not request special categories of data under Article 9 GDPR for its ordinary purposes as controller. Please do not include this kind of data in the message field of the contact form. FTT is not directed at minors.

4. Purposes and legal bases

FHORT may process data for the following purposes:

• Replying to enquiries received through the website contact form and following up on the request: steps taken at the request of the data subject prior to entering into a contract, and FHORT's legitimate interest in handling professional enquiries.
• Creating, administering and authenticating accounts and providing the Service: performance of the contract or pre-contractual steps.
• Managing contracting, billing, collections, usage and non-payments: performance of the contract and compliance with legal obligations.
• Preventing fraud, abuse and unauthorised access, and protecting the Platform and the website: FHORT's legitimate interest and compliance with legal security obligations.
• Handling enquiries, incidents and support: performance of the contract and legitimate interest in managing the Service properly.
• Managing B2B commercial relationships and opportunities: pre-contractual steps, contractual relationship or legitimate interest, depending on the specific processing.
• Sending promotional electronic communications: where they have been requested or authorised, or where an applicable legal exception exists.
• Operating the website and using measurement technologies: legitimate interest for strictly necessary elements, and consent where the law requires it.

Where FHORT relies on a legitimate interest, it will carry out the corresponding balancing test where necessary and will respect the right to object.

Submitting the contact form does not subscribe you to any promotional mailing list.

5. Data entered by customers into FTT

Customers may enter into their tenants patterns, technical sheets, POMs, measurements, size charts, images, fitting photographs, documents, comments, CAD/DXF files and other content related to the industrialisation of textile products.

Where such content includes personal data and the customer determines the purposes and means, the customer is the controller and FHORT acts as processor. The customer must have a valid legal basis and, where applicable, the necessary authorisations or consents, including image rights.

FHORT does not generally verify the lawfulness of each item of content uploaded by customers and will process it following the customer's documented instructions and the terms of the DPA.

6. Artificial intelligence and automation

FTT may use artificial intelligence systems for extraction, structuring, classification, matching, consistency auditing, assistance, proposal generation and automation of technical content.

By default, FHORT will not use customer content to train general-purpose models, whether its own or third parties'. Where external providers are involved in processing personal data to deliver these functions, they will be managed in accordance with the DPA, the obligations applicable to sub-processors and, where relevant, the rules on international transfers.

AI outputs may contain errors and require professional review. In its ordinary operation, FTT is not intended to take solely automated decisions that produce legal effects or similarly significantly affect individuals.

Enquiries received through the website contact form are not subject to automated decision-making.

7. Recipients and providers

FHORT may allow access to personal data to providers needed to deliver and maintain the Service and the website, including providers of hosting and infrastructure, email and domain services, payments, communications, support, security, artificial intelligence, professional advice and technology services.

Providers processing data on FHORT's behalf are subject to the corresponding contractual obligations. The current list of sub-processors applicable to tenant content is kept up to date in the relevant documentation.

FHORT does not sell personal data. Data may be disclosed to authorities, courts or public bodies where there is a legal obligation or a valid request.

8. International transfers

Where a provider processes personal data outside the European Economic Area, FHORT will rely on a valid mechanism under Chapter V GDPR, such as an adequacy decision, Standard Contractual Clauses or other recognised safeguards, and will adopt supplementary measures where necessary.

9. Retention

Data is kept only for as long as necessary to fulfil the purpose for which it was collected and, afterwards, for the periods needed to meet legal obligations and address potential liabilities.

• Enquiries received through the contact form: up to twenty-four (24) months from the last contact, unless the enquiry leads to an ongoing contractual or commercial relationship, or the person requests erasure earlier.
• Account and contractual relationship data: for the duration of the relationship and any applicable legal periods thereafter.
• Billing and payment data: for the legally required tax, accounting and commercial periods.
• Commercial data: for as long as there is a relationship or legitimate purpose, and until objection or unsubscription where applicable.
• Support and security data: for as long as necessary to resolve incidents, protect systems and address liabilities.
• Cookies and similar technologies: in accordance with the Cookie Policy, where applicable.

10. End of the Service and Tenant data

When the contract ends, the Tenant will have a recovery period of thirty (30) calendar days during which the customer may request the export or recovery of its data in accordance with the General Terms and the DPA.

After those thirty (30) days, FHORT may delete or anonymise the data in the operational environment, unless there is a legal obligation, a valid instruction under the DPA or a different written agreement.

Data may temporarily remain in rotating backups until overwritten in accordance with the technical configuration in force. During that period it will not be used for ordinary purposes and may only be restored for continuity, disaster recovery, security or legal obligation reasons.

11. Security

FHORT applies technical and organisational measures appropriate to the risk and the nature of the Service. These may include logical isolation per Tenant through dedicated schemas, authentication and access control by roles and capabilities, encrypted communications, minimisation of internal access, secrets and credentials management, backups, event logging and monitoring, and incident management procedures.

Measures will be reviewed and will evolve in line with risk, architecture, the state of the art and the evolution of FTT.

12. Your rights

Data subjects may exercise, where applicable, the rights of access, rectification, erasure, objection, restriction and portability, as well as withdraw consent without affecting the lawfulness of prior processing.

Requests may be sent to hello@fhorttextile.tech or to FHORT's registered office. FHORT may request reasonable additional information to verify the identity of the person making the request and will reply within a maximum of one month, extendable under the terms of the GDPR.

A complaint may also be lodged with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es).

Where a request concerns data that FHORT processes exclusively as processor within a customer's Tenant, FHORT may forward it to the customer acting as controller or assist the customer in accordance with the DPA.

13. Commercial communications

FHORT will only send advertising or promotional communications by email or equivalent electronic means where they have been requested or authorised, or where an applicable legal exception exists, including, where relevant, a prior contractual relationship regarding similar products or services of its own.

Communications will identify the sender and, where required, offer a simple and free way to object or unsubscribe. The legitimate interest in maintaining a B2B commercial relationship will not be used on its own as the basis for promotional electronic communications where the law requires consent or another specific authorisation.

14. Minors

FTT is intended for companies, professionals and organisations and is not directed at minors. FHORT does not foresee the creation of user accounts by minors or the intentional processing of their data as users of the Platform.

15. Data Protection Officer

FHORT has not currently appointed a Data Protection Officer. The need or advisability of appointing one will be reviewed in light of the nature, scope, context and scale of the processing and the applicable regulations.

16. Corporate reorganisations

The FHORT Textile Tech business may in the future be subject to a corporate reorganisation, including its contribution or transfer to a group company, subsidiary, a company receiving a line of business, a successor to the business or an acquirer of FTT.

If such a reorganisation involves a change in the identity of the controller or a disclosure of data requiring specific information, FHORT will inform the persons affected and will update this Policy and the contractual documentation in accordance with the applicable regulations. The mere prospect of a future reorganisation does not currently entail a change of controller.

17. Changes to this Policy

FHORT may update this Policy to reflect regulatory, technical or corporate changes, or changes in its practices. Where changes are substantial and it is required, they will be communicated by email, by notice on the Platform or through another appropriate channel before they take effect.

18. Contact

19. Related documents

• General Terms of the SaaS Service.
• Data Processing Agreement (DPA).
• Cookie Policy.
• List of Sub-processors.
• Security documentation applicable to the Service.

20. Version

Version 1.0 — 21 September 2026. Canonical language: Spanish. This English version is a translation provided for information; in the event of any discrepancy, the Spanish version prevails.

FHORT MANAGEMENT, S.L. · FHORT Textile Tech · Privacy Policy