Wrambox — launching October 2026.
VVWramBox

PRIVACY POLICY — WRAMBOX

Francisco Manuel Gallardo Liebana trading under the name Wrambox

[Full address — pending] [Legal email — pending] [VAT number — pending]

1. Data controller

The controller of the personal data collected through the Wrambox platform is Francisco Manuel Gallardo Liebana, trading under the name Wrambox, with the contact details indicated in the header.

2. Data we collect

During registration and use of the platform, Wrambox may collect and process the following categories of data:

Identification data

  • Pseudonymous customer number (automatically assigned by Wrambox).
  • Full name.
  • Email address.
  • Phone number.
  • Company name or professional activity.

Billing data

  • Fiscal address.
  • Country of residence or activity.
  • Tax identification number or VAT ID where applicable.
  • Payment and billing history.

Technical data

  • IP address.
  • Date and time of access.
  • Browser language.
  • Operating system and browser used.
  • Technical information necessary for fraud prevention, platform protection and compliance with legal obligations.

Usage data

  • Applications used.
  • Selected settings.
  • History of operations carried out within the platform.
  • Service usage statistics.

Data provided by the user

  • Documents, files, images and content uploaded to the platform.
  • Invoices and documents generated through the applications.
  • Voice recordings and transcriptions.
  • Information entered to use artificial intelligence-based tools.

3. Purpose of processing

Personal data will be processed for the following purposes:

  • Managing user registration and account.
  • Providing contracted services.
  • Processing payments and issuing invoices.
  • Maintaining platform security.
  • Detecting fraudulent or abusive activities.
  • Complying with legal, tax and administrative obligations.
  • Managing support requests.
  • Improving service performance.
  • Determining applicable documentation and requirements based on the user's jurisdiction.
  • Providing artificial intelligence-based features.
  • Sending account confirmation emails (double opt-in) to verify ownership of the email address provided.
  • Sending operational and service communications relating to the account (security notices, service changes and administrative notifications).

4. Legal basis for processing

The processing of personal data is based on:

  • The execution of the contract between the user and Wrambox.
  • Compliance with legal obligations.
  • The legitimate interest of Wrambox in ensuring the security, stability and improvement of its services.
  • The user's consent where legally required.

5. Use of artificial intelligence

Certain Wrambox features (voice transcription, text processing and AI-based assistance) use artificial intelligence services provided by third parties.

To provide these features, the data entered by the user for that purpose — including voice recordings, their transcriptions and free text — is transmitted to those providers for processing.

These providers are located outside the European Economic Area (United States). The transfer relies on the Standard Contractual Clauses approved by the European Commission and, where applicable, on the provider's certification under the EU-U.S. Data Privacy Framework.

These providers act as data processors and do not use this data to train their models.

6. Sharing data with third parties

Wrambox shares personal data, only to the extent necessary, with the following data processors:

  • Stripe Payments Europe, Ltd. (Stripe, Inc. group) — payment processing (Ireland / United States).
  • Hetzner Online GmbH — hosting and technology infrastructure (Germany).
  • Zoho Corporation B.V. — email delivery (data center in the European Union).
  • OpenAI — voice transcription (United States).
  • Anthropic PBC — artificial intelligence features (United States).
  • Datadog, Inc. — monitoring and security (European Union).

Wrambox does not sell or transfer personal data to third parties for commercial or advertising purposes.

7. International transfers

Some data processors (Stripe, OpenAI and Anthropic) process personal data outside the European Economic Area, in the United States.

In such cases, the transfer takes place under the European Commission's Standard Contractual Clauses and, where applicable, the provider's certification under the EU-U.S. Data Privacy Framework, ensuring an adequate level of protection of personal data.

8. Data retention

Personal data will be retained for as long as necessary to provide the contracted services.

After the end of the contractual relationship, certain data may be retained for the periods required by applicable tax, commercial, administrative or fraud prevention legislation.

Once these periods have ended, data may be securely deleted.

9. User rights

The user may exercise the following rights at any time:

  • Right of access.
  • Right of rectification.
  • Right of erasure.
  • Right to restriction of processing.
  • Right to object.
  • Right to data portability.
  • Right to withdraw consent where processing is based on it.

To exercise these rights, the user may contact Wrambox via the email address indicated in the header.

The user may also lodge a complaint with the competent data protection supervisory authority.

10. Cookies and similar technologies

Wrambox may use cookies and similar technologies to ensure the functioning of the platform, improve user experience, strengthen security and obtain usage statistics.

Detailed information on these technologies is set out in a specific Cookie Policy.

11. Security

Wrambox applies appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, destruction or disclosure, including:

  • Encryption of data at rest (server disk encryption).
  • Encryption in transit via TLS.
  • Data isolation between accounts (row-level security in a multi-tenant environment).
  • Storage of passwords using robust hash functions.

These measures are reviewed periodically in line with the state of the art and existing risks.

12. Amendments to this privacy policy

Wrambox may amend this Privacy Policy when necessary for legal, technical, operational or commercial reasons.

Amendments will be communicated to users by email or through the platform itself.

The current version will always be available for consultation.