Privacy Policy

Effective Date: August 28, 2026

Viva Mortgages Spain SL ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you, in compliance with the General Data Protection Regulation (GDPR) and Spanish data protection laws (LOPDGDD 3/2018).

1. Information We Collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data: includes billing address, email address and telephone numbers.
  • Financial Data: includes bank account, salary documentation, credit history, and details required for mortgage applications.
  • Technical Data: includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform.

2. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you (e.g., providing mortgage brokerage services).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

3. Disclosures of Your Personal Data

We may have to share your personal data with internal and external third parties, including:

  • Spanish registered banking institutions and lenders to facilitate mortgage pre-approval and applications.
  • Professional advisers including lawyers, bankers, auditors, and insurers based in Spain.
  • Regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Service providers acting on our instructions (see section 5).

4. AI-Assisted Processing

To prepare your mortgage evaluation efficiently, we use artificial-intelligence (AI) tools that assist our team. These tools help us: read and summarise the documents you provide (for example passports, payslips and bank statements) and check them for completeness and consistency; prepare bank recommendations for your advisor to consider; direct your enquiry to the most suitable advisor; and research public information such as regional tax rates.

These tools assist our staff — they do not make decisions about you on their own. Every recommendation, evaluation or communication that affects you is reviewed and approved by a licensed human advisor before it is acted on, and the decision on any mortgage application is always made by the lending bank, not by us and not by any automated system. We do not make decisions producing legal or similarly significant effects on you based solely on automated processing (Article 22 GDPR).

Where AI tools process your information, the data is transmitted to our AI service provider (Anthropic — see section 5) under a data-processing agreement, and it is not used to train AI models.

5. Our Service Providers

We use a small number of carefully selected service providers who process personal data on our behalf under data-processing agreements, and only on our instructions:

  • Anthropic: AI processing that assists our team as described in section 4 (United States; transfers safeguarded by approved mechanisms under Chapter V GDPR).
  • Google Cloud / Firebase: secure hosting of our client platform, authentication, database and document storage.
  • Vercel: hosting of our website and client platform.
  • HighLevel (LeadConnector): our customer-relationship system, used to manage enquiries and send you emails and messages about your application.

We retain the documents you provide, and any AI-assisted analysis of them, only for as long as needed to provide our services and to meet our legal obligations, after which they are deleted.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.

7. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at info@vivamortgagesspain.com.