Privacy Policy
This is an informative English translation of the Spanish original. If there is any discrepancy, the Spanish version prevails.
Data in the EU
europe-west1
Encryption
Encryption at rest
Privacy · DPO
dpo@tributai.es
GCP
Google Cloud
Data we collect
Identification data
- Full name
- DNI/NIE
- Phone
- Address
Purpose: Identification and communication
Tax data
- Tax ID (NIF)
- Economic activity (CNAE/IAE)
- Tax address
- Contribution base
Purpose: Processing of registrations and tax returns
Financial data
- Bank IBAN
- Billing data
- Payment method
Purpose: Management of payments and invoicing
Browsing data
- IP
- Cookies
- Device
- Browser
Purpose: Service improvement and security
Index
1Data Controller
The controller of your personal data is:
TRIBUTAI SOLUTIONS, SOCIEDAD LIMITADA
Tax ID (CIF): B88695895
Address: CL. General Vives, 56, 2 Pta. D, Oficina 201, 35007 Las Palmas de Gran Canaria
Data Protection Officer (DPO), to exercise your GDPR rights (Art. 15-22) and for privacy queries: dpo@tributai.es
Any other query: soporte@tributai.es
TRIBUTAI has appointed an external and independent Data Protection Officer (DPO), the firm LetsLaw, which oversees the processing of personal data. You can contact the DPO at the mailbox dpo@tributai.es, which is only for data protection. For everything else, write to soporte@tributai.es.
To exercise any of the rights recognised by the GDPR (access, rectification, erasure, restriction, portability, objection, not to be subject to automated decisions — Art. 22), write to the DPO at dpo@tributai.es or use the form at /data-rights. We will reply within a maximum of one month (Art. 12 GDPR).
2Legal Basis for Processing
The processing of your data is based on the following legal bases provided for in article 6 of the GDPR:
- Performance of a contract (Art. 6.1.b): Your data is necessary to provide you with the contracted services.
- Compliance with legal obligations (Art. 6.1.c): We must keep certain data because of tax and commercial obligations.
- Legitimate interest (Art. 6.1.f): To improve the service, for security and to prevent fraud.
- Consent (Art. 6.1.a): For commercial communications and non-essential cookies.
3Purposes of Processing
We process your personal data for the following purposes:
- User account management: Creating and maintaining your account on the Platform.
- Provision of services: Processing registrations, tax returns and the other contracted services.
- Invoicing and payments: Managing payments for the contracted services.
- Service communications: Sending you relevant information about your account and services.
- Customer support: Answering your queries and complaints.
- Service improvement: Analysing use of the Platform to improve the experience.
- Security: Preventing fraud and unauthorised access.
- Legal compliance: Responding to requests from competent authorities.
4Recipients of the Data
Your data may be disclosed to the following recipients:
Public Administrations
AEAT, TGSS, Ministry of Industry (CIRCE) — to process your tax and Social Security obligations.
Data Processors (Art. 28 GDPR)
All signed under a data processing agreement; the full list is published in the Legal Notice:
- Cloud infrastructure: Google Cloud Platform (Cloud Run, Cloud Storage, Cloud KMS HSM, Secret Manager).
- Databases: MongoDB Atlas (EU Frankfurt) and Redis Upstash (cache/ephemeral sessions).
- Payments: Stripe Payments Europe Ltd.
- Generative AI and OCR: Claude (Anthropic) through Google Cloud Vertex AI, and Google Vision API / Document AI.
- Transactional emails: SendGrid / Twilio.
- Security and anti-fraud: Cloudflare (CDN, anti-DDoS, Turnstile), FingerprintJS (self-hosted device fingerprinting) and MaxMind GeoLite2 (IP geolocation; includes GeoLite2 data created by MaxMind, available at maxmind.com).
- Social authentication: Google OAuth2 and Microsoft Azure AD.
- Web analytics (only with consent): Google Analytics GA4 and Google Tag Manager (pending activation in production).
Professional advisers
Lawyers, auditors and financial institutions under a legal or contractual duty of confidentiality.
Safeguard: All our processors have signed data processing agreements in accordance with Art. 28 GDPR, with obligations of confidentiality, security and breach notification. The full list, with location and international transfer safeguards, is published in the Legal Notice.
5International Transfers
Your data is stored mainly on servers located in the European Union (Google Cloud Platform - europe-west1 region, Belgium).
Your data is stored in the European Union. Claude (Anthropic) through Google Cloud Vertex AI, processed in the European Union: the eu multi-region and, as a fallback, the europe-west1 region (Belgium). Queries to the AI model are not processed outside the EU. We have a data processing agreement (DPA) with the provider, which does not use the queries to train its models. In the case of other transfers to third countries (such as the USA for SendGrid services, Google/Microsoft social authentication, or Stripe for payments), these are made under:
- Adequacy decision: EU-US Data Privacy Framework for certified companies.
- Standard contractual clauses: Approved by the European Commission.
- Supplementary measures: Encryption and pseudonymisation where applicable.
You can request detailed information about the applicable safeguards by contacting dpo@tributai.es.
6Retention Periods
We keep your data for the following periods:
7Security Measures
TributAI implements technical and organisational measures to protect your data:
Encryption
Modern encryption in transit and at rest
Restricted access
Principle of least privilege + MFA
Secure backups
Daily encrypted copies with 30-day retention
Audits
Periodic security reviews
In the event of a security breach affecting your data, we will notify you within a maximum of 72 hours in accordance with the GDPR.
8Your Rights
The GDPR recognises the following rights over your personal data:
To exercise any of these rights, contact us at dpo@tributai.es attaching a copy of your DNI/NIE. We will reply within one month, extendable by two more months in complex cases (art. 12.3 GDPR).
If you consider that we have not dealt with your rights properly, you can lodge a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es
9Use of Artificial Intelligence, profiling and automated decisions (Art. 22 GDPR)
TributAI uses artificial intelligence technology (Claude by Anthropic, as well as Google Vertex AI / Vision API / Document AI for document OCR) to assist with tax queries and process documentation. The logic applied, its importance and consequences are explained below:
Profiling
We generate internal profiles to personalise the assistant and improve the experience. These profiles may include:
- Your tax regime, CNAE/IAE, type of activity and formal obligations.
- History of queries and procedures with TributAI.
- Aggregated signals for anti-fraud detection (device fingerprinting, IP geolocation).
Automated decisions (Art. 22.1 GDPR)
- We do not take automated decisions with binding legal effects. All official procedures (Form 036, returns 303 / 130 / 111, self-employed registration) are reviewed and validated by qualified human staff before they are submitted to the AEAT or TGSS.
- The AI assistant’s answers are for guidance only and do not constitute binding professional advice.
- Automated decisions that we do carry out without immediate human intervention (always with a right to subsequent human review): anti-fraud checks / crypto-sensitive step-up, temporary blocking after anomalous access attempts, limiting use according to consumption of the plan taken out.
Your specific rights regarding AI
- Right to human intervention (Art. 22.3): at any time you can ask a technician to manually review any recommendation or block, by writing to dpo@tributai.es.
- Right to object to profiling (Art. 21.1): you can object to profiling based on legitimate interest from the same email.
- Right to contest the decision: you can express your disagreement with a decision and obtain a human explanation.
No training of external models: Your conversations and documents are not used to train third-party AI models. Anthropic and Google operate under data processing agreements without any right of secondary use.
10Changes to this Policy
TributAI may update this Privacy Policy to reflect changes in our practices or in the applicable legislation.
We will notify you of any material change by email or through a prominent notice on the Platform before it takes effect.
We recommend reviewing this page periodically to stay informed about how we protect your information.
Your GDPR rights
Access
Obtain confirmation of whether we process your data and access it
Rectification
Correct inaccurate data or complete incomplete data
Erasure
Request the deletion of your data ('right to be forgotten')
Restriction
Restrict processing in certain circumstances
Portability
Receive your data in a structured, machine-readable format
Objection
Object to the processing of your data for specific purposes
Do you need the detail by category of data subject, specific retention periods or the full list of data processors? See additional Data Protection information.