Transparency
Use of artificial intelligence
We want you to know, without fine print, where AI is involved and where a human always decides. This page anticipates transparency duties and will be updated when real AI use changes.
Updated
1. Executive summary
- We do not use an AI chatbot as the main mortgage customer channel on this website.
- We do not take automated decisions that approve or refuse a loan: the lender decides; we intermediate with human judgement.
- We may use internal AI support tools (drafting, translation, organisation, image generation or staff assistance) with human review before publishing or communicating terms to a client.
- If we later offer a direct interaction with an AI system (e.g. a conversational assistant), we will label it clearly, in line with Article 50 of Regulation (EU) 2024/1689.
2. Where AI may be used
- Producing and improving web content, guides or internal materials (drafts, summaries, language review), always with human oversight before public information goes live.
- Supporting operational tasks (organising information, templates, ES/EN translation), without replacing case analysis by ICI-certified staff.
- Generating or editing non-photographic visuals (illustrations, variants) when workflows use them; we do not present deepfakes of real people as authentic customer-service recordings.
- Third-party tools (CRM, productivity, cloud) that the vendor states include AI features: also governed by their terms and, if personal data is processed, by the GDPR and the processor contract.
3. Where we do not use AI (current commitments)
- We do not replace human case review or file follow-up with an autonomous AI agent.
- We do not automatically score your solvency with an opaque AI system that decides an internal pass/fail.
- We do not use emotion recognition or biometric categorisation on visitors or clients.
- We do not generate deepfakes of clients, staff or third parties to mislead about who is speaking.
4. Personal data and GDPR
If an AI system processes personal data, the GDPR still applies: legal basis, minimisation, security, processors and rights. The AEPD can act against unlawful processing even while the AI Act rolls out in phases.
Do not send sensitive data or full case files to public third-party AI chats. For your case, use official channels (madrid@skyfinancialservices.es, site forms, offices).
5. EU AI Act — transparency
Regulation (EU) 2024/1689 includes Article 50 transparency duties (inform when interacting with AI; mark certain synthetic content). Per AESIA / Commission guidance, those transparency obligations apply from 2 August 2026 (with a limited grace period to 2 December 2026 only for labelling/detection of generated content for systems already on the market before that date).
Even though we do not currently deploy a public-facing AI assistant on this site, we publish this page to anticipate AEPD-recommended transparency and to document internal support uses.
6. Site content
Legal texts, commercial claims and figures (fees, BE register, NAP) are validated against internal sources and, where applicable, Sky Law / published rules. AI is not a regulatory source of truth: if there is a conflict, the contract, the bank’s FEIN and the BOE prevail.
7. Contact
Questions about this policy: gdpr@skyfinancialservices.es. Intermediation-service complaints: complaints channel. We will update this page when we add new user-facing AI systems.