Terms and Conditions of Use — SES Peregrino

Article 1. Purpose and Scope

1.1. These Terms and Conditions govern access to and use of the SES Peregrino mobile application, developed and operated by Wise Pilgrim SL, based in Galicia, Spain.

1.2. SES Peregrino helps accommodation providers in Spain comply with guest registration obligations under Royal Decree 933/2021 and the SES.HOSPEDAJES system of the Ministry of Interior.

1.3. The Application enables:

1. Scanning traveler identity documents or QR codes to capture registration data.
2. Generating XML files required by SES.HOSPEDAJES.
3. Preparing and facilitating the submission of guest registrations to the Ministry of Interior. The accommodation provider remains solely responsible for the timely and accurate submission of all required data to government systems.
4. Storing encrypted guest registration data on Wise Pilgrim's cloud infrastructure for the retention period required by law (see Article 5).
5. Publishing accommodation listings — including property name, address, contact details, services, and pricing — in Wise Pilgrim's applications and guides (see Article 7).
6. Receiving and answering bed requests from pilgrims through the optional "Saved beds" service (see Article 7A).

1.4. By using the Application, you accept these Terms in full.

1.5. The Application is provided free of charge. Wise Pilgrim reserves the right to introduce paid features in the future with at least 60 days' notice. Core compliance functionality will remain free.

Article 2. Eligibility

2.1. The Application is intended for owners or legal representatives of accommodation establishments in Spain required to register guests under Royal Decree 933/2021.

2.2. You must: (a) be at least 18 years old; (b) have legal capacity to enter into agreements; (c) be the registered owner or authorized legal representative of a Spanish accommodation establishment; and (d) hold valid, current SES.HOSPEDAJES credentials.

2.3. You represent and warrant that all eligibility information provided is accurate. Wise Pilgrim reserves the right to verify eligibility at any time and to suspend accounts where eligibility cannot be confirmed.

2.4. If your SES.HOSPEDAJES credentials expire or become invalid, submission functions may be restricted. You are responsible for maintaining valid credentials with the Ministry of Interior. Wise Pilgrim is not liable for penalties resulting from expired or invalid credentials.

Article 3. Account and Security

3.1. Use of the Application requires creating an account with accurate, up-to-date information.

3.2. You are responsible for keeping your account credentials confidential.

3.3. SES.HOSPEDAJES credentials are stored in your device's secure keychain (iOS Keychain or Android Keystore) and are never transmitted to Wise Pilgrim servers.

3.4. Zero-Knowledge Encryption. All guest personal data is encrypted on your device using AES-256-GCM encryption with a key derived from your password via PBKDF2-SHA256. Encrypted data is stored on Wise Pilgrim's cloud infrastructure, but Wise Pilgrim does not possess, store, or have access to your encryption key. This means Wise Pilgrim cannot view, access, or decrypt your guest data under any circumstances.

3.5. Recovery Code. Upon account creation, you will receive a unique recovery code. This code is your only means of regaining access to your encrypted data if you forget your password. You must store this recovery code securely in a location separate from your device (for example, a printed copy in a safe or a separate password manager).

3.6. PERMANENT DATA LOSS WARNING. If you lose both your password and your recovery code, your encrypted guest data is permanently and irreversibly unrecoverable. Wise Pilgrim cannot recover, restore, or decrypt this data under any circumstances. This is an inherent consequence of the zero-knowledge encryption architecture, which ensures that no one — including Wise Pilgrim, law enforcement, or any third party — can access your guest data without your key. By using the Application, you acknowledge and accept this risk.

3.7. Device Security. You are responsible for the physical security of any device used to access the Application. Wise Pilgrim recommends: (a) enabling a strong device passcode or biometric lock; (b) enabling remote wipe capability; (c) keeping your device operating system updated. If your device is lost or stolen, you should change your account password immediately and, if you believe guest data may have been compromised, follow the breach notification procedures required by GDPR and Royal Decree 933/2021.

3.8. Password Changes and Re-Encryption. Because of the zero-knowledge encryption architecture, changing your password requires re-encrypting all stored guest data. When you initiate a password change, the Application will: (a) create a temporary backup copy of your encrypted data on Wise Pilgrim's servers; (b) download your encrypted records to your device in batches; (c) decrypt each batch using your old password-derived key; (d) re-encrypt each batch using your new password-derived key; and (e) upload the re-encrypted batch to Wise Pilgrim's servers before processing the next batch. Records are processed in batches to minimise the volume of data held in decrypted form on your device at any given time. This process may take significant time depending on the volume of stored guest data.

3.9. Re-Encryption Safeguards. During the re-encryption process described in Article 3.8: (a) you must not close the Application, switch to another application, or lose network connectivity — an interruption may result in data corruption or loss; (b) a temporary backup copy of your data (encrypted with your old key) is retained on Wise Pilgrim's servers to allow restoration if the process fails; (c) upon completion, you will be asked to confirm in the Application that the password change was successful; (d) Wise Pilgrim will then separately verify and confirm with you that the re-encryption completed successfully before deleting the temporary backup copy. The backup copy is not deleted automatically — it is retained until Wise Pilgrim has confirmed successful completion with you and manually initiates deletion. This manual confirmation process may be replaced with an automated process in the future if the protocol demonstrates consistent reliability at scale, and any such change will be communicated in accordance with Article 11. Wise Pilgrim is not liable for data loss or corruption resulting from an interrupted re-encryption process where the interruption was caused by your actions, device failure, or loss of network connectivity, but will use commercially reasonable efforts to restore data from the backup copy where possible.

Article 4. User Obligations

4.1. You agree to: (a) provide accurate data; (b) use the Application lawfully and in compliance with Royal Decree 933/2021; (c) maintain valid SES.HOSPEDAJES credentials; (d) verify guest data before submission; and (e) safeguard your encryption key and recovery code.

4.2. You are solely responsible for the accuracy of guest information you enter into the Application. Wise Pilgrim acts as a technology provider and does not verify the substantive accuracy of guest data (for example, whether an identity document number is valid or a name is correctly spelled).

4.3. Wise Pilgrim is responsible for ensuring that the Application accurately encodes your data into the XML format required by SES.HOSPEDAJES without modification or loss of information. If a defect in the Application causes data to be incorrectly encoded, Wise Pilgrim will use commercially reasonable efforts to correct the defect promptly.

4.4. You are the Data Controller for all guest personal data processed through the Application. This means you bear legal responsibility under GDPR and LOPDGDD for: the lawfulness of data collection, providing guests with privacy information (Articles 13 and/or 14 GDPR as applicable), responding to data subject rights requests, reporting data breaches to the AEPD within 72 hours, and maintaining compliance with Royal Decree 933/2021 retention requirements.

Article 5. Data Protection and Wise Pilgrim's Role

5.1. Data processing is governed by Regulation (EU) 2016/679 (GDPR) and Spain's Organic Law 3/2018 (LOPDGDD).

5.2. Guest Personal Data. The accommodation provider is the Data Controller for all guest personal data. Guest data is encrypted on your device before being transmitted to and stored on Wise Pilgrim's cloud infrastructure. Because of the zero-knowledge encryption architecture, Wise Pilgrim cannot access, read, or process this data in decrypted form. Wise Pilgrim's role with respect to encrypted guest data is limited to providing secure storage infrastructure. Wise Pilgrim does not determine the purposes or means of processing guest personal data and does not qualify as a Data Processor for this data within the meaning of GDPR Article 4(8).

5.3. Operational and Property Data. Wise Pilgrim acts as Data Processor for operational metadata associated with your account, including: submission timestamps, submission status (success/failure), API responses, and technical logs. This processing is governed by the Data Processing Agreement (DPA), which forms part of these Terms.

5.4. Property Listing Data. Property information you provide — including property name, address, contact details, services offered, and pricing — is provided by you with the express understanding and consent that Wise Pilgrim will publish this information in its applications, guidebooks, websites, and related media. This data is not treated as confidential. The legal basis for this processing is your consent and contract performance (GDPR Article 6.1(a) and (b)).

5.5. All data — encrypted guest data, operational metadata, and property listing data — is hosted by Supabase Inc. on Amazon Web Services servers located in the EU (AWS region eu-west-1, Ireland). Supabase Inc. is a US-headquartered company; Wise Pilgrim has Standard Contractual Clauses (SCCs) in place with Supabase to ensure GDPR-compliant data transfers. Details of sub-processors and transfer safeguards are available in the DPA and Privacy Policy.

5.6. Wise Pilgrim maintains a Data Protection Impact Assessment (DPIA) in accordance with GDPR Article 35, evaluating risks associated with identity document processing, minors' data, zero-knowledge encrypted storage, and legal data retention. The DPIA is reviewed and updated periodically. A summary is available upon request by contacting privacy@wisepilgrim.com.

5.7. Saved beds. For data processed in Saved beds (Article 7A), Wise Pilgrim acts as an independent Data Controller, not as a Data Processor. Details are in Section 1.5 of the Privacy Policy and Article 2.5 of the DPA.

Article 6. Availability and Limitations

6.1. Wise Pilgrim will use commercially reasonable efforts to maintain Application availability. Wise Pilgrim does not guarantee uninterrupted or error-free service.

6.2. Wise Pilgrim does not operate or control the SES.HOSPEDAJES system and is not responsible for: (a) SES system outages or performance issues; (b) SES validation errors or rejection of submissions; (c) changes to SES policies, formats, or requirements; or (d) delays in Ministry of Interior processing.

6.3. Force Majeure. Neither party is liable for failure to perform due to events beyond reasonable control, including natural disasters, war, pandemic, government action, cyber attacks on critical infrastructure, or sustained power or telecommunications failure. If a force majeure event prevents Wise Pilgrim from providing the Application for more than 30 consecutive days, you may terminate your account without penalty.

6.4. Planned Maintenance. Wise Pilgrim will provide reasonable advance notice of scheduled maintenance that may affect availability, where practicable.

6.5. The Application provides tools to assist with regulatory compliance. It does not guarantee that: (a) SES.HOSPEDAJES will accept your submissions; (b) the Ministry of Interior will process registrations; or (c) use of the Application will prevent administrative penalties. Compliance with Royal Decree 933/2021 is your responsibility.

Article 7. Property Listing and Publication

7.1. Providing property listing data for publication is entirely optional. You may use all core compliance features of the Application (guest registration, data capture, SES.HOSPEDAJES submission, and encrypted data storage) without providing any listing data. If you choose to provide listing data, the terms below apply.

7.2. By providing property information (name, address, contact details, services, and pricing) through the Application, you grant Wise Pilgrim a worldwide, royalty-free license to use, display, reproduce, and distribute this information in Wise Pilgrim's applications, guidebooks, websites, and related publications for the duration of your active account and for twelve (12) months following account termination or withdrawal of consent, to allow for removal from publications in progress. Property listing information included in print editions published before your termination or withdrawal of consent may remain in those editions, but Wise Pilgrim will not include the listing in new print editions published after the removal date.

7.3. You represent and warrant that: (a) you have the authority to list the property; (b) all listing information is accurate, current, and lawful; and (c) the property complies with all applicable local licensing, zoning, and tourism registration requirements.

7.4. You may update or request removal of your property listing at any time by contacting support@wisepilgrim.com or through the Application settings. Removal will be processed within 30 days, though previously published print editions issued before the removal request may continue to display the listing. Wise Pilgrim will not include the listing in new print editions published after the removal date.

7.5. Wise Pilgrim may remove or decline to publish any listing that it reasonably believes is inaccurate, misleading, or in violation of applicable law.

Article 7A. Saved Beds

7A.1. What it is. "Saved beds" is an optional service of the Application. Pilgrims using All Caminos, Wise Pilgrim's app for pilgrims, can send you a bed request for tonight or tomorrow night, and you confirm it, decline it or propose another option from the Application. There is no advance payment, card or deposit: it runs on each side's word. The pilgrim undertakes to turn up or to cancel in time; you undertake to keep the bed you confirm. Wise Pilgrim is not a party to the accommodation arrangement: the price, its payment and the terms of the stay are solely between you and the pilgrim.

7A.2. Free, with no commission. Saved beds is free for you and for the pilgrim. Wise Pilgrim charges no commission on bed requests or stays and processes no payments. Any future change will be communicated in accordance with Article 1.5.

7A.3. Switching it on and off. Saved beds is switched on at your request, after Wise Pilgrim has linked your property to its entry in Wise Pilgrim's guides. You can stop accepting requests at any time: for tonight ("Tonight"), for tomorrow, on your rest days, or by switching Saved beds off entirely in the Application. Stopping requests does not cancel beds you have already confirmed, which remain your commitment, and you can still answer pending requests from the list.

7A.4. The settings you choose. In the Saved beds settings you decide:

a) Your check-in deadline for each night (default 20:00).

b) Your free-cancellation time: 1 to 12 hours before your check-in deadline (default 6 hours before). It is the same for you and for the pilgrim.

c) How long a pilgrim waits for your answer: 15 or 30 minutes (default 30). After that the request expires and the pilgrim looks for a bed elsewhere.

d) If you propose another option, how long the pilgrim has to accept it: 5 to 30 minutes (default 15).

e) Auto-accept, optional and per room type (shared dormitory, private room, whole house): requests from pilgrims whose trust score is at or above the minimum you choose are confirmed automatically, up to the nightly cap you set. A bed confirmed this way binds you exactly like one you confirm by hand.

f) The optional "WhatsApp introduction" (see Article 7A.9).

The check-in deadline and free-cancellation time are fixed on each bed when it is confirmed: if you later change your settings, beds already confirmed keep theirs. Example: deadline 18:00 and 3 hours → free cancellation until 15:00. The pilgrim's saved bed shows both times.

7A.5. Your commitment when you confirm. By confirming a request, you undertake to keep that bed, for that number of people and that night, until that bed's check-in deadline. A pilgrim can hold only one confirmed bed per night: once one is confirmed, their other requests for that night are cancelled automatically. Wise Pilgrim never holds against you answering slowly, letting a request expire, declining it or proposing another option. Only what happens after you confirm counts.

7A.6. If you cancel a confirmed bed. You can cancel it at any time; the pilgrim is notified straight away and their score does not change.

a) Before that bed's free-cancellation time: it counts as a cancellation on your record (Article 7A.8) and removes your "Keeps its word" badge for 90 days.

b) From that time onwards: it also counts as a turn-away (Article 7A.7). Telling the pilgrim is always better than leaving them at the door.

Example: deadline 18:00, free cancellation until 15:00. Cancelling at 14:00 is a cancellation; cancelling at 16:00 is a turn-away.

7A.7. Turn-aways.

a) What a turn-away is: you cancel a confirmed bed from your free-cancellation time onwards, or the pilgrim reports in All Caminos ("I was turned away") that they arrived with a confirmed bed and were not given it, whatever the reason. The pilgrim can report from 1 hour before the check-in deadline (or from when they tapped "I'm here", if earlier) until 11:00 the next morning.

b) "I'm here": on arrival, the pilgrim can tap it from 12:00 on the night or from 3 hours before the check-in deadline, whichever is earlier, until 3 hours after the deadline. Their own phone checks that they are within 300 m of your property, and you are notified. A turn-away report made after "I'm here", from a phone that has passed Apple's or Google's device check, is a checked report.

c) Your answer: a checked report cannot be contested; if you think something is wrong with it, write to Wise Pilgrim (see 7A.13). Within 72 hours of any other pilgrim report you can answer "They never arrived". To any report you can add your side of what happened (no phone numbers). Your side is kept on record.

d) When it counts: your cancellation from the free-cancellation time onwards always counts. A checked report counts from the moment it is made; an unchecked one counts only if 72 hours pass without you answering "They never arrived". A report you answer with "They never arrived" stops counting towards the badge and the switch-off, and Wise Pilgrim may review both sides.

e) Switch-off: Saved beds is switched off automatically for your property when, in the last 90 days, there are counted turn-aways from at least two different trusted sources. A trusted source is each pilgrim affected by a cancellation of yours made from the free-cancellation time onwards, and each phone that has passed Apple's or Google's device check and whose report counts (one phone counts once). If counted turn-aways come from two different pilgrims but not from two trusted sources, nothing is switched off automatically: Wise Pilgrim is alerted and reviews it. While Saved beds is switched off, pilgrims cannot send you bed requests, and only Wise Pilgrim can switch it back on.

Example: on 3 May you cancel at 16:00 a bed whose free cancellation ended at 15:00 (it counts). On 20 June another pilgrim, whose phone passed the device check, taps "I'm here" and then reports being turned away: that is two trusted sources in 90 days, and Saved beds is switched off at that moment.

7A.8. Your public record and the "Keeps its word" badge.

a) Record: once your property has confirmed at least 5 beds in the last 90 days, pilgrims see in All Caminos, before asking you for a bed, how many of those confirmed beds ended cancelled by you or with a turn-away report; for example "Has never cancelled a confirmed request" or "Cancels 1 in N confirmed requests". With fewer than 5 confirmed beds nothing is shown.

b) Badge: pilgrims see "Keeps its word" next to your property's name in All Caminos while, over the last 90 days, you have: at least 15 points from confirmed beds you kept, on at least 3 different nights; no confirmed bed cancelled by you (not even before the free-cancellation time); and no counted turn-away. Points: shared dormitory bed, 1 per bed; private room, 3; whole house, 6. A confirmed bed counts as kept from 11:00 the next morning if it ended as "Arrived" or "No-show" (you held it). After a cancellation of yours or a counted turn-away, the badge cannot return until 90 days after that date, and only if the conditions are met again.

Example: 5 dormitory beds confirmed and kept on each of 3 different nights make 15 points over 3 nights.

7A.9. Pilgrim data and WhatsApp.

a) Before you confirm, you see a shortened name (first name and initial of the surname, for example "María G."), the number of people (1 to 8), the room types requested, the pilgrim's message if any (up to 300 characters, no phone numbers) and their trust score (level, points, stays and no-shows). Once the bed is confirmed, you see the full name the group will check in under. Through Saved beds you never see the pilgrim's email, phone number or device data. The name and messages are deleted automatically 3 days after the night.

b) You undertake to use this data only to manage that stay. Guest registration under Royal Decree 933/2021 is done as usual, at check-in.

c) WhatsApp introduction: if you switch it on, pilgrims who have asked you for a bed see a button that opens WhatsApp with your property's WhatsApp number. If a pilgrim writes to you, you see their number, as with any message. That conversation goes from the pilgrim to you over WhatsApp without passing through Wise Pilgrim: Wise Pilgrim does not receive the pilgrim's number and does not see or keep the conversation. If you do not switch it on, Saved beds does not show your number.

7A.10. Arrivals, no-shows and the pilgrim's score.

a) Score: every pilgrim starts at 50 points; gains 5 for each stay, up to a maximum of 100; loses 5 for cancelling a confirmed bed from the free-cancellation time onwards and 25 for each no-show. Each of these counts in the order it happens, and the score never goes above 100 or below 0. A slip can be made good: every stay adds 5 (5 stays make up for a no-show). Levels: Caution (below 40), New (40 to 59) and Trusted (60 or more). Cancelling before the free-cancellation time costs the pilgrim nothing.

b) Arrived: you can mark the arrival. If you do not, the stay counts as "Arrived" automatically at 11:00 the next morning, unless you have marked "No-show" before then.

c) No-show: if the pilgrim has not arrived and has not told you, you can mark it from 30 minutes after that bed's check-in deadline (for example, deadline 20:00 → from 20:30) until 11:00 the next morning. Mark it only if it is true.

d) Corrections: until 23:59 on the day after the night you can, once, change a "No-show" to "They arrived after all" (they came later: the pilgrim gets the 25 points back and the stay is added) or to "Didn't stay, but paid" (the 25 points come back, no stay added). If you marked "Arrived" by mistake, you can change it to "No-show" from 30 minutes after the check-in deadline until 11:00 the next morning, only if you marked the arrival yourself.

e) If the pilgrim tapped "I'm here" and you mark them as "No-show", Wise Pilgrim reviews the case before any points change.

f) Wise Pilgrim may correct a pilgrim's score after reviewing a case. You do not see these corrections.

7A.11. Automatic pause of "Tonight". This is not a penalty. If, in the last 72 hours, 6 or more requests have expired and you have opened none of them, Wise Pilgrim switches "Tonight" off (accepting requests for tonight) so pilgrims are not left waiting, and tells you with a notification and a banner on your dashboard, where one tap switches it back on. "Tomorrow" and your other settings do not change, and the pause does not affect your record or your badge. The 72 hours are counted from the last time you opened a request, changed a setting or answered by hand, if that is more recent. The pause is only applied between 08:00 and 21:59, Madrid time. The check runs every hour. Example: if 6 requests expire between Monday and Tuesday and you have opened none, "Tonight" is switched off at the next check and you are notified; had you opened one on Tuesday morning, only those expiring after that would count.

7A.12. Notifications. While you use Saved beds, the Application sends you push notifications for new requests, automatic confirmations, cancellations, answers to your proposals, "I'm here" and turn-away reports; on iPhone, also a Live Activity on the lock screen with your open requests. You may also receive a reminder at 10:00 (Madrid time) and, on Mondays, a weekly summary that you can switch off in the Saved beds settings. Notifications do not include the pilgrim's name. You can switch notifications off in your phone's settings, but you may then not learn of requests in time.

7A.13. Review by Wise Pilgrim. Wise Pilgrim reviews doubtful cases: a "No-show" after "I'm here", turn-away reports you answer with "They never arrived", and complaints from pilgrims or owners. It uses the service records for this (times, statuses, checks and each side's account). If you disagree with something that counts on your record, write to support@wisepilgrim.com.

7A.14. Scope. Wise Pilgrim puts pilgrims and properties in touch but does not guarantee that a pilgrim will turn up or any minimum number of requests. Article 9 also applies to Saved beds.

Article 8. Intellectual Property

8.1. The Application, including all software, designs, and functionality, is the property of Wise Pilgrim SL. You receive a limited, non-exclusive, non-transferable, revocable license to use the Application for its intended purpose in compliance with these Terms.

8.2. You agree not to: (a) copy, modify, or create derivative works of the Application; (b) reverse-engineer, decompile, or attempt to discover source code; (c) circumvent, bypass, or disable any security or encryption mechanism; or (d) use the Application for any purpose other than accommodation guest registration and property listing.

Article 9. Limitation of Liability

9.1. Disclaimer of Certain Liabilities. Wise Pilgrim is not liable for: (a) errors, inaccuracies, or omissions in data you enter; (b) SES.HOSPEDAJES system outages, rejections, or processing delays; (c) administrative fines or penalties imposed due to your errors, omissions, or non-compliance; (d) data loss resulting from loss of your encryption key and recovery code (see Article 3.6); (e) failure or interruption of third-party services (Supabase, AWS, SES.HOSPEDAJES).

9.2. Maximum Liability. Except for liabilities that cannot be limited under applicable law (see Article 9.3), Wise Pilgrim's total aggregate liability arising from or related to these Terms and your use of the Application shall not exceed the greater of (a) the total fees paid by you to Wise Pilgrim in the twelve (12) months preceding the claim, or (b) one thousand euros (€1,000).

9.3. Non-Waivable Liability. The liability cap in Article 9.2 does not apply to:

1. Wise Pilgrim's liability under GDPR Articles 82-83 for violations of its data protection obligations as described in these Terms, the Privacy Policy, and the DPA.
2. Liability arising from Wise Pilgrim's gross negligence (negligencia grave) or willful misconduct (dolo).
3. Liability for death or personal injury caused by Wise Pilgrim's negligence, to the extent such liability cannot be excluded under Spanish law.
4. Liability arising from Wise Pilgrim's fraud or fraudulent misrepresentation.

9.4. Exclusion of Consequential Damages. To the maximum extent permitted by law, Wise Pilgrim shall not be liable for indirect, incidental, special, consequential, or punitive damages, including loss of profits, loss of data, loss of business, or regulatory fines imposed on you, regardless of whether Wise Pilgrim was advised of the possibility of such damages. This exclusion does not apply to damages arising from Wise Pilgrim's violation of GDPR or Spanish data protection law.

9.5. Indemnification by You. You agree to defend, indemnify, and hold harmless Wise Pilgrim from any third-party claim, demand, or judgment (including reasonable legal fees) arising from: (a) your breach of these Terms or applicable law; (b) your use of the Application in a manner not authorized by these Terms; (c) inaccurate or unlawful data you submit; (d) your failure to comply with GDPR, LOPDGDD, or Royal Decree 933/2021 in your capacity as Data Controller; or (e) property listing information you provide that infringes third-party rights. This indemnification does not apply to the extent that Wise Pilgrim's own actions caused or contributed to the claim.

Article 10. Termination

10.1. You may terminate your account and stop using the Application at any time through the Application settings or by contacting support@wisepilgrim.com.

10.2. Wise Pilgrim may suspend or terminate your account immediately if: (a) you breach any material provision of these Terms; (b) you are subject to government prohibition from operating an accommodation; (c) required by law or court order; or (d) your account poses a security risk to the Application or other users.

10.3. Wise Pilgrim may terminate your account with 30 days' written notice if: (a) you breach a non-material provision and fail to cure within 15 days of notice; or (b) your account has been inactive for more than 12 consecutive months.

10.4. Effect of Termination on Data. (a) Encrypted guest data stored on Wise Pilgrim's servers will be retained for the remainder of the 3-year retention period required by Royal Decree 933/2021, then automatically deleted. You may request earlier deletion, but you acknowledge this may affect your compliance obligations. (b) Operational metadata will be retained for 3 years from termination, then automatically deleted (Section 6.3 of the Privacy Policy). (c) Property listing data will be removed from digital publications within 30 days; previously published print materials may continue to display the listing. (d) Saved beds is switched off for your property; Saved beds data is retained in accordance with Section 6.6 of the Privacy Policy.

10.5. Survival. Articles 5 (Data Protection), 7 (Publication License), 8 (Intellectual Property), 9 (Liability), 12 (Governing Law), 13 (Contact), and 14 (General Provisions) survive termination.

Article 11. Modifications

11.1. Wise Pilgrim may modify these Terms at any time.

11.2. Material changes — including modifications to liability limitations, data processing practices, or core functionality — will be communicated with at least 30 days' notice via email and in-app notification.

11.3. If you do not accept a material change, you may terminate your account within the 30-day notice period. Continued use of the Application after the effective date constitutes acceptance of the modified Terms.

Article 12. Governing Law and Dispute Resolution

12.1. These Terms are governed by Spanish law. Disputes shall be resolved in the courts of Santiago de Compostela, without prejudice to any mandatory consumer jurisdiction rules that may apply.

12.2. For data protection disputes, either party may file a complaint with Spain's Data Protection Authority (Agencia Española de Protección de Datos, AEPD, www.aepd.es). Regulatory proceedings are independent of any private dispute resolution.

12.3. Before initiating court proceedings (other than applications for injunctive relief or complaints to the AEPD), the parties shall attempt to resolve disputes through good-faith negotiation for a period of thirty (30) days from the date of written notice of the dispute.

Article 13. Contact

Wise Pilgrim SL
Galicia, Spain
General inquiries: info@wisepilgrim.com
Privacy and data protection: privacy@wisepilgrim.com
Security issues: security@wisepilgrim.com

Article 14. General Provisions

14.1. Severability. If any provision of these Terms is found by a court of competent jurisdiction to be invalid, illegal, or unenforceable, that provision shall be modified to the minimum extent necessary to make it enforceable, or if modification is not possible, severed. All remaining provisions shall continue in full force and effect.

14.2. Entire Agreement. These Terms, together with the Privacy Policy and Data Processing Agreement, constitute the entire agreement between you and Wise Pilgrim regarding the Application and supersede all prior agreements, representations, and understandings.

14.3. No Waiver. Wise Pilgrim's failure to enforce any provision of these Terms shall not constitute a waiver of that provision or any other provision.