Privacy

Draft. The text describes what the application actually does. Before publication it belongs in front of a data protection review.

Controller

Tobias Benkner · Calle Doctor Alfonso Chiscano Diaz 10 · 35010 Las Palmas de Gran Canaria · España

info@pulpo.cloud

This website

This website is static. It sets no cookies, embeds no fonts or scripts from third-party servers and measures no usage behaviour. Retrieving it produces the usual server logs (IP address, time, requested address); they serve operation and the prevention of abuse and are deleted after a short time.

Account and sign-in

For an account, e-mail address and name are stored. There is no password: you sign in with a one-time code sent to the address on file.

Documents

Uploaded files are stored unaltered; corrections only ever touch the values beside them. From a document we capture issuer, date, amounts, tax rates, document number and similar fields, plus whatever you enter yourself, such as notes and categories.

Documents containing health data

Some documents belong to a visit to the doctor: an invoice meant for the tax return. More than an amount is written on it: the service provided, often the speciality, sometimes already in the name of the practice. That is health data and Art. 9 GDPR protects it specially.

We neither ask for it nor evaluate it, but we cannot tell what is inside a file before it has been read. So we ask beforehand, separately from everything else, whether such documents may be processed. This consent under Art. 9(2)(a) GDPR is voluntary and without it everything else can be used unchanged.

It can be withdrawn at any time on the account page, just as easily as it was given. Withdrawal takes effect for the future; what happened before remains lawful (Art. 7(3)). If you also want to be rid of what is stored, the data package and the delete button are right beside it.

If you upload documents as a company or through your tax practice, that decision is not ours but yours or the practice's and we then process on your behalf. See “As a processor” below.

Automatic reading

If a PDF invoice contains a structured record under EN 16931 (ZUGFeRD, Factur-X, XRechnung), it is read locally; nothing leaves the server in the process.

Otherwise the document, as text or as an image of the first page, is transmitted to an AI service that reads out the values. Processing takes place in a data centre in Germany. The contents are not used to train AI models.

Service providers

We use processors who are contractually bound to the same obligations that bind us. The full version with the technical measures is in the data processing agreement.

Tax practice

Anyone assigned to a tax practice grants it read access to their documents and the state of their months. The practice cannot change or delete anything. The assignment only ever comes about through an explicitly accepted invitation and can be broken unilaterally at any time and the documents stay with the client in full.

Retention

Documents and master data remain as long as the account exists. The duty to retain accounting records lies with the taxpayer, not with this service, which is why a complete package of all data can be downloaded at any time. Operating logs are deleted after 30 days.

Deleting the account

An account can be deleted in the settings. It is first marked and locked and removed for good after 30 days; during that time the deletion can be undone and the data package remains available. Anyone who does not want to wait can delete immediately. With the account go the documents, files and master data.

Backups are excluded from this. They contain the data until they expire. Backups are not edited after the fact and are used for nothing other than recovery in an emergency.

From the AI cost accounting one line remains without any personal reference: the account identifier in it is replaced, the amount stays as part of the operator's total.

Your rights

• Access, rectification, erasure and restriction of processing
• Data portability: that is what the button in the settings is for, the one that hands out everything as a ZIP
• Objection to processing based on legitimate interest
• A complaint to a supervisory authority: the competent one is the Spanish Agencia Española de Protección de Datos (AEPD), because that is where our establishment is. The complaint can also be lodged with the authority where you live; it is then passed on.

As a processor

Anyone using the service in a business capacity is themselves the controller for the data in their documents and we process it on their behalf. The agreement required for that under Art. 28 GDPR is accepted together with the terms and conditions and is set out in full under data processing; no signature is needed.

The app

The app loads the same application as the browser. Camera, notifications and Face ID are used only with explicit permission and can be revoked at any time in the system settings. Documents shared from another app stay on the device until they are uploaded.