Privacy Notice

1. Who we are

Smart Bookkeeping is operated by Zigetti Ltd, a company incorporated in England and Wales.

Zigetti Ltd is the controller responsible for personal data processed through Smart Bookkeeping unless another organisation is identified as the controller for a particular activity.

Registered office:

1st Floor, 314 Regents Park Road London N3 2LT

This Privacy Notice explains how we collect, use, share, retain and delete personal data when you use Smart Bookkeeping.

2. Our approach

Financial documents may contain sensitive personal and business information. We design Smart Bookkeeping around data minimisation.

Our default approach is to:

• process only what is needed
• restrict access
• delete working content aggressively; and
• retain only the information required to operate, secure and evidence the Service.

3. Personal data we process

Depending on how you use the Service, we may process:

Account and contract data

• name and email address
• account, organisation and company identifiers
• whether you declared business/professional or mainly personal use
• represented business name and authority confirmation
• Terms and Privacy Notice versions, timestamps and acceptance evidence
• request IP address, user agent and related audit metadata
• subscription, purchase, cancellation and confirmation records; and
• support communications.

Documents and accounting data

• invoices, receipts, statements and related attachments
• email bodies, subjects, sender and recipient information
• contact and supplier names
• transaction descriptions, dates and amounts
• VAT and tax-related fields
• account codes, tracking categories and saved processing rules; and
• data retrieved from or written to connected accounting systems.

Service-generated data

• extracted text and fields
• document classifications
• draft bookkeeping outputs
• validation and reconciliation results
• processing status, timestamps and error codes
• model, token, cost and credit usage
• Xero tenant and document identifiers; and
• security and operational logs.

Payment data

Stripe processes payment-card and payment-method details. We receive identifiers, status, amounts, currency, invoices, refunds and other transaction information needed to administer purchases. We do not normally receive or store full card details.

4. How and why we use personal data

We process personal data for the following purposes and lawful bases:

To provide and administer the Service

We use account, document, accounting, integration and payment data to create accounts, connect authorised systems, interpret documents, prepare drafts, allocate credits, process payments, provide support and deliver contract confirmations.

The lawful basis is performance of a contract or taking steps at your request before entering into a contract.

To operate, secure and improve the Service

We use limited account, usage, error, security and diagnostic data to prevent misuse, diagnose failures, maintain reliability, measure costs and improve processing quality.

The lawful basis is our legitimate interests in operating, securing and improving Smart Bookkeeping. We balance those interests against the rights of affected individuals.

To meet legal and accounting obligations

We retain information where necessary for tax, accounting, fraud prevention, dispute handling and other legal obligations.

The lawful basis is compliance with a legal obligation and, where relevant, our legitimate interests in establishing, exercising or defending legal claims.

With consent

Where we ask for optional marketing consent or another activity that relies on consent, that consent is separate from accepting the Terms. Consent can be withdrawn at any time.

5. Sources of personal data

We receive personal data:

• directly from you
• from people who send documents to an authorised Smart Bookkeeping address
• from account owners and authorised team members
• from connected services such as Xero
• from Stripe in connection with payments; and
• automatically from use of the Service and its infrastructure.

You are responsible for ensuring that you have authority to provide personal data about other people.

6. Service providers and recipients

We share relevant data only as needed to operate the Service, meet legal requirements or protect rights and security.

Current categories and providers include:

• Anthropic (Claude) and xAI (Grok) for document interpretation and automated processing
• Google for inbound email and related mailbox services
• Resend for outbound email and delivery logs
• Xero for authorised accounting integrations, draft entries and attachments
• Stripe for subscriptions, one-time purchases, invoices, cancellations and refunds
• Railway and other hosting/infrastructure providers for application hosting, databases, networking and operational logs; and
• professional advisers, authorities or counterparties where reasonably required by law or to protect legal rights.

Those providers process data under their own agreements, security controls, retention settings and privacy notices.

We do not sell personal data or use it for third-party advertising.

7. International transfers

Some providers may process personal data outside the United Kingdom.

Where required, we use appropriate safeguards such as:

• a UK adequacy regulation
• the UK International Data Transfer Agreement
• the UK Addendum to approved standard contractual clauses; or
• another lawful transfer mechanism.

Information about relevant safeguards may be requested using the contact details below.

8. Retention and deletion

Processing content

Email content, filenames, attachments, extracted text and accounting details are retained by Smart Bookkeeping only while a job is queued, processing or retrying.

After a successful response or final failure response, Smart Bookkeeping deletes that working content and its local temporary files.

Inbound messages are deleted from the processing mailbox after success or final failure, but Google may retain its own copies. The message sent and our reply may remain in the sender's or recipient's own email account.

Draft entries and source attachments sent to Xero remain in the authorised Xero organisation under Xero's retention controls.

Provider copies

Removing Smart Bookkeeping's working copy does not delete copies held by service providers. Anthropic, xAI, Google, Resend, Stripe, Xero and hosting providers may retain data according to their agreements and configured account settings.

We do not control how long Anthropic or xAI retain a provider-side copy after processing.

Resend may retain outbound email content and logs for the period applicable to our plan. Those messages may include processing results and contract confirmations.

Account, legal and operational records

We retain account, legal acceptance, contract, payment and confirmation records for as long as reasonably necessary to provide the Service, comply with tax and accounting requirements, resolve disputes and establish or defend legal claims.

We retain non-content operational metadata for longer than working content, including:

• timestamps and document types
• processing outcomes and error codes
• model, token, cost and credit totals
• internal account, company and run identifiers
• legal-document versions and acceptance evidence; and
• Xero tenant and document identifiers needed for audit and draft-only undo.

We maintain a retention schedule and delete or anonymise information when it is no longer required.

9. Automation and human review

Smart Bookkeeping uses automated systems to interpret documents and prepare draft bookkeeping outputs.

Automation may produce errors and outputs depend on document quality and context. Outputs require human review before use.

We do not train general-purpose models on your financial documents.

In limited cases, authorised personnel may review data to diagnose failures, resolve customer issues, maintain security or improve reliability. Access is restricted and we do not routinely review user documents.

Smart Bookkeeping does not make solely automated decisions that produce legal or similarly significant effects about individuals.

10. Security

We use reasonable technical and organisational measures designed to protect personal data, including:

• access controls
• secure processing environments
• monitoring and logging
• data-minimisation and deletion controls
• separation of operational roles; and
• incident response procedures.

No system is completely secure. You should use secure email and connected-service accounts and promptly report suspected unauthorised access.

11. Your rights

Depending on the circumstances, UK data-protection law may give you rights to:

• request access to personal data
• request correction of inaccurate or incomplete data
• request erasure
• request restriction of processing
• object to processing based on legitimate interests
• receive certain data in a portable format
• withdraw consent where processing relies on consent; and
• complain to a supervisory authority.

These rights are not absolute. We may need to verify identity and may retain information where the law permits or requires it.

12. Complaints

Please contact Zigetti Ltd first so that we can try to resolve a privacy concern.

You may also complain to the Information Commissioner's Office:

• Website: https://ico.org.uk/
• Telephone: 0303 123 1113

You may have the right to complain to another supervisory authority if you are located outside the United Kingdom.

13. Changes to this Privacy Notice

We may update this Privacy Notice to reflect changes to the Service, providers, processing activities or legal requirements.

We will bring material changes to your attention where appropriate. A Privacy Notice explains how data is processed; continued use is not treated as consent to changes.

Archived versions remain available so that we can identify the notice provided at a particular time.

14. Contact

Contact Zigetti Ltd about privacy or data-protection requests at:

1st Floor, 314 Regents Park Road London N3 2LT

When making a request, provide enough information for us to identify the relevant account and respond securely.