Legal Notice

Last updated: 20 March 2026

Identifying data of the service provider
Object and scope of application
Description of services
Access and use conditions
Contracting and payment process
Subscription model (afini.ai)
Right of withdrawal
Intellectual and industrial property
Non-clinical nature of the service
Artificial intelligence and automated processing
Personal data protection
Cookie policy
Service availability and continuity
Links to third-party websites
Electronic communications
Partial invalidity
Alternative dispute resolution (ADR)
Applicable law and jurisdiction
Contact

1. Identifying data of the service provider

In compliance with article 10 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE), the following identifying data of the owner of this website are provided:

Data

Details

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Legal name

Bilbao AI S.L.

Trade name

Afini / Afini.ai

Tax ID (CIF)

B-13759758

Registered address

Calle Diputación 8, floor 4, Department 5, 48008 Bilbao (Bizkaia), Spain

Email

info@afini.ai

Websites

https://test.afini.ai · https://afini.ai

Registration details

Registered in the Commercial Registry of Bizkaia

Main activity

Personality assessment and cognitive profile services based on validated scientific models (Big Five / OCEAN and other psychometric instruments) through information technologies and artificial intelligence

2. Object and scope of application

This Legal Notice governs access to and use of the websites test.afini.ai and afini.ai (hereinafter, collectively, the "Platforms" or "Websites"), owned by Bilbao AI S.L. (hereinafter, "Afini", "us" or the "Provider").

The Platforms comprise two distinct but complementary services:

test.afini.ai — Transactional service for Big Five personality assessment (IPIP-NEO) in modalities of 60, 120 and 300 items.
afini.ai — Multilayered cognitive profile platform with subscription, integrating multiple psychometric assessment instruments and offering personalized interaction through artificial intelligence.

Access to any of the Websites and use of any of their services implies full and unconditional acceptance of all provisions included in this Legal Notice, as well as in the Privacy Policy, in the version published at the time of access.

Territorial scope: Afini offers its services to users worldwide. This Legal Notice is governed by Spanish law as the provider's main regulatory framework, without prejudice to the rights that local laws of each user recognize them as a consumer. In case of conflict, the most protective rule for the consumer user shall prevail.

If you do not agree with any of the conditions set forth here, we ask you not to use the Platforms.

3. Description of services

3.1. Big Five personality test (test.afini.ai)

Afini provides a personality assessment service based on the Five Factor Model of personality (Big Five / OCEAN), using as a measurement instrument the IPIP-NEO inventory (International Personality Item Pool — NEO), which is in the public domain.

The service is offered in three modalities:

Modality

Items

Report content

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Essential

60 items

5 major personality traits

Advanced

120 items

5 traits + 30 facets

Complete

300 items

5 traits + 30 facets (maximum precision)

After completing the questionnaire, the user receives a personalized results report — which may include a narrative analysis generated through artificial intelligence — accessible via a private link.

3.2. Multilayered cognitive profile (afini.ai)

The afini.ai platform offers a comprehensive cognitive profile service combining multiple psychometric assessment instruments with personalized interaction through AI. This service includes:

Additional psychometric assessments to Big Five, including — as the platform evolves — instruments for assessing attachment styles, humor styles, values orientation, time perspective and cognitive style.
Compiled cognitive profile: A structured profile integrating results from all assessments completed by the user.
Personalized AI interaction: A conversation service with a language model (LLM) that uses the user's cognitive profile to deliver interaction adapted to their personality traits.
Portable profile (optional, under additional purchase): A structured and documented JSON file with the user's complete cognitive profile, designed to be injected as context into other AI systems.

This service is provided through a monthly subscription model described in section 6.

4. Access and use conditions

4.1. Access requirements

To use the services, the user must:

Be at least 16 years old (or have authorization from a parent or legal guardian).
Provide truthful information during the purchase process, registration and completion of assessments.
Use the service on a personal and individual basis — each purchase or subscription corresponds to a single person.

4.2. User obligations

The user agrees to:

Make lawful use in good faith of the Platforms and their services.
Not reproduce, distribute, transform or publicly communicate the contents of the Websites without express authorization.
Not use the services for fraudulent, unlawful or public policy-violating purposes.
Not attempt to access restricted areas of the Websites, Afini's computer systems or other users' data.
Not interfere with normal operation of the Platforms.
Not resell, redistribute or commercialize access to the service, generated reports or the cognitive profile without express authorization from Afini.
Not use AI interaction on afini.ai to generate unlawful, harmful, defamatory content or content violating third-party rights.
Not attempt to extract, replicate or reverse engineer the cognitive profile compilation algorithms or system prompts used by Afini.

4.3. Use of results

Assessment results and cognitive profile are for the user's personal and private use. You are free to share them with whoever you wish, but Afini is not responsible for how third parties may use that information.

5. Contracting and payment process

5.1. Purchase process (test.afini.ai)

The service contracting process is conducted entirely through the Platform, following the steps indicated on screen. The contracting language is Spanish (also available in English, French, German, Italian and Portuguese). Upon completing the purchase, the user will receive electronic confirmation.

In accordance with article 23 of the LSSI-CE, the contracting process follows these steps:

The user selects the desired test modality (Essential, Advanced or Complete).
The user provides their name or pseudonym and email address.
The user is redirected to the secure Stripe payment gateway.
Once payment is completed, the user accesses the questionnaire directly.
Upon finishing the test, the user receives their results report.

Alternatively, the user may access the service through an invitation code (voucher) provided by an authorized third party, in which case access may be free or discounted.

5.2. Pricing

Prices are displayed on the Platforms before purchase, in euros (EUR) with taxes included when applicable. Afini reserves the right to modify prices at any time, with current prices at the time of purchase or contracting applying.

5.3. Payment processing

Payments are processed entirely through Stripe, Inc., a payment platform certified to PCI-DSS Level 1 standard. Afini does not store, process or have access at any time to the user's credit card, debit card or other payment data.

5.4. Invoicing

Transactions on test.afini.ai are documented through a simplified invoice in accordance with article 7 of Royal Decree 1619/2012, without requiring identifying personal data from the buyer (neither email nor tax ID). If the user needs a complete invoice, they can request one by writing to info@afini.ai.

Subscriptions to afini.ai are billed monthly through Stripe. Users can manage their billing from their account panel.

6. Subscription model (afini.ai)

6.1. Subscription plans

The afini.ai platform operates under a monthly subscription model with different service levels. Current plans, their characteristics and prices are published on the platform itself. Each plan may vary in: the AI model used for interaction, monthly available usage volume, profile recalibration frequency and portable profile availability.

6.2. Recurring billing

The subscription renews automatically each calendar month. Charges are made through Stripe to the payment method registered by the user. The user will be notified of charges in advance and may cancel the subscription at any time from their user panel.

6.3. Subscription cancellation

The user may cancel their subscription at any time. Cancellation takes effect at the end of the current billing period. No prorated refunds will be issued for partial periods, unless applicable law requires it.

After cancellation, the user retains read access to their assessments and results for a reasonable period (minimum 30 days) to allow them to download their information. After that period, data will be retained in accordance with the Privacy Policy.

6.4. Portable profile purchase

The portable profile (JSON file) can be purchased as an independent purchase. It is a static export of the user's cognitive profile at the time of download. The portable profile does not update automatically; to obtain an updated version after new assessments or recalibrations, the user must purchase a new export or have a plan that includes it.

7. Right of withdrawal

In accordance with article 103.a) of Royal Decree-Law 1/2007 (Consolidated Text of the General Law for Consumer Protection — TRLGDCU) and article 16.a) of Directive 2011/83/EU, the right of withdrawal does not apply to digital content supply contracts not provided on material media when execution has begun with the consumer's prior express consent and knowledge that they lose their right of withdrawal.

7.1. Individual tests (test.afini.ai)

Upon starting the personality test — understood as "starting" by answering at least one questionnaire item — the user expressly consents to the service commencement and acknowledges that once the test is started, they lose their right of withdrawal with respect to that specific service.

However:

If the user has made payment but has not yet started the test (has not answered any item), they may request a full refund by writing to info@afini.ai within 14 calendar days of purchase.
In case of technical error preventing test completion or result retrieval, Afini will offer the user the option to retake the test at no cost or receive a full refund.
For users outside the EU/EEA: The above refund policies apply equally, regardless of local regulations, as a courtesy and in compliance with our commitment to user satisfaction.

7.2. Subscriptions (afini.ai)

For subscriptions, the user has 14 calendar days from initial contracting to exercise their right of withdrawal, provided they have not completed any assessment or used the AI interaction service during that period. In case of withdrawal, the first installment will be reimbursed in full.

8. Intellectual and industrial property

8.1. Public domain measurement instruments

The IPIP-NEO inventory used in test.afini.ai is in the public domain, developed by the International Personality Item Pool (https://ipip.ori.org) under the leadership of Lewis R. Goldberg and collaborators. IPIP questionnaire items are not Afini's property and may be used freely by any person or entity in accordance with the IPIP's public domain conditions.

Other psychometric instruments integrated into afini.ai (ECR-R, HSQ and others) are used in accordance with licenses granted by their respective authors or, where applicable, are instruments designed by Afini based on scientific theories in the public domain.

8.2. Content owned by Afini

The Platforms' software (source code, architecture, APIs).
Website design (interface, graphic elements, visual identity, logos, brands).
Interpretive texts of results (descriptions of traits, facets and recommendations).
Specific calculation algorithms developed by Afini for report generation and cognitive profile creation.
The cognitive profile compiler and portable profile format (JSON structure, schema, documentation).
System prompts, profile injection instructions and all prompt engineering developed by Afini for AI interaction.
The format and structure of personality reports.
Editorial contents of the Platforms (texts, articles, guides, technical manuals).

8.3. Scientific models

The underlying scientific models (Big Five / OCEAN / Five Factor Model, attachment theory, etc.) are public domain models resulting from decades of research. Afini claims no ownership over the theoretical models themselves.

8.4. Prohibitions

The reproduction, distribution, public communication, transformation or any other form of total or partial exploitation of content owned by Afini without prior, express and written authorization is expressly prohibited. Breach of this prohibition may result in legal action as provided by applicable intellectual property and industrial property law (Royal Decree-Law 1/1996; Law 17/2001 on Trademarks).

8.5. User report and profile

The personality report and cognitive profile generated for the user are for their personal use. You may freely share them, but cannot commercialize, resell or present the report or profile as your own service. The portable profile, once purchased by the user, is their property for personal use, but the injection instructions and accompanying documentation remain under Afini's intellectual property.

9. Non-clinical nature of the service

The personality assessments and cognitive profile offered by Afini are self-knowledge instruments based on widely validated scientific models. The services:

DO NOT constitute a psychological diagnosis or clinical evaluation.
DO NOT substitute consultation with a mental health professional (psychologist, psychiatrist or any other qualified healthcare professional).
ARE NOT medical instruments or regulated healthcare products.
SHOULD NOT be used as a basis for medical, therapeutic or clinical decisions.
DO NOT detect nor claim to detect pathologies, mental disorders or psychiatric conditions of any kind.
SHOULD NOT be used by third parties to make employment, insurance, credit or any other decisions affecting the user.

The AI interaction available on afini.ai IS NOT a therapy service, psychological counseling or counselling. It is a conversational tool that uses the user's profile to offer a personalized self-exploration experience.

If you experience mental health problems, we recommend consulting a qualified healthcare professional. Results are offered exclusively for informational purposes and personal self-knowledge. Any interpretation or use of results beyond this purpose is solely the user's responsibility.

10. Artificial intelligence and automated processing

10.1. Use of artificial intelligence

Afini uses large language models (LLM) provided by Anthropic PBC for two functions:

Narrative report generation (test.afini.ai): Based on the scores obtained in the test, an AI model generates a personality report in natural language. This report is based exclusively on the user's scores and the Big Five scientific model.
Personalized interaction (afini.ai): The user's cognitive profile is injected as context into the AI model to provide adapted conversation. Conversation content is not used to train AI models and is not shared with third parties.

10.2. Transparency regarding the injected profile

On afini.ai, the user has the right to know at all times which dimensions make up their cognitive profile and how they are used to personalize AI interaction. The profile is injected as system context (system prompt) in each conversation. Users can view their profile composition from their user panel.

10.3. Compliance with Regulation (EU) 2024/1689 (AI Act)

Afini designs and operates its services in compliance with the European Artificial Intelligence Regulation (AI Act). Afini's services do not constitute a high-risk AI system (Annex III) as they are not used for: personnel selection, credit evaluation, access to essential services, law enforcement or any of the categories listed in article 6 of the Regulation. The cognitive profile is used exclusively for personal self-knowledge and personalization of the user's own experience, under their control and consent.

However, Afini voluntarily adopts transparency practices typical of higher-risk systems: it informs the user that they are interacting with an AI system, documents the models used, and allows the user to access their profile composition.

11. Personal data protection

Afini treats your personal data in accordance with Regulation (EU) 2016/679 (GDPR), Organic Law 3/2018 (LOPDGDD) and applicable data protection regulations in each jurisdiction.

Complete information about personal data treatment — including categories of data collected, treatment purposes, legal bases, recipients, international transfers, retention periods, your rights and global jurisdictional coverage — is detailed in our Privacy Policy. We recommend reading it in full before using the service.

12. Cookie policy

The Platforms use a minimal amount of cookies, limited to what is strictly necessary for service operation and secure payment processing through Stripe. We do not use analytics, advertising, social media or tracking cookies of any kind.

Additionally, we use browser local storage (localStorage) to store session tokens that allow the user to access their in-progress test, their results and their subscription account. These tokens are technical identifiers necessary for service operation and do not contain personal data.

For more information, consult our Cookie Policy and section 15 of our Privacy Policy.

13. Service availability and continuity

Afini will make best efforts to ensure availability and accessibility of the Platforms 24 hours a day, 7 days a week. Access may be interrupted for maintenance reasons, updates, technical incidents or force majeure causes.

Afini reserves the right to modify, suspend or interrupt, temporarily or permanently, any aspect of the service, with or without prior notice. In case of permanent service closure, Afini guarantees the user a reasonable period of access to their results and the ability to download their report and, where applicable, their cognitive profile.

For the subscription service (afini.ai), Afini will notify users at least 30 days in advance of any substantial service modifications affecting the benefits included in the contracted plan. The user may cancel the subscription without penalty if they do not accept the modifications.

14. Links to third-party websites

The Platforms may contain links to third-party websites (for example, Stripe for payment processing, IPIP for information on the item inventory, or Anthropic as provider of AI technology). These links are provided solely as reference and convenience for the user. Afini:

Has no control over the contents or privacy practices of such sites.
Assumes no responsibility for the contents, products, services or privacy policies of third-party websites.
Does not imply, through inclusion of a link, approval or recommendation of the linked site or its contents.

We recommend you consult the legal notices and privacy policies of any website you visit.

15. Electronic communications

Afini does not send unsolicited commercial communications electronically. In accordance with article 21 of the LSSI-CE, Afini will only send electronic communications to the user in the following cases:

Transactional emails directly related to the contracted service (purchase confirmation, results delivery, subscription confirmation, renewal notices).
Operational emails related to the user's account (access magic link, plan changes, usage limit notifications).
Responses to inquiries initiated by the user themselves.

Afini does not use user emails for newsletters, bulletins, commercial offers or promotional communications of any kind, except with prior, express and specific user consent.

16. Partial invalidity

If any clause of this Legal Notice is declared null, invalid or inapplicable by final resolution of the competent authority, the remaining clauses will remain in full force and effect, and the affected clause will be interpreted in the manner closest to the original intent that is valid under applicable law.

17. Alternative dispute resolution (ADR)

In accordance with Regulation (EU) 524/2013 of the European Parliament and of the Council, of 21 May 2013, we inform users residing in the European Union of the existence of the European Online Dispute Resolution Platform (ADR platform), which you can access at: https://ec.europa.eu/consumers/odr/

This platform facilitates extrajudicial resolution of disputes arising from contracts of sale or services concluded online between consumers and traders. Afini's contact email for these purposes is: info@afini.ai.

For users outside the EU: If you reside outside the European Union, you may use any alternative dispute resolution mechanism available in your jurisdiction. Afini commits to cooperating in good faith with any reasonable mediation or arbitration mechanism proposed by the user.

18. Applicable law and jurisdiction

This Legal Notice is governed by Spanish law, in particular by:

Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).
Royal Decree-Law 1/2007, of 16 November, approving the Consolidated Text of the General Law for Consumer Protection (TRLGDCU).
Royal Decree-Law 1/1996, of 12 April, approving the Consolidated Text of Intellectual Property Law (TRLPI).
Law 17/2001, of 7 December, on Trademarks.
Regulation (EU) 2024/1689 of the European Parliament and of the Council (Artificial Intelligence Regulation / AI Act).
Spanish Civil Code and Commercial Code.
Regulation (EU) 2016/679 (GDPR), Organic Law 3/2018 (LOPDGDD) and other data protection regulations.

For any dispute arising from this Legal Notice, the Courts and Tribunals of Bilbao shall be competent, with express waiver of any other jurisdiction that might correspond to the parties.

Safeguard for consumers and users: The foregoing is understood without prejudice to the inalienable rights recognized by current legislation to consumers and users in all jurisdictions, in particular the right to submit to the courts of their domicile in accordance with article 52.3 of the Civil Procedure Act (Spain), article 18.1 of Regulation (EU) 1215/2012 (Brussels I bis) for consumers in the EU/EEA, the Consumer Rights Act 2015 for UK consumers, the Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010) for Australian consumers, the state and federal consumer protection laws of the United States and Canada, or applicable consumer protection legislation in any other jurisdiction of the user's residence.

19. Contact

For any questions, suggestions or complaints related to this Legal Notice or the operation of the Platforms:

Email: info@afini.ai
Postal address: Bilbao AI S.L. — Calle Diputación 8, floor 4, Department 5, 48008 Bilbao (Bizkaia), Spain

*Last updated: 20 March 2026*