Privacy policy

Controller

The controller of your personal data is:

• Controller: Sellado
• Email: [email protected]

This policy explains, in line with article 13 of Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD), what data we process, why and on what legal basis.

What data we process and why

• Account: your email address and, if you sign in with Google, the name and picture of your Google account. We use them to give you access. Legal basis: performance of the contract (art. 6(1)(b) GDPR).
• Profile answers: the details you give us to order your steps and fill in the forms (for example nationality, situation, passport details or address). Legal basis: performance of the contract (art. 6(1)(b) GDPR).
• Encryption: your passport number, full date of birth and full address are stored encrypted (AES-GCM) with a key that only the server holds.
• Files and progress: the procedures you open and the steps you mark as done. Legal basis: performance of the contract (art. 6(1)(b) GDPR).
• File without an account: if you use the service without signing in, your answers to the situation questions, your progress on the steps and the version of the "Terms of use" you accepted, linked to a random identifier kept in a cookie (see "File without an account" below). Legal basis: performance of the contract for the free use of the service, set out in the "Terms of use" (/en/legal/terms-of-use) (art. 6(1)(b) GDPR).
• Purchases: the pack bought, the amount, the date, Stripe's payment identifiers, the version of these texts you accepted and the numbered invoice, showing the VAT (IVA), that Stripe issues and emails to you with your name, email and billing country. We never see or store your card details: only Stripe processes them. Legal basis: performance of the contract and compliance with accounting and tax obligations (art. 6(1)(b) and 6(1)(c) GDPR).
• Withdrawal requests: if you withdraw from your account, the purchase it refers to, the date and time, the reason if you choose to give one, the outcome (refunded or pending) and Stripe's refund identifier. If you withdraw by email, we record it the same way, with the channel (email), the purchase and the date and time we received it. We use them to process your withdrawal, send you the acknowledgement and refund you. The controller receives an email with the purchase and the outcome, never with the reason or your email. Legal basis: compliance with a legal obligation (art. 6(1)(c) GDPR, articles 102 to 108 of the Spanish General Law for the Protection of Consumers and Users).
• Error reports: the message you write and, if you want a reply, your email (your account's address if you are signed in). We use them only to correct the content and, where it applies, to tell you what we did (see "Error reports" below). Legal basis: our legitimate interest in keeping the information accurate (art. 6(1)(f) GDPR). To limit abuse, we use your IP address transiently, in memory only, and do not store it with the report (as with any visit, our server's access log and Cloudflare's request logs do record it; see "Technical logs" and "Processors").
• "Save my roadmap" (no longer offered): if you asked us to email you your roadmap before we withdrew that option, we keep your email, the date of your consent and the version of these texts you accepted. We no longer collect new data this way. Legal basis: your consent (art. 6(1)(a) GDPR), which you can withdraw at any time.
• Technical logs: the minimum needed to run the service, protect it against abuse and detect faults. Our server's access log records, for each request, your IP address, the date and time, the page requested (without the parameters in the address), the result, and the size and duration of the response; it does not record your browser, the page you came from or anything you send. The application's own logs never contain your profile answers, your email, your IP address, the text of your reports or the reason for a withdrawal. Legal basis: our legitimate interest in keeping the service secure and working (art. 6(1)(f) GDPR).

Do you have to give us your data?

Your email address is a contractual requirement to create an account and buy a pack: without it we cannot give you access or provide the service. Your profile answers are needed to order your steps and fill in the forms; if you do not give them, you can still use the free guides, but not the pack tools. Leaving your email in an error report is optional, and not doing so has no consequences.

File without an account

You can see your roadmap and track your progress without creating an account. In that case we keep a file without an account: your answers to the situation questions (for example nationality, situation or whether you already have a document) and the steps you mark as done, together with the version of the "Terms of use" you accepted when you started. It does not hold your name, your email, your passport details or your address. Your browser recognises it through the tramites.file cookie, which holds only a random, signed identifier, lasts 12 months and is renewed each time you use the file.

If you sign in from this same browser (the one that started the sign-in, including through "Save my file"), or create an account when you buy a pack, the file is attached to your account. If you open a sign-in link you did not request from this browser, or one requested for another address, the file is not attached to that account and stays a file without an account. Once attached, it is kept from then on like the account's files. If you do not use a file without an account for 12 months, we delete it, together with its progress.

Error reports

When you send an error report, the controller gets an email saying only that a report has arrived, for which procedure and which step, without its text: the text stays in our database and only the controller reads it, in a private panel. When the report is closed (fixed or rejected) and you left a reply address, the controller may write to you to tell you the outcome, once for each outcome. We use that address for nothing else.

We make no automated decisions with legal effects on you and build no marketing profiles. We do not sell your data or use it for advertising.

Processors

To provide the service we use these providers, under data processing agreements:

• netcup GmbH (Germany): application hosting on a virtual private server that we run ourselves, in a netcup data centre in Germany. Every request to the site passes through it and it holds the access log (see "Technical logs"); your account, profile and file data are not kept on it but in the database. No transfer outside the European Union.
• Neon: Postgres database, hosted in Frankfurt (Germany, European Union). The data processing agreement is with Databricks, Inc. (US), the parent company of Neon, LLC. Neon also uses sub-processors in the US (for example Grafana Labs, for infrastructure services). Transfer to the US: Databricks, Inc. participates in the EU-US Data Privacy Framework, and its certification covers Neon, LLC; its data processing agreement provides for standard contractual clauses should that framework cease to apply.
• Cloudflare: delivery and protection network in front of our server (DNS, delivering the pages and defence against attacks). Your browser's encrypted (HTTPS) connection ends at the Cloudflare server nearest to you, which may be outside the European Union, and from there travels, encrypted again, to our server. So Cloudflare processes the content of requests transiently and only to deliver them (including what you type into forms), and keeps technical connection data, such as your IP address, for a limited time for security and to run its network. It may cache the public pages, which hold no data about you. Transfer to the US and other countries: Cloudflare, Inc. participates in the EU-US Data Privacy Framework; its data processing agreement also includes standard contractual clauses.
• Resend: sending sign-in emails (including those from "Save my file"), the reply to an error report and the acknowledgement of a withdrawal; it receives your email address and the content of that email (the sign-in link, the outcome of the report or the acknowledgement with the purchase and the reason you gave or, if you withdrew by email, the content of your statement; never your profile answers). Transfer to the US: Resend (Plus Five Five, Inc.) participates in the EU-US Data Privacy Framework; its data processing agreement also includes standard contractual clauses.
• Stripe: payments, through Stripe Payments Europe, Ltd. (Ireland). Stripe also acts as an independent controller for fraud prevention and its own legal obligations. Transfer to Stripe, Inc. (US): EU-US Data Privacy Framework and standard contractual clauses.
• Google: only if you sign in with Google, through Google Ireland Ltd. Transfer to Google LLC (US): EU-US Data Privacy Framework and standard contractual clauses.

Where your data is and international transfers

Your data is stored in the European Union: the application runs in Germany (netcup) and the database is in Frankfurt (Neon). Data leaves the European Economic Area in these cases: your requests passing through Cloudflare's network (and its logs), access from the US by Neon, its parent Databricks and their sub-processors (for example Grafana Labs), emails sent through Resend, payments with Stripe and, if you choose it, signing in with Google. Each relies on the European Commission's adequacy decision for the EU-US Data Privacy Framework (art. 45 GDPR), where the company participates, and on the Commission's standard contractual clauses (art. 46(2)(c) GDPR), as set out above for each provider.

You can ask us for a copy of the standard contractual clauses that apply, or where to read them, by writing to [email protected]. The list of organisations in the Data Privacy Framework is published at www.dataprivacyframework.gov ↗ (opens in a new tab).

How long we keep data

• Account, profile and files: until you delete your account. Deletion takes effect immediately.
• File without an account: we delete it after 12 months without use. Each use restarts the period. Once attached to an account, it is kept like the account's files.
• Purchases and invoices: six years from the purchase (art. 30 of the Spanish Commercial Code), for our accounting and tax duties, VAT included. If you delete your account, we keep the purchase record with no link to it, and Stripe keeps the receipts and invoices it issued.
• Withdrawal requests: six years, like purchases, including those received by email. If you delete your account, we keep them with no link to it and delete only the reason you wrote. After the six years, we delete them. The refund also stays on record at Stripe.
• Error reports: we delete them 24 months after the report is closed (fixed or rejected), and sooner if you delete your account. If you left a reply address, we delete it 180 days after the report is closed.
• "Save my roadmap" (no longer offered): the addresses we already hold, until you sign up with the same email or withdraw your consent, and for at most 12 months from your request.
• Sessions and sign-in links: sessions expire after 30 days and sign-in links after 24 hours; expired ones are deleted every day.
• Server access log: 14 days; it is then deleted automatically.

What is kept when you delete your account

When you delete your account, we straight away delete your profile, your files and their progress, your pack access, the reason for your withdrawal requests, your error reports, your sessions and any roadmap saved under your email, and remove your address from any reports you sent without signing in. All that remains, for six years and with no link to the account, is the record of your purchases and of your withdrawal requests (without the reason), plus the receipts and invoices Stripe issued, because the law requires us to keep them or we need them to show that we handled your withdrawal.

Your rights

On your account page (/en/cuenta) you can, at any time and free of charge:

• Download your data as a JSON file holding everything we keep about you (access and portability). Error reports sent without signing in that give your email are listed without their text: anyone can type an address, so that text may not be yours.
• Delete your account for good, by typing your email to confirm (erasure).

For the other rights (rectification, restriction of processing and objection) and to withdraw your consent, write to [email protected]. We will reply within one month. If we need to confirm your identity, we will ask you to write from your account's email address.

If you believe we have not handled your data properly, you can lodge a complaint with the Spanish Data Protection Agency, AEPD (www.aepd.es ↗ (opens in a new tab)).

Cookies

We only use strictly necessary cookies, among them tramites.file, which keeps your file without an account on this device, and tramites.signin, which lasts 1 hour and checks that sign-in started in this browser, so your file only joins the account you sign in to from this same browser. It does not hold your email. The details are in the cookie policy.

Changes

If we change this policy, we will update the date shown at the top of this page. If the change is significant, we will let you know by email.