Privacy Policy

1. What we collect

• Free diagnostic (chat): the messages you type. The free diagnostic requires no signup, no email, and no identity documents. We ask you not to share passport numbers, financial account numbers, or document uploads during the free phase.
• Paid packages: the personal data needed to prepare your documents — such as your name, nationality, date of birth, address, employment and income details, family composition, and the consulate you will file at. We collect only what the deliverables require.
• Payments: processed entirely by Paddle as Merchant of Record. We never see or store your card details. Paddle's privacy policy applies to the payment transaction.
• Technical data: standard server logs (IP address, timestamps) used for security and rate limiting.

2. How we use your data

• To run the diagnostic and answer your questions.
• To prepare your personalized document package (paid tiers).
• To provide support during your package's support window.
• To protect the service against abuse and fraud.

We do not sell your personal data. We do not use your data for third-party advertising.

3. AI processing

Conversations and document-preparation tasks are processed using large-language-model services provided by Anthropic (the Claude API). Your messages are transmitted to Anthropic's API to generate responses. Per Anthropic's commercial API terms, API inputs and outputs are not used to train their models by default. See Anthropic's commercial terms and privacy policy.

4. Retention

• Free diagnostic conversations: retained only as long as needed to operate the service and improve its quality, then deleted or anonymized.
• Paid case data and deliverables: retained for the duration of your support window plus 90 days, so we can honor corrections and re-reviews, then deleted except where a longer period is legally required (e.g., invoicing records held by Paddle).
• Server logs: rotated within 30 days.

5. Sharing

We share data only with the processors needed to run the service: Anthropic (AI processing), Paddle (payments, as independent Merchant of Record), and our hosting provider (Hetzner Online GmbH (Germany)). We do not share your data with immigration authorities, consulates, or any third party — you file your own applications.

6. International transfers

Our processors may process data in the United States and the European Union. Where required, transfers rely on the processors' standard contractual safeguards.

7. Your rights

Depending on your jurisdiction (including GDPR if you are in the EU/EEA and Peru's Personal Data Protection Law No. 29733), you may have the right to access, correct, delete, or receive a copy of your personal data, and to object to or restrict certain processing. To exercise any of these rights, write to support@xpatspain.es. We respond within the legally required timeframe.

8. Security

Data in transit is encrypted (HTTPS/TLS). Access to case data is restricted. No system is perfectly secure; if a breach affecting your data occurs, we will notify you as required by law.

9. Children

The service is not directed at anyone under 18. Dependent minors' data is provided by their parent or guardian solely for document preparation.

10. Changes

We may update this policy; material changes will appear here with a new date.