PRIVACY POLICY – PROPINDER

Last updated: 03/03/2026

This Privacy Policy explains how BAIX GAIA EDUCA, S.L. (“Propinder”, “we”, “us”, or “our”) collects, uses, and protects personal data when you access or use the Propinder website, survey, and related services (the “Platform”).

We process personal data in accordance with Regulation (EU) 2016/679 (GDPR), Organic Law 3/2018 (LOPDGDD), and applicable e-privacy and marketing regulations.

If you do not agree with this Privacy Policy, you must not use the Platform.

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1. DATA CONTROLLER

Controller: BAIX GAIA EDUCA, S.L.
Tax ID: B75637835
Registered address:
PS Taulat 229, Esc. D, 2º–4ª
08019 Barcelona, Spain

📩 admin@propinder.com

2. PERSONAL DATA WE COLLECT

2.1 Data you provide directly

• Email address
• Account and login information
• Discord ID number in case the user uses the Discord Social Login
• Responses to the profiling survey (preferences, constraints, parameters)
• Information voluntarily added to your user profile
• Communications you send to us (support, feedback)

2.2 Data collected automatically

• IP address
• Device, browser, and operating system information
• Usage and interaction data (pages visited, clicks, session duration, referrers)
• Cookies and similar identifiers (see Section 7)

2.3 Email interaction data

When we send emails, we may process:

• Delivery status
• Opens and clicks (where supported by the email client)
• Subscription and opt-out preferences

3. PURPOSES OF PROCESSING

We process personal data only for specific, explicit, and legitimate purposes:

3.1 Platform operation

• Creating and managing user accounts
• Storing and displaying survey responses and profiles
• Providing access to Platform features and content

3.2 Profiling for informational purposes (“users like you”)

We may process survey responses and limited usage data to generate descriptive, non-binding informational outputs, such as:

“Challenges commonly explored or selected by users with similar parameters.”

This profiling:

• Is informational only
• Does not constitute financial or investment advice
• Does not assess suitability
• Does not predict or guarantee success, acceptance, payouts, or performance
• Does not produce legal or similarly significant effects

3.3 Email communications

We may send emails relating to:

• Platform updates and service information
• Informational content derived from aggregated user patterns, including profiling-based insights
• Commercial Campaigns

These emails are not recommendations and not financial advice.
You may unsubscribe from non-essential communications at any time.

3.4 Analytics, improvement, and security

• Measure Platform usage and performance
• Improve features and user experience
• Detect, prevent, and mitigate fraud, abuse, and security incidents

4. LEGAL BASES FOR PROCESSING

We rely on the following legal bases under GDPR:

4.1 Performance of a contract (Article 6(1)(b))

Processing necessary to provide the Platform and its requested features (accounts, surveys, profiles).

4.2 Consent (Article 6(1)(a))

Where required by law, including for:

• Non-essential cookies and tracking technologies
• Profiling-based informational emails and newsletters

Consent may be withdrawn at any time.

4.3 Legitimate interests (Article 6(1)(f))

For:

• Essential Platform security
• Fraud and abuse prevention
• Service integrity and technical operations

You may object to processing based on legitimate interests.

5. PROFILING & AUTOMATED DECISION-MAKING

5.1 Profiling

Propinder performs limited profiling based on user-provided survey data and aggregated patterns.

Safeguards:

• No use of special categories of personal data (Article 9 GDPR)
• No scoring, ranking, or eligibility assessment
• No disclosure of individual profiles to third parties

5.2 No automated decision-making

Propinder does not carry out automated decision-making within the meaning of Article 22 GDPR.

Profiling outputs:

• Do not approve or reject users
• Do not affect access to services
• Do not determine contractual outcomes

6. AGGREGATED AND ANONYMIZED INSIGHTS

Propinder may aggregate and analyze data collected through the Platform to generate statistical, analytical, and market-level insights regarding general trends and patterns (for example, reports or publications).

Before any use or disclosure:

• Data is aggregated and anonymized
• All direct and indirect identifiers are removed
• Individual-level data is irreversibly excluded
• Re-identification of users is not reasonably possible

Once anonymized, such data no longer constitutes personal data under applicable data protection laws.

Propinder may use, publish, share, or commercialize these anonymized and aggregated insights (including in paid reports or PDFs), provided that no individual user can be identified or inferred.

7. COOKIES, ANALYTICS & SESSION RECORDING

7.1 Consent management

We use a cookie banner implementing Google Consent Mode to manage user preferences.

• Essential cookies may be used without consent
• Analytics and session-recording tools run only where legally permitted and consented

7.2 Analytics

We use analytics tools to understand aggregated usage patterns and improve the Platform.
Analytics cookies are treated as non-essential and require consent where applicable.

7.4 Managing cookies

Users may manage or withdraw cookie consent via:

• The cookie banner/settings
• Browser settings (blocking or deleting cookies)

Disabling cookies may affect some Platform functionality.

8. EMAIL SERVICES (Beehiiv and SendX)

We use Beehiiv and SendX to manage email communications processes:

• Email addresses
• Campaign delivery and engagement data

Both services act as a data processor under contractual safeguards and processes data only on our instructions.

9. DATA SHARING

We do not sell personal data.

We may share data with trusted service providers acting as data processors, including:

• Hosting and infrastructure providers
• Beehiiv and SendX
• Analytics providers: PostHog
• Security and anti-abuse services

We do not share individual survey or profile data with Prop Firms for their own purposes.

10. INTERNATIONAL DATA TRANSFERS

Some service providers may process data outside the European Economic Area (EEA), including in the United States.

Where applicable, transfers are protected by:

• Standard Contractual Clauses (SCCs)
• Supplementary safeguards as required by law

11. DATA RETENTION

Personal data is retained only as long as necessary for the purposes described:

• Account and profile data: while the account is active and for a limited period thereafter
• Email subscription data: until you unsubscribe or request deletion
• Analytics and session data: limited retention aligned with minimization principles

Certain data may be retained in a blocked form to comply with legal obligations or to defend legal claims.

12. YOUR RIGHTS

You have the right to:

• Access your personal data
• Rectify inaccurate data
• Request erasure
• Restrict processing
• Object to processing (including profiling)
• Data portability (where applicable)
• Withdraw consent at any time
• Lodge a complaint with the Spanish Data Protection Agency (AEPD)

Requests can be made to admin@propinder.com.
We may request identity verification.

13. SECURITY

We implement appropriate technical and organizational measures to protect personal data. However, no system is completely secure.

14. MINORS

The Platform is not intended for users under 18 years of age. We do not knowingly collect data from minors.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Updates will be published on the Platform and take effect upon publication.

16. CONTACT

📩 admin@propinder.com