Privacy policy (GDPR)

1. Overview

This policy explains how the Platform (Beckham Law Agency, a trade name of Elite Digital Services LLC, the controller identified above) processes personal data collected through this Site, in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Data Protection and Digital Rights (LOPDGDD). It covers the Site and the matching service only. Once a professional accepts your case, the data you exchange with them is processed by that professional as an independent controller, under their own privacy policy, engagement terms and professional-secrecy obligations.

2. Data we process

We only process the personal data you actively provide:

• Requests for Guided filing or Annual filing: the service you select, name, email address, your phone number if you give it, and any notes you choose to add.
• Case records: when you send a form, we keep a record of your request, the consent you gave (the wording, date and page), whether you asked for follow-up emails and reminders, the registration date you entered in the diagnosis, and the emails we have sent you.
• Matching requests: name, email address, the service you are interested in, your work situation, your Social Security registration status, the country you are moving from and the free-text description of your case that you choose to write. We ask you not to include identity documents, payslips or contracts.
• Lead forms: your email address and the estimate or answer details you actively choose to send us, for example when requesting your calculator estimate by email or asking for one of our guides.
• Case file (“Prepare your case”): the details Modelo 149 asks for — tax identification number, name and surnames, phone number, address for notifications, dates of entry and start of activity, last country of residence, nationality, the cause of your move and the identification of your employer or entity — the name, tax identification number, date of birth and date of entry of each family member opting in with you and, only for a child aged 25 or older, whether they have a recognised disability (box 65 of their Modelo 149, which is health data: see section 4), the registration number of the documentation you filed beforehand, the receipt number of your filed Modelo 149 if you give it to us (your family members need it for theirs), and the documents you upload for your route (identity, employment or posting documents, Social Security registration or certificate of coverage). We also ask whether you already have a digital certificate or Cl@ve to file with the tax agency, and keep only that answer. We will never ask for your digital certificate or your Cl@ve password.
• Payment of Guided filing, Annual filing and the Relocation tax binder: you pay on Stripe’s own page, not on this Site. You give Stripe your payment details and they never reach us: we neither receive nor store your card number or your billing address. Of each purchase we see the data of the sale — your name and email address, what you bought, the amount, and the country Stripe takes into account for the tax on the sale, which Stripe charges as the seller (section 6).
• WhatsApp: if you write to us on WhatsApp, your phone number, profile name and messages are also processed by WhatsApp (Meta Platforms) under its own terms and privacy policy, outside our systems. We use it only for short exchanges and never ask for identity documents, payslips or contracts through it: those go through the encrypted case file on this Site.
• Correspondence: personal data contained in emails you send to the contact address shown on the Site.
• Technical data: our hosting provider may log IP addresses and basic request metadata for security and operational purposes.
• Advertising measurement data (only if you accept cookies): when you arrive from one of our Google Ads ads and then send a form or tap the WhatsApp button, Google Ads records that a conversion happened, using its own cookies and identifiers (such as the ad click ID), your IP address and browser data. We do not send Google your name, your email or the contents of any form.

3. What stays in your browser

The free diagnosis and the savings calculator run entirely in your browser. The answers and figures you enter are not transmitted to our servers and are not stored by us, unless you subsequently choose to send them to us, for example by booking a consultation, requesting your estimate by email, or writing to us.

The only exception is anonymous usage statistics (see the cookies section below): we record that the calculator was used and which step and outcome category the diagnosis reached (for example “eligible” or “outside the deadline”), never your individual answers, your salary figure, your email or any identifier that could link those statistics to you.

4. Purposes and legal bases

We process personal data for the following purposes, on the following legal bases (art. 6 GDPR):

• Managing service requests and responding to enquiries, steps taken at your request prior to entering into a contract (art. 6(1)(b) GDPR).
• Putting you in contact with an independent professional who can take your case, which requires sharing your matching request with that professional, steps taken at your request prior to entering into a contract (art. 6(1)(b) GDPR).
• Complying with legal obligations, tax, accounting and, where applicable, anti-money-laundering rules (art. 6(1)(c) GDPR).
• Keeping the Site secure: our legitimate interest in preventing abuse (art. 6(1)(f) GDPR).
• Measuring how the Site is used (which pages and steps are visited, which buttons are pressed) with Umami, a cookieless analytics tool: our legitimate interest in understanding and improving the Site (art. 6(1)(f) GDPR). It stores nothing on your device and needs no consent; you can object at any time (section 8), for example by blocking cloud.umami.is in your browser.
• Sending you information you have expressly requested, your consent (art. 6(1)(a) GDPR), which you may withdraw at any time.
• Measuring the effectiveness of our advertising (Google Ads conversion tracking), your consent given in the cookie banner (art. 6(1)(a) GDPR and art. 22.2 LSSI-CE), which you may withdraw at any time from “Cookie settings” at the bottom of every page.
• Sending you the acknowledgement of each form and the email copy of your diagnosis or estimate, which you ask for when you send the form (art. 6(1)(b) GDPR).
• Sending you the reminders related to your case, which is what you agree to in the privacy box of each form: a notice before your Modelo 149 deadline, two short follow-up emails (on days 3 and 7) if you asked us for Guided filing or Annual filing, and never for a request for a professional or for a diagnosis or an estimate on its own, and, if you have bought one of our products and have a registration date, a reminder every April while the regime lasts that the annual Modelo 151 is due, plus a notice in the fifth year (the yearly reminders are part of the paid products: a diagnosis or an estimate on its own receives only the notice before its Modelo 149 deadline). Legal basis: your consent (art. 6(1)(a) GDPR and art. 21 LSSI-CE), which you may withdraw at any time. Every one of those emails carries a one-click unsubscribe link, and unsubscribing stops all of them, the yearly ones included.
• The recognised disability of a child aged 25 or older (box 65 of their Modelo 149), which is health data, a special category of data (art. 9 GDPR). We ask for it only for a child of that age, the only case in which the box decides anything, and process it on the explicit consent you give in the privacy box of the case file (art. 9(2)(a) GDPR), together with the performance of the service you asked for (art. 6(1)(b) GDPR); you declare that you give it with your adult child’s authorisation. For any other family member it is never asked for or kept, and a value saved before is erased. It is not sent to the AI model, it goes to a professional only inside your case file and only if you ask us to pass your case on, and it is deleted with the rest of your case file.
• Reading the documents you upload in the guided case file (/prepare/) to fill in its fields for you, which you ask for when you upload them there and agree to in its privacy box (art. 6(1)(b) GDPR). Everything read stays marked “to confirm” until you confirm or correct it; we keep only the fields read, never a copy of the document outside our encrypted storage.
• Delivering Guided filing and Annual filing, the self-service products, which are automated from end to end and include the use of an artificial-intelligence model (Anthropic, acting as our processor) to read what you upload and to produce the checks on your case file and the texts the product gives you, performance of the contract you entered into (art. 6(1)(b) GDPR). What is sent to the model is the document you uploaded, or the data of your case file and what you wrote to us, and never your password, your Cl@ve or your digital certificate, which we never ask for. The model decides nothing about you: whether you are eligible, your Modelo 149 deadline and which boxes of the form are mandatory are worked out by our own code from the rules, and everything the model reads stays marked “to confirm” until you confirm or correct it. There is no automated decision within the meaning of art. 22 GDPR: the product gives you information and checks, and the decision to file, or not to, is yours.

5. Retention

We keep personal data only for as long as needed for the purpose it was collected for: matching requests, enquiries and booking data for 12 months after the last contact, so that we can follow up on the outcome of the matching, and thereafter only as required by statute. The professional who takes your case keeps their own engagement file under the retention periods that apply to them. Data processed on the basis of consent is kept until you withdraw it. If you have bought one of our products and asked for the yearly reminders, we keep your email address, name and registration date for as long as the reminders last, and at most until the end of the regime period (seven years from that date); unsubscribing stops every email immediately. The documents you upload to a case file are deleted automatically 90 days after the case file is created if you do not engage a service, together with the case-file PDF generated from them; if you do engage one, they are kept for as long as that service and its legal obligations require. The rest of the case file (the Modelo 149 details) follows the 12-month rule above. You can ask us to delete your documents earlier at any time.

6. Recipients and processors

We do not sell personal data and do not share it with third parties for their own marketing. Data is disclosed only to: (i) the independent professional assigned to your matching request, who receives the information you submitted and processes it as an independent controller, bound by professional secrecy — and, only when you ask us to pass your case on, read-only access to your case file and its documents through a link that expires and that we can revoke; (ii) service providers acting as processors under art. 28 GDPR: GitHub, Inc. (hosting of this website on GitHub Pages: it receives your IP address and the technical data of each visit in order to serve the pages), the form service that receives our web forms (Formspree), Cloudflare (hosting of our case system, its database and the storage of your documents: Cloudflare Workers, Workers KV and R2), Vercel Inc. (a second entrance to that case system, in the United States, that forwards requests to it when Cloudflare cannot be reached from your network; it keeps nothing), Resend (sending of acknowledgements, follow-ups and reminders), Anthropic, PBC (automatic reading of the documents you upload in the guided case file, to fill in its fields, and of what you write to us in a request, so that we do not ask you again for what you have already told us; the checks and the texts of the self-service products, Guided filing and Annual filing, which are automated and in which no person reviews your case; and the drafting of our replies to you, which a person reads and corrects before sending them: it receives each document, or the data of your case file and that text with a summary of your case without your contact details or identity numbers, only to return the data read, the checks or the draft, under its commercial terms, which do not allow it to use the data to train its models; we do not keep the document anywhere outside our encrypted storage, and of your text we keep only what was read, marked «to confirm». It decides nothing: your eligibility, your deadline and the mandatory boxes of the form are worked out by our own code), and our email provider; (iii) Google Ireland Limited (Google Ads), only if you accept advertising cookies, which receives the conversion measurement data described in section 2 and processes it under its own advertising terms and privacy policy (policies.google.com/privacy); (iv) Stripe, Inc., which collects the payment for Guided filing, Annual filing and the Relocation tax binder: with Stripe’s managed payments Stripe is the seller towards you in that purchase (merchant of record), so for the sale it acts as an independent controller and not as our processor, and processes what you give it under its own privacy policy (stripe.com/privacy). You enter your payment details on Stripe’s own page and they never reach us: we neither receive nor store your card number or your billing address. Of a purchase we see the data of the sale — your name and email address, what you bought, the amount, and the country Stripe takes into account for the tax on the sale, which Stripe charges and accounts for as the seller. The service you buy is provided by Elite Digital Services LLC (legal notice, section 9); and (v) public authorities and courts where legally required.

7. International transfers

The controller, Elite Digital Services LLC, is established in the United States, so the data you send us is received by a controller outside the European Economic Area. The GDPR applies to that processing because the Site offers its services to people in the European Union (art. 3(2) GDPR), and everything in this policy applies in full.

Your data is stored and processed in the United States. The controller is a US company, and so are the providers who process it for us: your case, your case file and your documents live in Cloudflare (Workers KV and R2, in North America), and the rest of the processing is done by GitHub, Vercel, Resend, Anthropic, Formspree and Google. Every transfer is covered either by the European Commission’s adequacy decision for the EU-U.S. Data Privacy Framework, for the providers that take part in it (Cloudflare, Vercel, Resend, GitHub and Google, checked on their official list), or by the Standard Contractual Clauses approved by the Commission, in their data processing agreement, for those that do not (Anthropic, Formspree). Spanish and European data protection law applies to you in full wherever the data is: this section says where it is, not which rights you have.

The payment is different: Stripe, Inc. is established in the United States, and it is you who gives it your payment data, on its own page, as the seller of that purchase and its own controller (section 6). We are not the ones transferring it, and that processing is governed by Stripe’s own privacy policy and the safeguards stated there; of the sale we only ever see what section 6 lists.

8. Your rights

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

• Access the personal data we hold about you.
• Rectify inaccurate or incomplete data.
• Erase your data (“right to be forgotten”) where there is no legal ground to retain it.
• Restrict processing in the cases foreseen by art. 18 GDPR.
• Receive your data in a portable format (art. 20 GDPR).
• Object to processing based on legitimate interest.
• Withdraw consent at any time, without affecting the lawfulness of prior processing.

9. How to exercise your rights

Write to the privacy contact address above, attaching proof of identity; we will reply within one month (art. 12 GDPR). If you believe your rights have been infringed, you may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD, www.aepd.es).

10. Cookies

Umami (Umami Software, Inc., Umami Cloud) measures our audience without cookies and without any persistent identifier: it writes nothing to your device (the script only checks whether a local opt-out setting exists, which it never creates), keeps no identifier between visits and does not track you across websites. For each page view it records the page, the referring site, the browser, operating system, device type, screen size, language and country (derived from your IP address, which is not stored), and the anonymous events we send to gateway.umami.is (which button, which step of a form, which outcome category), never an email, a name, an amount or a case number. Visits are grouped with a salted hash of IP address and browser that changes every day, so the same person cannot be followed from one day to the next. Because it stores nothing on your device and reads nothing that identifies you, it does not require the cookie banner (art. 22.2 LSSI-CE) and works whether or not you accept cookies; its legal basis is our legitimate interest (section 4). No other analytics tool runs on this Site.

The only non-essential cookies on this Site are those of Google Ads (Google Ireland Limited), used solely to measure advertising conversions, that is, whether a visit that came from one of our ads ends in a form submission or a tap on the WhatsApp button. They are set only if you click “Accept” in the cookie banner: until then the Google tag is not loaded, and we use Google Consent Mode v2 with advertising storage, ad user data, ad personalisation and analytics storage all set to “denied” by default; accepting switches them to “granted”, rejecting leaves them denied. The usual ones are _gcl_au and, when you arrive from an ad, _gcl_aw, which last up to 90 days. Your choice is saved in your browser’s local storage so the banner is not shown again, and you can change it at any time from “Cookie settings” at the bottom of every page; if you withdraw your consent, we delete those cookies.

When you open your case file or your walkthrough from “Your case” with the one-time code we email you, our case system sets one strictly necessary cookie on its own domain, bla_case_session: a random identifier, valid for 24 hours, so the same browser can open them again without a new code. It opens nothing of any other case, is not used for measurement and needs no consent (art. 22.2 LSSI-CE).

This Site is hosted on GitHub Pages (GitHub, Inc.), which receives your IP address to deliver the pages and sets no cookies. Fonts are served from this Site’s own domain. All of these services are governed by their own privacy policies.

When you submit a form on this Site (diagnosis, calculator, professional request or payment), your browser keeps a temporary copy of what you entered in its local storage (localStorage) only until the submission is completed, so it is not lost if the connection fails; it is deleted as soon as the submission succeeds. This copy is not a cookie, never leaves your device on its own and is not used to track you; you can also remove it at any time by clearing this Site’s data in your browser.

11. Security

We apply appropriate technical and organisational measures (art. 32 GDPR) to protect personal data, including encrypted transport (HTTPS), access controls and data minimisation, in particular, the Site’s interactive tools are designed to run locally in your browser. The documents you upload to a case file are encrypted by us (AES-GCM) before they are stored, on top of the storage provider’s own encryption at rest, and they are only reachable through links that expire; the links shared with a professional can also be revoked.

12. Changes to this policy

We may update this policy to reflect legal or operational changes. The date of the current version is shown at the top of this page; material changes will be highlighted on the Site.