Finomo Operational Annexes

Annex 1. Representation engagement before the AEAT

1.1 Parties. The client, identified in their account by name and NIF (and, if acting through a representative, the representative's identity and title), engages Evgenii Ustinov, NIF Z2074293C, under the Finomo brand, with registered address at Juan Caturla Gosalvez 2, 03005 Alicante, to file with the AEAT, on their behalf, the returns described in this annex. Contact: support@finomo.es; personal data: gdpr@finomo.es. This document sets out private instructions between the client and Finomo; it does not by itself evidence registration of a power of attorney in the AEAT Register of Powers of Attorney.

1.2 Representation route. The route is a power of attorney registered in the AEAT Register of Powers of Attorney, checked for each procedure. Without a usable power of attorney, Finomo does not act as the client's representative and the platform provides the file for self-filing (section 2.4 of annex 2).

1.3 Actions engaged. With the corresponding power of attorney, Finomo may transmit: the periodic returns of forms 130 and 303; the recapitulative statement of intra-Community transactions (form 349), monthly or quarterly as applicable; the annual summary (form 390); where the client applies withholdings to invoices from professionals recorded on the platform, forms 111 and 190; and corrections of returns, whether the client's own or predating Finomo, by the route resulting from the coded rules (terms 5.3). Sending VERI*FACTU invoicing records is a separate action that requires its own authorisation and is activated separately. Drafts are prepared automatically by the platform from the client's data and documents (terms 2.1). Each version to be filed requires the client's express and individual approval, which constitutes the order for its transmission; Finomo transmits it with its electronic certificate, through the official channel available for that form, with no human intervention in its content and reproducing exactly the approved version. The code and scope of each procedure are checked against the AEAT catalogue of procedures that may be delegated before the power is used; the status of each power of attorney is shown in the client's account.

1.4 Actions not engaged. Not included: registration or deregistration as a business owner or professional or ROI registration; drafting or filing replies to information requests, submissions or appeals; representation in verification or inspection proceedings; the personal income tax return (form 100); or receiving or handling AEAT notifications (terms 2.6).

1.5 Power of attorney and control of instructions. The client grants, by a means accepted by the AEAT, the necessary powers in favour of the identified representative, procedure by procedure. Finomo accepts the power of attorney with its certificate where the procedure requires it, checks the grantor's identity under annex 4 as well as the scope, validity and status of the power, informs the client of the effective date and keeps the evidence of registration and acceptance. Finomo does not ask the client for their private key, Cl@ve password or certificate. A broader authorisation in the Register does not extend the contracted services. If a sufficient power is missing, the check of annex 4 has not been completed or there is a discrepancy, Finomo does not use the power for the affected action and informs the client of the missing element; the client may file the return themselves with the file of annex 2. Silence, payment of the subscription, the existence of a power or marking data as ready do not authorise a filing.

1.6 Effects, payments and receipts. Transmission by Finomo with a valid power and a recorded approval has the effect of a filing by the client; the receipt with secure verification code (CSV) is made available to the client. Finomo only receives the price of its service and does not receive on the client's behalf their income, tax refunds or funds intended for paying taxes (terms 4.4). The tax result and the payment or refund method are shown for approval; a direct debit requires a specific instruction from the client. The filing receipt and the payment receipt are kept separately.

1.7 Termination, limitation, revocation and renunciation. Cancelling the renewal keeps coverage until the end of the paid period. The client may earlier notify a limitation or withdrawal of instructions to support@finomo.es or from Finomo; new affected actions are stopped and the result of those already transmitted is checked. This notice does not erase a filing already made and does not replace revocation before the AEAT. If the client limits or revokes the power, the affected returns may be filed by the client themselves with the file of annex 2 (terms 4.2). When the service ends, pending returns, known dates, instructions that end and powers no longer needed are identified. Finomo asks the client to revoke unnecessary powers and checks the result through an official source; a request does not evidence revocation. If after closure the power of attorney remains in force, the platform reminds the client periodically and offers them the choice of revoking it or continuing with the service; their silence is neither consent nor revocation and Finomo does not revoke the power on their behalf. Finomo may renounce the power of attorney in accordance with the official requirements, notifying the client beforehand and without leaving already approved returns unattended (terms 9.4). The power does not renew the subscription or extend the archive.

1.8 Acceptance. The engagement is accepted on the platform with the following text: "I engage the actions identified in this document, with the limits and conditions indicated. I understand that I must grant the applicable powers of attorney before the AEAT, procedure by procedure, that Finomo will not use the power until it has verified my identity as grantor under annex 4, and that I must approve each return before its transmission. I have received a copy that I can keep." The identity of the accepting person, the date, the means of acceptance and the full version delivered are recorded in the client's account.

Annex 2. Approval of a return or correction

2.1 What is approved. Before requesting your approval, the platform shows you: the taxpayer and their NIF; the form, tax year and period (130, 303, 349, 390, 111 or 190); whether it is an initial return or a correction and, in the latter case, the route applied under the coded rules (rectifying self-assessment, supplementary return or rectification request) with a general explanation of its effects (terms 5.3), as well as the earlier return being corrected, its reference with CSV and the reason you recorded; an understandable summary of the calculation (bases, amounts, deductions and differences from the previous version) and, for form 349, the list of counterparties with their VAT number, the VIES check result, keys and amounts; pending automatic warnings with the general explanation of the rule applied; the result (payable, refundable, to offset, no activity or other) and its amount; the accepted payment or refund method, with amount, dates and a securely identified account; the official deadline and the expected filing date; the filing route (transmission by Finomo with a power of attorney, indicating the representative Evgenii Ustinov, NIF Z2074293C, and the channel, or self-filing with the file of section 2.4); a full copy to review and keep; and the digital fingerprint and version of the package that will be transmitted or whose file will be provided to you. A technical fingerprint does not replace readable information.

2.2 Express statement. Approval is made with the following text: "I have been able to review and keep the identified return and its payment or refund instructions. I approve this version and order Finomo to transmit it to the AEAT through the indicated channel, without alteration and within the limits of the power in force" or, without a power of attorney, "I request its file in the AEAT filing format so that I can file it myself". In both cases: "If its content or the approved instructions change, my approval must be requested again."

2.3 Limit of approval. If the automatic checks indicate that substantial data needed to complete the return is missing, it is neither transmitted nor its file provided; accepting an automatic warning does not cure the absence of data or shift Finomo's own errors onto the client. Residual warnings are recorded only if compatible with a complete return. Approval does not mean accepting a different return, waiving rights against a Finomo error or authorising a charge for additional services. Where the tax payment requires a specific authorisation, it is collected separately. Approval may be withdrawn from Finomo or via support@finomo.es until transmission begins; a withdrawal does not by itself cancel a return already filed.

2.4 Record and result. For each approval the following are recorded: the identity and authentication of the approver; the express action with date, time, time zone and IP address; the text displayed, the full document and its fingerprint; the separate confirmation of a draft with a residual warning, if any; the earlier approval replaced or withdrawn; the copy delivered; the prior check of power, engagement and grantor identity, if Finomo transmits; the transmission status (pending, blocked, uncertain result, accepted or rejected); the file provided to the client without a power of attorney, with date, format and fingerprint; the official response with date, reference, receipt and CSV or, if the client files, the receipt they provide; and the status of the tax payment, with its separate receipt. An approval, a technical submission or delivery of a file is not communicated as acceptance by the AEAT or as a completed filing. If the result is uncertain, it is checked before repeating.

2.5 Without a power of attorney: file for filing by the client. Without a power of attorney registered and sufficient for the procedure, or until the check of annex 4 has been completed, Finomo does not act as the client's representative and does not transmit the return. After your approval, the platform provides you with the file of the approved version in the AEAT filing format, identified by its fingerprint, together with general instructions for filing, and you file it yourself through the official channel (terms 1.3). The instructions are the same for all clients and describe the procedure for filing the file; they do not indicate which data to enter or assess the specific case. The filing you make with the file is your own act (terms 4.3). Delivery of the file does not extend the official filing or direct-debit deadlines. You may add to Finomo the receipt with CSV of your filing so that it appears in your history.

Annex 3. Closure of the service, powers of attorney and archive

3.1 Closure protocol. Effective closure is distinguished from mere cancellation of the renewal. At closure, pending returns and corrections, including approved returns awaiting transmission, their known dates and the powers no longer needed are inventoried (terms 9.1 and 9.4). Finomo asks for unnecessary powers to be revoked and checks the official result. If after closure the power remains in force, the platform reminds the client periodically and offers them the choice of revoking it or continuing with the service; their silence is neither consent nor revocation and Finomo does not revoke the power on their behalf.

3.2 Cancellation confirmation. When cancelling the renewal, the client receives a confirmation stating the date and time (Europe/Madrid) at which the paid period ends, the expected effective closure date, the inventory of pending returns or corrections with their status, official deadline and next action, and any outstanding invoices. Where applicable, they are reminded that for the platform to prepare and Finomo to transmit form 390 and, if they apply withholdings, form 190 in January, an active subscription in that month is needed; without it, they are provided with the data to arrange their filing. That communication does not renew or charge the subscription. The confirmation also states the specific date until which they can view and download their file free of charge.

3.3 Powers in force after closure. If Finomo finds that powers no longer needed for the terminated service remain in force, it informs the client, identifying each power, its procedure and scope, its verified status and the reason for termination. While those powers remain in force, Finomo continues to appear as attorney before the AEAT. The client is asked to choose between revoking them through an accepted official channel, providing the receipt in Finomo, or continuing with the service. If you do not reply, it will not be understood that you consent or that you revoke, and Finomo will not revoke the powers on your behalf. This message does not evidence that the power is revoked and does not extend the subscription; access to the archive does not depend on this step.

3.4 Renunciation by the representative. Finomo may renounce a power of attorney in accordance with the applicable official requirements. Before doing so it checks pending returns and their effects, and informs the client of the powers it is renouncing, the reason, the handling of pending returns until it takes effect and the archive end date. Effectiveness is checked through the AEAT channel and notified with a receipt. The renunciation does not cause the client to waive rights against Finomo.

3.5 Verified result. When Finomo verifies the status of a power at the official source, it informs the client of the date, the source, the power, its status, the effective date and the receipt. If the result is unknown, this is expressly stated together with the next planned action.

3.6 First complete download. When the first complete receipt of the archive after closure is recorded, Finomo notifies the date and time of receipt, the reference and version of the archive and the new end-of-access date, three calendar months later, inclusive. Later downloads do not restart that period. If you detect an incomplete or defective delivery, report it to support@finomo.es; Finomo will check the case before carrying out a deletion that depends on that receipt.

3.7 Reminders and planned deletion. Each reminder states whether or not the complete download is on record, the specific and inclusive date on which access ends and the possibility of downloading the complete archive in the protected area of Finomo. After that date, data with no retention obligation is deleted and evidence that must be kept for its own purpose and period is restricted. The tax archive is not attached to the reminders. Data protection rights may be exercised at gdpr@finomo.es without an active subscription.

3.8 Archive and notice rule. After the service has actually ended, the client keeps free access to view and download their file for six calendar months if complete receipt of the archive is not on record. Once the first complete download after closure is confirmed, access ends three calendar months later, even if the date is after the initial six-month limit. Finomo notifies the specific date and updates it when the download is verified. A click, a partial export or a failed transfer do not prove complete receipt. An initial notice is sent at closure; then reminders every fourteen days during the first three months and every seven days thereafter; during the last calendar month before the planned deletion date, every three days. Closure occurs when the service actually ends; cancelling the renewal does not bring it forward. Calendar months are calculated in Europe/Madrid, adjusting to the last day of the month where appropriate, and access lasts until the end of the notified day. The temporary ZIP expires after seven days but can be regenerated while access is open. No payment of a debt, renewal or revocation of a power is required to view, download or exercise rights. When access ends, data that no longer needs to be kept is deleted; evidence needed under an applicable obligation is separated by category, purpose, access and period, with restriction and blocking where appropriate. Backups follow their own cycle and a restore re-applies deletions and restrictions. Persistent delivery failures, an incomplete or inaccessible archive and disputes about receipt are reviewed with a named person and date before any automatic deletion; an incident does not authorise unlimited retention.

Annex 4. Grantor identification

4.1 Check. For registration and use of the power of attorney (terms 6.1 and annex 1), the client uploads to the platform a copy of their identity document (DNI, NIE or TIE) and Finomo uses it to check that the account holder is the grantor named in the power of attorney. Payment by card or link does not replace this check. Finomo does not ask the client for their private key, Cl@ve password or certificate, and does not ask for statements about the origin of their funds or about public office.

4.2 Effects. Until the check is complete, Finomo does not use the power of attorney and the platform provides the file for filing by the client under annex 2. If the copy of the document is not uploaded or the account holder does not match the grantor, the check is not completed and the platform states the reason.

4.3 Use and retention. Finomo keeps the copy of the identity document and the result of the check for the duration of the contract and five years after it ends, with access limited to authorised persons, and uses them solely for this purpose. This period is independent and does not depend on the archive period of annex 3. Finomo processes this data as controller (terms 11.2 and Privacy Policy).

4.4 Record. The client's account shows the grantor and the power of attorney to which the check relates, the document type (DNI, NIE or TIE), the upload date of the copy, the date and result of the check and the evidence reference.

Annex 5. Information on the right of withdrawal

This information forms part of the contractual file (terms 1.5) and applies where the client is legally entitled to the right of withdrawal (terms 8.4). The real purpose of the contract, and not merely holding a business or professional NIF, determines whether mandatory consumer protection rules apply; no label in the terms excludes the rights that legally apply (terms 8.5).

Provider: Evgenii Ustinov, Finomo, NIF Z2074293C, Juan Caturla Gosalvez 2, 03005 Alicante. Communications: support@finomo.es.

Right of withdrawal. You may withdraw from the contract within fourteen calendar days of its conclusion, without giving reasons, by any unequivocal statement addressed to support@finomo.es or to the provider's address before the period ends. You may use the form below or your own written notice. The legal extension of the period for lack of information and the other mandatory rules are respected. Finomo refunds the amount due by the same payment method, without undue delay and no later than fourteen calendar days after the date on which it is informed of the withdrawal.

Immediate start and proportional payment. If you validly requested immediate start of performance (terms 8.3), were informed and withdraw, only the amount proportional to the part of the service actually provided up to notice of withdrawal is due. Without the legal requirements for claiming that amount, no charge is made for merely opening an account or receiving documents, and no automatic minimum is applied for withdrawing.

Loss of the right. Loss of the right requires full performance of the service, the client's prior express consent and their informed acknowledgement of this consequence, with separate evidence. Opening the account or providing documents does not by itself mean losing the right.

Withdrawal form (optional). You may copy and complete the following text: "To Evgenii Ustinov, Finomo, Juan Caturla Gosalvez 2, 03005 Alicante, support@finomo.es. I hereby give notice that I withdraw from my contract for the provision of the following service: (state the service and your order reference). Contracted on: (contract date). Client name: (your name). Client address: (your address). Date: (date of this notice). Client signature, only if submitted on paper."

The form is not mandatory. Renewing, paying another fee or revoking a representation is not required in order to give notice of withdrawal. The consequences for pending actions are arranged separately and communicated to you.