Spen AI

Privacy Policy

Last updated: 30 October 2026

This policy explains how Mazinger Ventures, S.L. processes personal data on spen.ai and in the Spen service, in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

1. Controller

2. Our role depending on who you are

3. What data we process, why, and for how long

PurposeDataLegal basisRetention
Answering enquiries and demo requestsEmail, name, company, messagePre-contractual steps at your request and legitimate interest in respondingUntil the enquiry is resolved plus 12 months
Creating and managing your accountName, email, phone number and Channel handle, company, job title, language, time zonePerformance of contractWhile the account is active
Providing the serviceContent from the Integrations you connect (emails, events, contacts, documents, CRM records, invoices, transcripts), messages and voice notes you send, Routines and preferences, Spen's context memoryPerformance of contractWhile the account is active; deleted within 30 days of closure, except backups, deleted within 35 days
Processing third-party data within your Content (senders, meeting attendees, contacts)Name, email, job title, company, communication content, public professional informationLegitimate interest of the User and Mazinger in delivering the requested featureSame as Content
Billing and legal obligationsTax details, payment historyLegal obligation6 years (Spanish Commercial Code) and tax limitation periods
Security, abuse prevention and activity logsIP address, device, access and action logsLegitimate interest in protecting the service12 months
Improving SpenAggregated or pseudonymized usage metrics (features used, errors, timings). Never the content of your emails or documentsLegitimate interest24 months
Sending Spen newsEmailConsent or, for customers, Art. 21.2 LSSI-CEUntil you unsubscribe
Cookies and web analyticsSee the Cookie PolicyConsent (except technical cookies)See the Cookie Policy

Voice notes are automatically transcribed so Spen can understand the request. The audio is kept with your conversations, like any other file you send, until you delete it or close your account.

4. What we do not do

5. Google and Microsoft data

Spen's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In particular:

We apply the same commitments to Microsoft 365 data and all other Integrations. You can revoke access at any time from Spen or from the security settings of your Google or Microsoft account.

6. Who we share data with

Only with the providers needed to deliver Spen, under data processing agreements, and with authorities where required by law. The current list of sub-processors is in the Annex to the Data Processing Agreement.

CategoryFunctionLocation
Infrastructure and hostingData and application hostingEuropean Union
AI model providers (currently including Anthropic, OpenAI, Google, MiniMax and open models hosted by Mazinger)Processing requests and generating OutputsUS, China and EU, depending on the model
Integration connectivityConnecting the tools you authorizeUS
Speech-to-textConverting voice notes to textEuropean Union (our own infrastructure)
Messaging Channels (Meta/WhatsApp, Slack, Microsoft, Telegram, SMS carrier)Communicating with youDepends on the provider
Payments, transactional email and supportBilling, notifications and customer supportEU and US

We use several model providers and may change them to deliver the best results. Before adding a new one we update the list and notify Business Customers under the Data Processing Agreement.

When you connect an Integration, Spen sends or updates information in that service on your instructions; that third party processes the data under its own policy.

7. International transfers

Some providers, particularly AI model providers, are located outside the European Economic Area. In those cases transfers rely on an adequacy decision (such as the EU-US Data Privacy Framework for certified providers) or on the European Commission's Standard Contractual Clauses, with supplementary measures where needed. Data is stored in the EU; model processing may take place outside it. You may request a copy of the safeguards at privacy@spen.ai.

Business Customers may request that their Content be processed only with EU-hosted models, or deploy Spen on their own infrastructure.

8. Security

We apply appropriate technical and organizational measures: encryption in transit and at rest, least-privilege access control, activity logging, customer isolation and incident management. If a breach poses a risk to your rights, we will notify it as required by the GDPR.

9. Your rights

You may exercise your rights of access, rectification, erasure, objection, restriction of processing and data portability, and withdraw your consent at any time, by writing to privacy@spen.ai and stating the right you are exercising. We will respond within one month.

If you believe we have not handled your request properly, you may lodge a complaint with the Spanish Data Protection Agency (aepd.es) or the supervisory authority of your country of residence.

10. Minors

Spen is not intended for anyone under 18. If we detect that a minor has registered, we will delete the account.

11. Changes

We may update this policy. For material changes we will notify you by email or within Spen before they take effect and, where they affect the use of Google data, ask for your consent again where required.