Finomo Terms of Service

1. Provider, nature of the service and contracting

1.1 Provider. Evgenii Ustinov, self-employed professional under the Finomo brand, NIF Z2074293C, Juan Caturla Gosalvez 2, 03005 Alicante, Spain. Support and complaints: support@finomo.es. Personal data: gdpr@finomo.es.

1.2 Nature of the service. Finomo develops and operates an invoicing and tax-return preparation software platform that the client accesses by subscription. The platform prepares drafts automatically from the data and documents provided by the client, applying the rules coded into the software; the client reviews and approves each return. Finomo does not provide tax, accounting or legal advice, does not assess the client's tax situation or decisions and does not make recommendations about their case. The provider does not present itself as a registered administrative agent (gestor administrativo), lawyer, auditor or tax adviser.

1.3 Acting before the AEAT. The intended route for Finomo to transmit returns on the client's behalf is a power of attorney registered in the AEAT Register of Powers of Attorney, sufficient for the specific procedure, accepted by the attorney where applicable, with a valid certificate, a verified channel and the identity check of clause 6.1. The client's approval of each return is the order for its transmission: with a registered and sufficient power of attorney, Finomo transmits to the AEAT, with its electronic certificate and through the official channel available for that form, exactly the approved version, with no human intervention in its content and without altering it. Without a power of attorney, Finomo does not act as the client's representative: the platform provides the client with the approved return's file in the AEAT filing format, with general instructions, and the client files it themselves. Finomo plans to offer in the future desktop and mobile applications from which the client will be able to transmit directly with their own certificate, without handing it over to Finomo; that route is not available today and is not part of this subscription.

1.4 Separate acts. These are separate acts and none replaces another: (i) subscribing; (ii) registering a power of attorney with the AEAT; (iii) approving a specific return, which constitutes the order for its transmission; (iv) authorising charges. Finomo does not perform any act requiring one of these elements unless it is on record as granted.

1.5 Contractual file. The service, its financial terms and its calendar are described in these terms and in the sheet; the specific details of each order (client identification, activation date, initial amount, coverage and renewal dates) are shown in the subscription process and in the confirmation. The file includes these terms, the Terms of Use and Subscription, the sheet, the annexes, the Privacy Policy, the Cookie Policy and the Data Processing Agreement, as well as the representation documents where they exist. An expressly agreed particular term prevails over the general term it modifies, subject to mandatory rules. Privacy information does not in itself amount to consent to any processing.

1.6 Electronic contracting process. Subscription takes place on the platform in the following steps: (1) selection of the monthly or annual plan; (2) presentation of the documents in the file, with their version indicated and the option to download them; (3) express and separate acceptance of (i) the terms and the sheet and (ii) the request for immediate start under clause 8.3; (4) confirmation via the button "Subscribe with obligation to pay"; (5) dispatch by e-mail, within the following 24 hours, of the confirmation with a PDF copy of the accepted texts, scope, price and dates. The contract is concluded in Spanish. Before confirming, the client can review and correct the data entered and download the documents. Finomo archives the contract and keeps it accessible to the client in their account. Acceptance of a contract does not in itself evidence that a tax filing has been made.

1.7 Subscription record. Finomo keeps a record of each subscription with the client's identification, the date and time, the IP address and user agent, the version and digital fingerprint (hash) of the accepted texts and the result of each acceptance. The following are recorded separately: acceptance of the contract and price; authorisation of recurring charges; authorisation of surcharges; the granting of the power of attorney; approval of each return; and the request for immediate start. No single checkbox is interpreted as all of those decisions. The record is kept for the duration of the contract and the limitation period for actions arising from it and is provided to the client on request.

2. Scope of the services

2.1 Subject matter. Through the subscription, Finomo makes available to the client a software platform comprising: (a) access for recording income and expenses, keeping the documents provided and, only once it is enabled for the client's account under clause 2.5, issuing invoices; (b) automatic preparation, from the data and documents provided by the client, under the rules coded into the software and with automatic consistency checks, of the drafts of forms 130 and 303 applicable to the client, of form 349 under clause 2.3, of form 390 under clause 2.2 and, where the client applies withholdings, of forms 111 and 190 under clause 2.7, with the rule of clause 2.2 for form 190; (c) transmission to the AEAT of each return approved by the client or, without a power of attorney, delivery of the file for filing by the client, under clause 1.3; (d) the corrections set out in clause 5. Each form is prepared when its generator is implemented on the platform and the form applies to the client according to the data recorded; the platform shows at all times which forms it can prepare and does not promise generators that are not yet available. The generators currently available prepare forms 130, 303 and 349; forms 390, 111 and 190 form part of the contractual scope and are prepared once their generator is implemented and they apply to the client under clauses 2.2 and 2.7. A return is not filed merely because its form appears in the application.

2.2 Annual forms 390 and 190. Preparation of the draft and ordinary transmission of form 390 in January are included at no extra cost only where there is an active subscription in January, on the filing date, even if the platform has prepared all the periods of the previous year. The same rule applies to form 190 where the client applies withholdings under clause 2.7. If the subscription ends on 31 December, the client must subscribe again for the platform to prepare form 390 and, where applicable, form 190 in January. The cancellation process expressly warns of this condition. The platform applies the coded rules on exemption from filing form 390 according to the data recorded by the client and shows the result before the year-end. Separate preparation of forms 390 and 190 is not offered to clients without an active subscription.

2.3 Form 349. Preparation of its draft and its transmission are included in the subscription at no extra cost, with any legally applicable frequency. The platform determines the obligation according to the transactions recorded, the VAT territory and the client's regime, without treating a pending ROI registration as the absence of an obligation. Monthly frequency is the general rule; quarterly frequency depends on the legal requirements for the current period and the four preceding ones. The coded rules apply the threshold and its composition in accordance with the instructions in force. The platform automatically checks VAT numbers in the VIES system where applicable and consistency with form 303; the result of that check does not by itself decide the tax classification of the transaction. ROI registration is not included. For the July period of the monthly form 349 the special official calendar applies; the internal documentation deadline is 5 August, with the shift provided in clause 3.2.

2.4 Software quality control. Before making a draft available to the client, Finomo may verify that the system is working correctly, that is, that the calculation follows the coded rules and the uploaded documents. This verification is a software quality control: it is not a review of the client's tax situation or decisions, does not constitute advice, never modifies the client's data and is not offered as a review service. Any error detected is corrected in the software. The verification is not performed at the client's request, does not replace their review of the draft (clause 10.2) and does not give rise to individual communications about their data. Finomo does not consult external professionals about a client's case.

2.5 Invoicing system and VERI*FACTU. Once invoice issuance is enabled for the client's account, the platform issues the client's invoices through Finomo's computerised invoicing system in VERI*FACTU mode. Invoice issuance is currently closed to clients and is enabled for each account only once VERI*FACTU transmission to the AEAT is operational for that account; until then the client may prepare invoice drafts, but the platform does not issue or number any final invoice. Sending invoicing records to the AEAT is a separate action from filing forms and requires its own authorisation: a specific power of attorney for that action or, once activated, Finomo's agreement with the AEAT as an invoicing system developer (type 17 agreement). Neither that agreement nor membership of the social collaboration scheme grants permission to file the client's forms; each procedure requires its own power of attorney. Activation of the sending, its date and its scope are recorded separately in the client's account; individual approval of a return does not extend to invoicing records. Structured business-to-business electronic invoicing has its own requirements and calendar; features the platform does not have available are not contracted.

2.6 Exclusions. The subscription does not include: (a) the client's registration or deregistration as a business owner or professional with the AEAT or Social Security, including ROI registration; preparatory use of the product before starting an activity does not include handling that registration; (b) drafting or filing replies to information requests, submissions, appeals or claims, and defending the client in any proceedings; (c) actions outside the accepted scope; corrections of earlier returns are included under clause 5; (d) tax, accounting, legal or any other advice; (e) the personal income tax return (form 100) of the client or of anyone else; (f) receiving, monitoring and handling AEAT notifications and communications addressed to the client, which the client receives and handles directly; (g) the special schemes for sales to final consumers in other Member States (OSS one-stop shop); (h) integrations or modules announced as future and, under clause 2.7, payroll management, withholdings on employment income and form 115. Where an excluded action is needed, the client chooses, engages and pays the professional of their choice. Taxes, interest, surcharges, penalties and third-party fees are not the price of Finomo's service.

2.7 Future features and current scope. Integrations or modules announced as future, including the applications with the client's own certificate referred to in clause 1.3, are not deemed contracted or available. In its current configuration, the generators available on the platform prepare forms 130, 303 and 349; the generators for forms 390, 111 and 190 are added once implemented, and the platform shows only those it can prepare. Once their generator is implemented, the platform prepares forms 111 and 190 solely for withholdings applied by the client to invoices received from professionals and recorded on it; it does not cover payroll management, withholdings on employment income or form 115. The service is currently provided only to clients in the common territory, excluding the Canary Islands, Ceuta and Melilla: clients whose tax territory is the Canary Islands, Ceuta, Melilla, the Basque Country or Navarre are not served. The platform indicates this during sign-up, before the client completes their other details and before any payment, and in those cases does not allow subscription. Features the platform does not have available are not promised.

3. Documentation and period preparation

3.1 Client information and automatic warnings. The client provides accurate, sufficient and up-to-date information, reports changes affecting the service and decides the data and options entered in each return. The draft is calculated solely from the data and documents recorded on the platform; transactions not recorded on it are not included. If the automatic checks detect missing information, contradictory information or a blocking issue, the platform warns in writing before the draft is approved, with a general explanation of the rule applied. These warnings are generated with the same rules for all clients; they do not constitute advice and do not tell the client which data to enter in their case. Unknown data is not automatically converted into zero amounts or a nil return. Finomo does not transmit returns containing data it knows to be false.

3.2 Ordinary calendar. For the periodic returns of forms 130, 303 and 349 and, where the client applies withholdings, form 111, the date for preparing the information is day 3 and day 5 of the filing month for each period is set as the internal deadline. If day 5 is not a working day under the Alicante calendar, the deadline moves to the next working day. Documentation is accepted without a late surcharge until the end of that day, in the Europe/Madrid zone; section C of the sheet specifies the calculation. For the monthly form 349, the internal deadline applies to the filing month of each monthly period. The shift does not by itself modify the official filing or direct-debit deadlines. The client may mark their data as ready before that date; the mark starts preparation of the draft, is not an approval of the return and does not guarantee the tax accuracy of the data. These dates are contractual rules. The automatic reminder of the preparation date, the data-ready mark, the automatic late-upload warning and automatic charging of the surcharge are not implemented on the platform today; the rules of this clause and of clause 7.5 apply nonetheless and will be executed on the platform once the late-documentation flow is operational. Until the mark is available, the client notifies in writing, through the channels of clause 3.5, that the documentation for the period is complete.

3.3 Availability of the draft and transmission. The platform makes the draft available to the client by the end of the working day following the date on which the client marks "all data ready", regardless of the time of that mark or, until the mark is available on the platform, notifies in writing under clause 3.2 that the documentation for the period is complete. After the client's approval, Finomo transmits the approved version, provided there is a registered and sufficient power of attorney, the check of clause 6.1 has been completed and an official channel and deadline are open; without a power of attorney, the file for filing by the client is provided after approval. Working days are Monday to Friday, excluding national, Valencian Community and local Alicante public holidays applicable in the relevant year, in Europe/Madrid. If information is missing, the platform indicates what is missing and its effect on the expected date; once all pending information has been received, the availability period is counted again until the end of the working day following the date of complete receipt. Partial delivery does not start that new period. Internal dates do not replace tax deadlines or specific direct-debit deadlines. The client is aware that late provision may prevent filing on time or direct debit of the payment and that surcharges, interest and penalties arising from a late filing are borne by them, without prejudice to clause 10.

3.4 Late documentation. Documents for the period received after the internal deadline are dealt with under the surcharge of clause 7.5 and section D of the sheet. Paying it does not by itself guarantee being able to file within the official deadline. Annual returns and corrections have their own calendar; day 5 does not automatically apply to them.

3.5 Channels and support. The working channels are the client area and the designated e-mail address. Data and documents are included in the calculation only when the client uploads or records them in the client area; the platform records their receipt and links them to the client and the period. Finomo does not enter, classify or confirm data on the client's behalf and does not include documents received by e-mail in the calculation. Messaging apps, where used, are reserved for technical support; they are not a channel for tax approval or for providing files. Support explains how the platform works and does not tell the client which data to enter in a specific case.

4. Approval, representation and result

4.1 Approval of each return. No return or correction is transmitted, and no filing file is provided, without the client's express and individual approval of the final draft; that approval is the transmission order or, without a power of attorney, the condition for providing the file under clause 1.3. Approval takes place on the platform; it shows the client, form, tax year, period, content, result and payment or refund method, and is recorded with the date, time, IP address and digital fingerprint of the approved draft. Finomo transmits exactly the approved version, without altering it; a change to the approved content requires a new approval. The client may withdraw approval up until the moment transmission begins. An automatic warning may be recorded and displayed with its general explanation, but the client's acceptance does not allow transmission or delivery of the file if the automatic checks indicate that substantial data needed to complete the return is missing. Residual warnings compatible with a complete return are documented without shifting Finomo's own errors onto the client. The subscription, silence, the data-ready mark and the existence of a power of attorney do not replace this decision by the client.

4.2 Representation. For transmission by Finomo, the client grants and registers the representation needed for the filing procedures in accordance with annex 1. Finomo checks its scope, validity and status, as well as the grantor's identity under clause 6.1, before acting. This contract does not replace registration of the power where the channel requires it. Revocation or limitation prevents the use of powers no longer available; in that case the platform provides the file for filing by the client under clause 1.3.

4.3 Result. The approved version, the approval evidence, the means of representation and the official result are retained. Transmission by Finomo with a valid representation 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 on the platform. A filing made by the client with the provided file is the client's own act. A draft, simulation or generated file is not identified as an accepted filing. In case of an uncertain result, its status is checked before repeating the operation.

4.4 Client funds. Finomo only receives the price of its services. It does not receive on the client's behalf their invoicing revenue, money for taxes or tax refunds. A filing, its payment and a refund are separate events. Any direct-debit action requires specific instructions and powers.

5. History and corrections

5.1 History. Importing history allows a distinction between "forms and receipts" and "forms, invoices and expenses". The cut-off date, periods, source, documents received, known limitations and values used in later calculations are documented. The import date does not replace the date of the historical event. Importing a return does not mean that Finomo filed it or that the platform has fully checked it; the filing of an earlier return is evidenced by its receipt with CSV, not by uploading a file.

5.2 Included corrections. Preparation of corrections to returns for the forms in clause 2.1, including returns filed before subscribing, and their transmission under clause 1.3 are included in the subscription. The correction is prepared with the form, tax year, reason and background recorded by the client, and the new approval and the receipt are retained. Each correction has its own calendar, notified when it is opened.

5.3 Correction route. The platform prepares each correction by the route resulting from the coded rules for the form and period (rectifying self-assessment, supplementary return or rectification request) according to the data recorded by the client, and shows before approval the route applied and a general explanation of the effects the regulations attach to it, such as surcharges and interest. This information does not constitute advice on the specific case. Replying to information requests, making submissions or lodging appeals is not part of the service (clause 2.6).

5.4 Migration. The absence of invoices in a forms-only migration does not allow expenses or deductions to be invented. Documents in the agreed historical archive for the initial migration to Finomo do not generate the €5 late surcharge, even if provided after day 5. Current documents outside that archive are subject to the ordinary deadlines and exceptions. The platform identifies the scope, periods and cut-off date of the migration when it is set up; using an import feature does not by itself turn a current document into part of the agreed historical archive.

6. Grantor identification

6.1 Grantor identity check. For registration and use of the power of attorney under clause 1.3, 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. Until the check is complete, Finomo does not use the power of attorney and the platform provides the file for filing by the client. Payment by card or payment link does not replace this check. Finomo keeps the copy of the document and the result of the check for the duration of the contract and five years after it ends, with restricted access, and uses them solely for this purpose. The client is not asked for statements about the origin of their funds or about public office, and no checks other than the grantor's identity are carried out.

7. Price, invoicing and payment

7.1 Price. The subscription has a single price: €25 per month or €250 for twelve full months, VAT included; the price of twelve months equals 10 monthly instalments. There are no other plans. The subscription includes up to 500 OCR document recognitions on the monthly plan or 6000 on the annual plan, and up to 5 GB of document storage in the account. When legally required, IRPF withholding on Finomo's invoices is identified on the invoice and the amount payable to Finomo is the price reduced by that withholding.

7.2 First period and promotions. The paid subscription starts from activation, with no standard free trial period. A promotion expressly identified in the subscription process may modify the initial terms; its duration, price and transition to the ordinary price are notified before subscribing. The first month is prorated for the remaining days of the activation month, including the activation day, in Europe/Madrid: M × R / D, where M is the monthly fee, D the actual days in the month and R the remaining days. The first annual period comprises that remainder of the month plus eleven full months, at the prorated annual price: A × (R / D + 11) / 12, where A is the annual price (€250). Section B of the sheet details the calculation; the initial amount, end date and subsequent renewal of each order are shown before subscribing. Shorter initial periods are not presented as twelve full months.

7.3 Renewal. The monthly plan renews on the 1st; the annual plan, on the 1st following the last covered month, for twelve full months. The current authorisation and any cancellation are respected. The date and amount of the next renewal are shown in the client's account. Finomo notifies the annual renewal, with its amount, on the day of the charge, the 1st.

7.4 Changes. Finomo notifies any change to the price or terms at least three months before it takes effect, identifying the new version, its scope and its effects, and a client who does not accept it may terminate the contract. On the annual plan, a new price applies from the first renewal taking place at least three months after the notification; the current annual period keeps its price. If the client terminates the contract because of a change to terms other than the price during an annual period already paid, the treatment of the amount corresponding to the unused part is determined under applicable mandatory law; these terms do not set a rule that reduces the client's legal rights. Services already accepted and mandatory rules are respected in all cases.

7.5 Late documentation surcharge. Each document for the period provided after the internal deadline gives rise to a €5 surcharge, VAT included, which is incurred when the document is processed on the platform and not when the unit is accepted. A document means each invoice, simplified invoice or receipt reflecting a separate transaction, regardless of the number of pages or of whether several documents are provided in the same file: a five-page invoice counts as one unit and a file with three separate invoices as three units. Once the late-documentation flow is operational, when a document is uploaded late the platform warns of the surcharge before the upload is confirmed; confirmation means acceptance of the specific surcharge, and before the platform includes the documents in the calculation the list of documents and the total are presented. That automatic warning is not implemented today; until it is, Finomo informs the client in writing, before invoicing, of the list of documents and the total, and the client's written confirmation counts as acceptance. No surcharge is incurred for: (a) duplicates; (b) the corrected version of a document already recorded, which replaces it without reflecting a new transaction; (c) payment receipts and clarifications that supplement a document already recorded without corresponding to a new transaction; (d) expressly agreed historical migration files; (e) documents whose late provision is due to a Finomo error; (f) cases of force majeure. A new independent document is assessed under the ordinary rules. Late issue or delivery by the supplier does not in itself remove the surcharge. There is no automatic exemption for providing it within the following three days. The cause and the decision are recorded. This surcharge does not apply to the exercise of rights over personal data and paying it does not guarantee filing on time.

Force majeure means an event beyond the reasonable control of the affected party which could not be foreseen or which, if foreseen, was unavoidable and which objectively prevented the document from being provided on time. The list of examples is open: serious illness or hospitalisation, disaster or widespread interruption of essential services or of the official channel, where there is an evidenced link with the delay. Evidence proportionate to each case is accepted. Ordinary workload, lack of organisation or the supplier's habitual delay are not sufficient on their own; nor is proven force majeure excluded merely because a third party was involved.

7.6 Invoicing of surcharges and due date. For the periodic documentation of the activity covered by this surcharge, the invoice is issued on the 1st of the month following the month in which the documents were processed, also on the annual plan or with a cancelled subscription; a unit accepted in one month and processed in the next is invoiced with those of the month in which it was processed. It identifies units, period and amount; it does not renew the subscription. It is payable within fifteen calendar days from the day after issue, with a last day falling on a non-working day moved to the next working day in the Alicante calendar, with the exact date on the invoice. Corrections and documents outside that period do not automatically receive this surcharge; they have their own calendar, notified when they are opened.

7.7 Methods and authorisation. A card with specific authorisation and a payment link are provided for, through the payment service provider Stripe. SEPA direct debit is not included. Saving a card or subscribing does not authorise surcharges; these require the corresponding consent as to units and amount. Subscription fees are charged for the amounts and on the dates indicated in the subscription process and on each invoice. Once the automatic surcharge charging feature is available, automatic charges are pre-notified to the client one week in advance: the surcharge invoice is issued on the 1st (clause 7.6) and the first charge attempt is made on the 8th of the same month; subsequent attempts follow clause 7.8. Automatic charging of surcharges is not implemented today; until it is, no automatic surcharge charge is made and surcharge invoices are paid by link within the period of clause 7.6.

7.8 Attempts, pauses and limit. Subsequent attempts are made every three calendar days within the payment period. Before repeating, payments and uncertain results are reconciled; while the client has an open payment-link session, no charge is initiated for the same amount. A payment by any route cancels pending attempts for the same debt. Once the effective payment period has elapsed, including its shift for non-working days, attempts are paused until the 1st of the following month. Resumption requires an outstanding balance, a valid authorisation and three calendar days' prior notice, calculated in Europe/Madrid, identifying the date, the outstanding amount and a link to pay independently. This notice is separate from the one-week pre-notification of clause 7.7. The maximum horizon for automatic attempts comprises the initial month and two additional monthly cycles, with the agreed pauses; after that the balance goes to manual review and any later payment is arranged by link, without new automatic orders. No further invoice is issued for the same documents and no unagreed penalties are added. Notices are sent when the invoice is issued, after a confirmed failed charge attempt and before charges resume; a pending or uncertain result is not communicated as a confirmed failure. No amount is charged twice; duplicate charges are refunded on Finomo's own initiative within five working days of detection.

7.9 Withdrawal of authorisation and stopping. The client may withdraw the charging authorisation at any time from their account or by e-mail; withdrawal stops charges not yet sent and does not affect operations already initiated or amounts already invoiced, which remain due and can be paid by link. The authorisation is limited to amounts invoiced under these terms; the existence of a debt does not extend its scope. Finomo may stop automatic attempts earlier and inform the client of the invoice status and payment options through the client area and by e-mail throughout the process; stopping does not extinguish the debt or reverse an operation already sent to the provider.

7.10 Non-payment. A pause in charge attempts does not by itself suspend the service. If an invoiced amount remains unpaid one month after the end of its effective payment period, the service is suspended and Finomo notifies the client at the time of suspension. For surcharges, the period of clause 7.6 applies; for subscription fees, the payment period and reference date appear on the relevant invoice. During suspension, the platform does not prepare new returns and Finomo does not transmit them; returns already approved by the client are transmitted or, without a power of attorney, their file is provided under clause 1.3, and the known official deadlines are communicated to the client. Once the collection cycles of clause 7.8 have been exhausted and after manual review of the balance, Finomo notifies termination of the contract in writing with a specific date. The debt does not condition viewing and downloading within the archive period or data rights. Interest, collection costs and mandatory consequences are examined within their actual scope, without adding automatic penalties not accepted.

8. Cancellation, withdrawal and legal rights

8.1 Cancellation. The client may cancel the renewal from their account, as easily as they subscribed, or notify support@finomo.es. Finomo confirms the end date of the paid period and the deactivation of the next renewal. Ordinary cancellation keeps the service until that date and does not by itself give rise to a refund of the remaining period, except in the cases of clauses 7.4 and 10 or where a mandatory rule provides otherwise. After the end of the period, the client keeps view-and-download access under clause 9.3.

8.2 Guarantees. The mandatory rights of withdrawal, termination, refund and liability are preserved. No clause of these terms is interpreted as a waiver of them.

8.3 Immediate start. The client expressly requests that performance begin from activation, without waiting for any withdrawal period to elapse. The request is recorded as a separate act and, where the client is legally entitled to the right of withdrawal, has the effects set out in clause 8.4.

8.4 Legal withdrawal. Where the client is legally entitled to the right of withdrawal, they have fourteen calendar days from conclusion of the contract to exercise it by any unequivocal statement addressed to support@finomo.es or to the provider's address. The legal extension for lack of information and the other mandatory rules are respected. If the client validly requested immediate start, was informed and withdraws, 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. The refund is processed by the same payment method, without undue delay and no later than fourteen calendar days after the date on which Finomo is informed of the withdrawal. Loss of the right requires full performance, prior express consent and informed acknowledgement, with separate evidence. Annex 5 contains the withdrawal information and form.

8.5 Purpose of the contract and mandatory rights. 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 these terms excludes the rights that legally apply; commercial cancellation is governed by clause 8.1.

9. End of service and continuity

9.1 Inventory before termination. Before termination, pending returns and corrections and their known dates are identified, including approved returns awaiting transmission. Cancellation of renewal does not by itself interrupt services during the paid period. If an incident prevents continuation, Finomo informs the client and provides the documentation needed for the client to arrange the filing of pending returns.

9.2 Pending forms 390 and 190. If the subscription ends before the January filing, Finomo informs the client that form 390 and, where the client applies withholdings, form 190 will not be prepared or transmitted without a new active subscription, and provides the data for the client to arrange their filing. The existence of those pending forms does not authorise renewing or automatically charging a cancelled subscription.

9.3 Archive after closure. 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 end-of-access and planned deletion date, and updates it when the download is verified. Later downloads do not restart the period; an incomplete or defective delivery attributable to Finomo must be corrected and does not shorten the right of access. A click, a partial export or a failed transfer do not prove complete receipt. An initial notice is sent at closure. Reminders are then sent every fourteen days during the first three months from closure and every seven days thereafter. During the last calendar month before the effective planned deletion date they are sent every three days, taking precedence over the previous frequency. All e-mails in this cycle state the specific date; the information is also available in Finomo. After the complete download, the new date is notified and the reminder text is adapted. Closure occurs when the service actually ends; cancelling the renewal does not bring closure 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 of the subscription or revocation of a power of attorney is required to view, download or exercise data protection rights. When access ends, data that no longer needs to be kept is deleted. Evidence needed under an applicable obligation or to deal with liabilities is separated by documented category, purpose, access and period, with restriction and, where appropriate, blocking. The entire file is not kept indiscriminately. Backups follow their own cycle and a restore re-applies deletions and restrictions before data is re-enabled. The archive period does not replace the legal retention periods, which are detailed in the Privacy Policy.

9.4 Powers of attorney on termination. When the service ends, the inventory of pending returns, known dates, instructions that end and powers of attorney no longer needed is identified. Ordinary use of powers outside the engagement is deactivated. Finomo asks the client to revoke powers that are no longer needed and checks the result through an official source; a request does not evidence revocation. If after closure the power of attorney in favour of Finomo remains in force, the platform reminds the client periodically and offers the choice of revoking it or continuing with the service. The client's silence is interpreted neither as consent nor as revocation, and Finomo does not revoke the power on the client's behalf. Finomo may renounce the power of attorney in accordance with the applicable official requirements, notifying the client beforehand and without leaving already approved returns unattended. The power does not renew the subscription and its validity does not by itself extend the archive. Rights and actions already arisen are preserved.

10. Diligence, liability and insurance

10.1 Diligence. Finomo provides the service with the diligence required of a provider of tax software and return transmission: it keeps the rules coded into the platform in line with the regulations applicable to each tax year and period and with the administrative criteria in force, and transmits the approved version without alteration. The client's approval does not remove Finomo's liability for its own errors in the software, calculation, transmission or execution.

10.2 Client obligations. The client provides accurate and complete documentation within the deadlines of clause 3, decides the data and options for each return, reviews drafts before approving them, responds to platform warnings, keeps their contact and payment details up to date and keeps their own copies of the documentation for the legal periods. That obligation does not exempt Finomo from displaying the warnings generated by the automatic checks.

10.3 Correction guarantee. If a return prepared by the platform contains an error attributable to Finomo, in particular in the coded rules, the calculation or the transmission, Finomo fixes the software and makes the correction available to the client at no extra cost as soon as the error becomes known; with a power of attorney, it transmits it after the client's approval and, without one, the platform provides its file under clause 1.3. This guarantee is independent of liability for damages.

10.4 Liability. Finomo is liable, under applicable law, for damage caused by breaches attributable to it. These terms do not establish a contractual monetary cap on liability, an automatic exclusion of loss of profit or indirect damage, or a waiver of mandatory rights.

10.5 Non-attributable cases. Finomo is not liable for damage arising from: (a) incomplete, inaccurate or late data or documents provided by the client, where the platform warned of this under clause 3.1 or where the inaccuracy was not detectable by the automatic checks required by the diligence of clause 10.1; (b) original acts of third parties not attributable to Finomo, without excluding Finomo's liability for the included correction it has undertaken; (c) unavailability of the AEAT electronic office or the payment provider, provided Finomo shows that it attempted the action on time and warned the client; (d) force majeure under clause 7.5. These exclusions are not a general exemption and are interpreted restrictively. In case of an incident, the cause, actions, consequences and corrective measures are documented; tax amounts and their ancillary items are examined according to their nature, causation and responsibility, without automatically assigning them to one party.

10.6 Insurance. Finomo does not currently hold a professional liability insurance policy; taking one out is planned immediately after the commercial launch of the service. Until then, Finomo meets the liability of clause 10.4 from its own resources. No coverage, insurer or insured sum is promised; the policy, once in place, does not replace or limit the applicable liability.

11. Confidentiality and data protection

11.1 Confidentiality. Access is limited to authorised persons and documented purposes. Finomo does not consult external professionals about a client's case and does not disclose their data to them for that purpose. The recipients and providers involved in the processing are identified in the Privacy Policy and the Data Processing Agreement.

11.2 Roles. Finomo acts as controller for the client's identification data, including that of the check in clause 6.1, and for subscription, invoicing, payment and security data. Finomo acts as processor for third-party data included in the client's invoices, ledgers and documents and for the automatic preparation of the returns relating to their business and their transmission to the AEAT or delivery of the file for filing by the client, under the Data Processing Agreement. Approval of a return and the power of attorney do not alter this classification.

11.3 Rights. Rights over personal data may be exercised at gdpr@finomo.es or through the procedure provided in the product, without needing an active subscription or paying a debt.

12. Versions, translations, complaints and jurisdiction

12.1 Versions. Each version of these terms is identified by its edition and date and its predecessor is retained. The client's acceptance is recorded immutably with the digital fingerprint of the accepted text; a later version does not replace that record. Every new subscription requires acceptance of the version in force at that time. Changes to the price or terms during the contract are governed by clause 7.4.

12.2 Translations. The contract is concluded in Spanish, which is the authentic version. Finomo provides informational translations into Russian, English and Ukrainian, identified with the version, date and link of the Spanish text they correspond to. In case of discrepancy the Spanish version prevails. Translations neither add nor remove rights or obligations. The client's account identifies the language and the versions actually delivered.

12.3 Complaints. Received at support@finomo.es and at the provider's address; receipt, follow-up and a reasoned reply within the applicable period are recorded. Official complaint forms are provided where applicable.

12.4 Law and jurisdiction. Spanish law and applicable mandatory rules. Jurisdiction is determined according to the rules of the case, including consumer protection rules where applicable. Tax residence does not replace the relevant domicile. No arbitration is imposed, nor any submission to Alicante that would deprive the client of a mandatory forum.

Operational documents in the file

The representation engagement (annex 1), the approval of each return (annex 2), the closure and archive communications (annex 3), grantor identification (annex 4), the withdrawal information (annex 5), the Privacy Policy, the Cookie Policy and the Data Processing Agreement specify the scope and facts of each file. Their applicable versions are identified in the client's account and copies are delivered with the subscription confirmation. Exit and any renunciation of the power of attorney are arranged under clause 9.4; an ordinary e-mail does not by itself amount to a deregistration in the AEAT register.