PRIVACY POLICY

Last updated: March 27, 2026

1. INTRODUCTION

At FORGELAB DIGITAL PRODUCTS, S.L. (hereinafter, "Askpancho", "we" or "the Platform"), we are committed to protecting the privacy and personal data of our users. This Privacy Policy describes how we collect, use, share and protect personal information when you use our AI-powered product evaluation services.

This policy complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 and Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD).

2. DATA CONTROLLER

Identity: FORGELAB DIGITAL PRODUCTS, S.L.

Tax ID: B75796524

Address: Calle Larga Nº19, 44622 Arens de Lledó, Spain

Email: pancho@askpancho.ai

3. DATA PROTECTION OFFICER (DPO)

Given the volume and nature of the data processed, FORGELAB DIGITAL PRODUCTS, S.L. is not required to appoint a Data Protection Officer pursuant to Article 37 of the GDPR. However, for any questions related to personal data protection, you may contact:

Privacy contact: pancho@askpancho.ai

We will handle your request within a maximum of one month from receipt, extendable to two months in cases of particular complexity, and we will inform you of such extension within the first month.

4. DATA WE COLLECT

4.1. Identification and Contact Data

Full name
Email address
IP address
Device and browser information

4.2. Evaluated Product Data

Depending on the type of product, we may collect:

For vehicles:

License plate, make, model, year
Mileage and general condition
Vehicle photos

For electronic devices:

Make, model
Condition and photos

For other products:

Relevant identifying information
Condition, features and photos
Any data necessary for the evaluation

4.3. Browsing Data

Cookies and similar technologies (see Cookie Policy)
Pages visited and browsing time
Interactions with the platform

4.4. Evaluation Data

History of evaluated products
Evaluation results
Communications related to the service

4.5. Payment Data

Payment data (card number, expiration date, CVC) are processed directly by our payment provider Stripe, Inc. and are never stored on our servers. Stripe may collect additional data such as IP address, browser information and card country of origin for tax calculation and fraud prevention.

5. PURPOSES OF PROCESSING

5.1. Main Purposes

We use your data to:

Service provision:

Generate product evaluations using AI
Process and analyze the images and data provided
Send evaluation results
Manage payments and the calculation of applicable taxes

Service improvement (with consent):

Train and optimize our artificial intelligence models
Develop new features
Statistical and performance analysis

Communication:

Respond to inquiries and requests
Send information about service status
Important notifications about changes
Commercial communications and surveys (only with express consent)

Legal compliance:

Comply with legal and tax obligations
Respond to legal requests

5.2. Processing Through Third-Party AI

To carry out the evaluations, we share data (mainly images and product descriptions) with the following AI service providers:

OpenAI (ChatGPT)
Anthropic (Claude)

These providers process the data according to their own privacy policies and under strict security measures. If new AI providers are added, this policy will be updated to reflect such change.

6. RESPONSIBILITY FOR UPLOADED IMAGES

The user is solely responsible for the content of the images they upload to the platform. Photos of vehicles or other products may contain personal data of third parties, such as license plates of other vehicles, people’s faces, addresses or other visible identifying information.

By using our services, the user declares and warrants that:

They have the right or necessary authorization to upload the images provided.
They have taken reasonable steps to avoid including personal data of third parties without their consent.
They assume full responsibility arising from the content of the uploaded images, including any third-party claims for violation of their privacy or data protection rights.

Askpancho does not manually review uploaded images to detect personal data of third parties, although it may implement automatic anonymization techniques when deemed appropriate.

7. LEGAL BASIS FOR PROCESSING

The processing of your data is based on:

Consent: For processing product images and data, for training AI models with user data, and for sending commercial communications and surveys.
Performance of a contract: For providing the requested service and managing payments.
Legitimate interest: For aggregated statistical analysis and overall platform improvement.
Legal obligation: For compliance with tax and legal obligations.

8. DATA RETENTION

Personal data will be retained for the following periods:

Account data: While you keep your account active and for 30 days after cancellation.
Evaluation data: For 2 years from the evaluation.
Tax data and transaction records: For a minimum of 10 years, in accordance with obligations arising from the EU One-Stop Shop (OSS) regime and applicable Spanish tax regulations.
Anonymized data: Indefinitely for improving AI algorithms, as it does not constitute personal data.

9. DATA RECIPIENTS

9.1. Data Sharing

We may share your data with:

Essential service providers:

Hosting services: MongoDB Atlas, AWS S3
AI providers: OpenAI (ChatGPT), Anthropic (Claude)
Payment services: Stripe, Inc. (payment processing, tax calculation and collection, fraud prevention)
Analytics services: Google Analytics

Authorities and public bodies:

When required by law
In response to legal proceedings

9.2. International Transfers

Some of our providers may be located outside the European Economic Area (EEA). In these cases, we ensure that appropriate safeguards are in place to protect your data, such as:

Standard contractual clauses approved by the European Commission.
European Commission adequacy decisions, including the EU–US Data Privacy Framework (DPF) for transfers to certified entities in the United States.
Other approved transfer mechanisms in accordance with Chapter V of the GDPR.

10. USER RIGHTS

10.1. Your Rights

As a user, you have the right to:

Access: Obtain confirmation and a copy of your personal data.
Rectification: Correct inaccurate or incomplete data.
Erasure: Request deletion of your data ("right to be forgotten").
Restriction: Restrict processing in certain circumstances.
Portability: Receive your data in a structured, commonly used format.
Objection: Object to certain processing operations, including those based on legitimate interest.
Withdrawal of consent: You may withdraw at any time the consent given for AI training or commercial communications, without affecting the lawfulness of processing carried out beforehand.
Not to be subject to automated decisions: Including profiling with legal or significant effects.

10.2. Exercising Your Rights

To exercise your rights, contact us at:

Email: pancho@askpancho.ai

Postal address: Calle Larga Nº19, 44622 Arens de Lledó, Spain

Include a copy of your identity document and clearly specify the right you wish to exercise. We will respond within a maximum of one month from receipt of the request, extendable by an additional two months in cases of particular complexity.

10.3. Complaints

If you believe your rights have been violated, you may lodge a complaint with the Spanish Data Protection Agency or with the data protection authority of your country of residence in the EU.

11. DATA SECURITY

We implement appropriate technical and organizational measures to protect your data, including:

Data encryption in transit (TLS/SSL) and at rest.
Role-based restricted access.
Continuous security monitoring.
Periodic security assessments.

12. MINORS

Our services are not directed at minors under 18 years of age. We do not knowingly collect data from minors. If we detect that we have received data from a minor, we will delete it immediately.

13. CHANGES TO THE POLICY

We reserve the right to update this policy. Significant changes will be notified through:

Prominent notice on the platform.
Email to registered users.
Request for new consent when necessary.

14. USE OF EVALUATIONS

14.1. Public Sharing

Evaluations may be shared publicly at the user's discretion. By doing so, the user assumes responsibility for the disclosure of any information contained therein.

14.2. Use by Askpancho

We reserve the right to use evaluations anonymously and in aggregate for:

Statistics and market analysis.
Improving our algorithms (subject to the user's consent).
Promotional purposes (always anonymized).

15. COOKIES

The use of cookies is governed by our specific Cookie Policy, available on the platform.

16. CONTACT

For any questions about this policy or about the processing of your data:

Email: pancho@askpancho.ai

Address: Calle Larga Nº19, 44622 Arens de Lledó, Spain

17. VERSION AND LANGUAGES

This policy is available in several languages. In the event of a conflict between versions, the Spanish version shall prevail.