Privacy Policy

Effective Date: April 16, 2026 | Compliant with GDPR & LOPDGDD (Spain)

            Data Controller (Responsable del Tratamiento):

            Name: [YOUR FULL NAME] (Autónomo)

            NIF/NIE: [YOUR NIF/NIE]

            Registered Address: [YOUR FULL ADDRESS IN SPAIN]

            Email: [YOUR SUPPORT EMAIL]

1. Zero-Data Leak Architecture (The Product)

PASSPORT is distributed as a local markdown-based framework. We do not operate cloud servers that sync, read, or process the data you input into your PASSPORT files. Your interactions with your chosen AI models (e.g., ChatGPT, Claude, or local LLMs) are governed locally or by their respective privacy policies. We have zero access to your personal AI data.

2. Information We Collect (The Website)

When you visit our website or purchase a license, we process the following data:

Purchase Data: Email address to deliver the product and updates. Billing information required for legally binding invoices.
Technical Data: Anonymized IP addresses and browser types for basic website security and analytics.

3. Legal Basis and Purpose (Finalidad y Legitimación)

Your data is processed under the following lawful bases (Art. 6 GDPR):

Execution of a Contract: To process your payment via Stripe and deliver the digital product to your email.
Legal Obligation: To maintain billing and tax records required by Spanish Tax Authorities (Agencia Tributaria).
Consent: When you contact us for support or accept optional cookies.

4. Data Retention (Conservación)

Your email and purchase data are retained as long as necessary to provide you with lifetime updates. Tax and billing records will be kept for up to 5 years complying with Spanish tax and mercantile law obligations.

5. Third-Party Recipients (Destinatarios)

We do not sell your data. We share necessary data strictly with service providers for operational purposes:

Stripe: Our secure payment processor. They handle all financial transactions. We do not see or store your credit card details.
Hosting/Email Providers: To host this website and send order fulfillment emails.

6. Your Rights (Derechos ARCO)

Under the GDPR and Spanish LOPDGDD, you have the right to:

Access the personal data we hold about you.
Request the rectification of inaccurate data.
Request the deletion of your data (Right to be forgotten), except where we are legally required to retain it for tax purposes.
Object to or restrict certain processing.
Data Portability.

To exercise these rights, email us at [YOUR SUPPORT EMAIL] with the subject "Data Protection Rights". You also have the right to file a complaint with the Spanish Data Protection Agency (AEPD) via www.aepd.es.