Legal
Privacy Policy
Draft — pending legal review
Summary
- We process the account details and financial documents you upload in order to run the bookkeeping pipeline.
- AI assistance is used to categorise transactions. It does not make final accounting decisions — a human review step remains available and, where configured, required.
- Uploaded source files are deleted after an organisation-configurable retention period.
- We do not sell personal data and we do not use customer financial data to train general AI models.
- Sections marked “Legal review required” are draft assertions that need qualified sign-off.
1. Who we are
Accounting Workbench is operated by [COMPANY_LEGAL_NAME], registered at [REGISTERED_ADDRESS] (company number [COMPANY_NUMBER]). We are the data controller for the personal data described in this policy, except where we process data on behalf of an accounting practice or organisation that has engaged us (in which case that organisation is the controller and we are the processor).
Questions about this policy or our data practices can be sent to [CONTACT_EMAIL].
2. Scope of this policy
This policy covers the Accounting Workbench web application, the public marketing site, and the document-processing and email-ingestion features that support them.
Where an organisation uses Accounting Workbench to process data belonging to its own clients, the organisation is responsible for its own privacy notices to those clients.
3. Data we process
- Account data: name, email address, authentication identifiers, organisation membership and role.
- Uploaded content: bank statements, invoices, spreadsheets and other financial documents, together with the text extracted from them.
- Processing data: generated journal entries, account-code suggestions, confidence scores, review decisions and audit records.
- Billing data: credit-purchase records and payment references handled by our payment provider. We do not store full card numbers.
- Technical data: IP address, request metadata and security/rate-limit logs needed to operate and protect the service.
4. How we use data and our lawful bases
We use the data above to provide the service (extraction, categorisation, review routing, export and billing), to secure and support it, and to meet our legal and accounting obligations.
The lawful bases relied on for each processing activity — including contract, legitimate interests, legal obligation and consent (for example, analytics cookies where used) — must be confirmed for the operating jurisdiction during legal review.
5. AI processing and automated assistance
When you submit a document, we extract its text and send the relevant transaction data, and the Chart of Accounts for the organisation, to a third-party large language model provider to suggest categorisations. Only the data needed for that suggestion is sent; we do not send more of your document than is required.
AI output is a suggestion. It is not accounting, tax, audit or legal advice, and it does not post to any accounting platform automatically. Where an entry does not meet the organisation’s configured confidence threshold, it is routed to the review queue.
Depending on the organisation’s review policy, entries may require approval by a person other than the submitter (“four-eyes” review) or may require manual review before use. Final responsibility for reviewing output before it is relied upon or filed rests with the organisation and its professional advisers.
We do not use customer financial data to train general or shared AI models.
6. Third-party subprocessors
We use the following categories of third party to operate the service. The current list, the processing purpose and the hosting region for each must be verified against [SUBPROCESSOR_REGIONS] and recorded in the data-processing agreements before launch:
- Cloud hosting and application delivery (Vercel).
- Authentication, database and file storage (Supabase; currently self-hosted, with a managed-cloud region planned).
- AI categorisation and review assistance (Anthropic).
- Transactional and inbound email (Resend).
- Payment processing (SumUp).
- Integration connectivity for accounting platforms (Nango; self-hosted).
- Optional distributed rate limiting (Upstash Redis), when configured.
7. International data transfers
Some subprocessors may process data outside the user’s country. Where personal data is transferred internationally, we rely on appropriate safeguards. The specific transfer mechanism for each subprocessor must be documented as [TRANSFER_MECHANISM] during legal review.
8. Retention and deletion
Uploaded source files (PDFs, CSVs and spreadsheets) are deleted automatically after the retention period each organisation selects. Available periods are 7 days, 30 days, 90 days, 1 year; the default is 30 days.
A scheduled cleanup job removes expired files each day (02:00 UTC). Setting retention to “delete immediately” removes newly expired files at the next cleanup run.
Generated journal entries, review decisions, audit records and billing records are retained for as long as the organisation’s account is active and for any additional period required for legal, tax or accounting purposes. The exact schedule for non-file records must be confirmed during legal review.
Organisations can request deletion of their account data, subject to records we are required to keep by law.
9. Security
Data is logically isolated between organisations using database row-level security. Access to production systems is restricted, secrets are managed as environment configuration and are not exposed to the browser, and security-relevant events are logged.
No online service can guarantee absolute security. We do not claim any security certification or regulatory approval that has not been independently assessed and evidenced.
10. Your rights
Depending on where you live, you may have rights to access, correct, delete, restrict or object to the processing of your personal data, and to request data portability. You may also have the right to withdraw consent where processing is based on consent.
To exercise a right, contact [CONTACT_EMAIL]. You may also complain to your local data-protection supervisory authority, for example [SUPERVISORY_AUTHORITY].
12. Changes to this policy
We will update this policy as the service and applicable law change, and will revise the version and “last updated” date above. Material changes should be communicated to affected organisations.
13. Contact and data-rights requests
For privacy questions or data-rights requests, contact [CONTACT_EMAIL]. Where a data protection officer or EU/UK representative is appointed, their details must be added as [DPO_CONTACT].
Postal requests can be sent to [REGISTERED_ADDRESS].
Legal wording is maintained in lib/legal/ as structured data so it can be reviewed and replaced without code changes. See docs/operations-runbook.md for the sign-off and publication process.