Most policy generators do template substitution — they take a fixed text file with placeholders and swap in your company name, your email, your country. miniterms does not.
Mode B render in one paragraph
Mode B is the internal name for the engine. Instead of starting from a finished policy and filling holes, it starts from your business profile and the jurisdiction's regulator citation set — the list of articles, BOE entries, EDPB guidelines, and AEPD circulars that apply to a controller in your situation. It walks that set, clause by clause, and emits the text that each citation requires. The output lists the regulatory sources behind its clauses in a Sources section at the end of the document.
Why this matters legally
A template-filled policy is, at best, evidence that you bought a template.
Accountability principle — [GDPR art. 5(2)] requires you to be able to demonstrate compliance, not merely claim it. Generated documents end with a Sources section that lists the regulatory sources behind its clauses, which you can keep as part of that record.
What you see in the output
The generated document is Markdown, and the preview shows it as Markdown. Clauses refer to the articles they rest on in the text — for example "(Art. 6(1)(a) GDPR)" — and the document ends with a Sources section, one line per clause and source:
- **§02-lawful-basis** — GDPR Art. 6(1)(a)–(f) — lawfulness of processing (GDPR, retrieved 2026-04-24). https://eur-lex.europa.eu/eli/reg/2016/679/oj
Each entry names the source, the date it was retrieved and a link to the official text — for example eur-lex.europa.eu for the GDPR, boe.es for Spanish law and edpb.europa.eu for EDPB guidelines.
What Mode B does NOT do
- It does not know your retention periods. Your business profile holds your identity and contact details (entity name, legal form, tax ID, registered address, website URL, contact email and privacy contact email), your jurisdictions and your languages — no retention periods, processing purposes or data categories. Those clauses start from conservative defaults: for example, account data is kept until the account is deleted, then 30 days. Check them against what your business really does and change them in your copy before you publish.
- It does not write legal opinions. It surfaces obligations and applies your declared facts to them.
- It does not replace counsel. The generated document is a defensible starting point, not a substitute for review by a Spanish data protection lawyer if your processing is high-risk.
What changes when regulators publish updates
When the AEPD issues a new circular, or when the EDPB updates guideline 03/2020 to a new version, we review it and, when it affects the documents miniterms generates, add it to Law updates in your dashboard, with the documents it affects. Your already-generated policy keeps working; the dashboard Overview shows how many updates need your review. See Regenerating when the law changes.
Your responsibility — This document is built to current GDPR and Spanish (AEPD) requirements from public regulatory sources, and kept up to date as the law changes. It is only as accurate as the information you provided: you are responsible for ensuring your answers are truthful and that the generated document reflects how your business actually collects and uses data. It is not individualised legal advice. Having a lawyer review it is optional, not required.