Privacy and the security of data are of paramount importance to all of us at Audapio. Please read this document carefully, and if you have any questions or queries about its contents, please e-mail us at firstname.lastname@example.org.
Audapio Ltd (collectively referred to as “we”, “us” or “our” in this policy) acts as a controller for any of your personal data which is collected or used via our Website and/or Web App. We are registered as a controller under registration number ZA678773 with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
If you access the Web App through an invitation triggered by an accountancy firm, that firm will be able to access personal data related to you which is made available on the Web App (including Identity Data, Contact Data, Financial Data and Transaction Data, as defined below). That firm will also act as a controller for any of your personal data which is collected or used via the Web App and which they use for their own client management purposes.
Our full details are:
You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance, at email@example.com.
Truelayer is our Account Information Services provider. We use Truelayer to securely connect your accounts and credit cards to Audapio.
When you connect, Truelayer gains read-only access and stores transaction data associated with the connected accounts. This lets us display your account information and transactions within Audapio. All your details are encrypted and protected by bank level security.
Audapio is acting as an agent of TrueLayer, who is authorised by the FCA as an Authorised Payment Institution (reference number: 793171).
The Website and Web App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these third-party websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check the privacy policies of any third-party websites or services before you submit any personal data through them.
We may collect, use, store and transfer different kinds of personal data about you as follows:
|Financial Data||Bank account information:|
|Transactional Data||Financial transaction data:|
We can collect personal data about Audapio users in the following ways:
Information shared with us by accountancy firms. An accountancy firm may ask us to send you an invitation to use the Web App, so that the firm can rely on our Web App to provide services to you more effectively. In this case, the firm will provide us with an e-mail address which we will use only to send you an invitation to start using the Web App.
Information you give us. You may decide to actively share personal data with us via the Web App or Website (for example, by registering to use the Web App or subscribing to any of our services), or by corresponding with us (for example, by reporting a problem with the Web App or the Website to us via e-mail or chat). If you contact us, we will keep a record of that correspondence.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Device Data from analytics providers;
Contact, Financial and Transaction Data from providers of technical, payment and banking services based inside the EU.
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us, at firstname.lastname@example.org.
It is important that the personal data we hold about you is accurate and current, to ensure that it is used fairly and reduce the risk of harm being caused to you. Please keep us informed if your personal data changes during our relationship with you, by reaching out to us at: email@example.com.
We may use personal data which we collect on you, through the Website and/or Web App, for the following purposes:
|Purpose / Activity||Type of data||Lawful basis for processing||Mandatory/optional|
|To provide you with the Services (categorised transactions, internal and external audit analysis) by linking your bank accounts and associated Transaction Data to the Web App||Identity Contact Financial Company Transaction||Performance of a contract with you||It is contractually mandatory for you to share these data with us - otherwise, we will not be able to provide you with the services.|
|To share income and expenditure analytics with accountancy firms via the Web App||Identity Contact Financial Transaction||Consent||If you sign-up to use our Web App through an invitation made by an accountancy firm, these data will automatically be made visible to that firm on the Web App. You can avoid this by signing up autonomously to use the Web App instead (in which case, no data will be visible to any accountancy firms), or by withdrawing your consent (see below).|
|To manage our relationship with you including notifying you of changes to the Website, the Web App or any Services||Identity Contact||Performance of a contract with you||It is contractually mandatory for you to share these data with us – otherwise, we will not be able to correctly perform our contract with you.|
|Storing and using Transaction and Financial Data handled over the Web App to develop and improve our AI models and algorithms.||Financial Transaction||Necessary for our legitimate interests (to train and improve the accuracy of our AI models and analytics and to improve our categorisation of transactions, internal and external audit analysis)||It is not mandatory for you to share these data with us - you can object to this activity (see below for more information).|
|To collect information on how you interact with our Website, such as the pages you visit and time spent on each page, in order to improve our Website and the services we offer||Device Usage||Consent||It is optional for you to allow us to carry out this activity – you can do so by consenting to the use of analytics cookies on the Website.|
|To administer and protect our business and our Website and Web App, including troubleshooting, data analysis and system testing||Device Usage||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)||It is mandatory for you to share these data with us, so that we can ensure the security of the Website and Web App.|
Please note that, if you have been invited to use the Web App by an accountancy firm, that firm may also process personal data related to you via the Web App for their own purposes (typically, to provide financial services to you).
The firm which invited you to use the Web App is solely responsible for their own use of your personal data – please reach out to them directly if you have any specific questions on how they are handling your information.
As noted above, if you would prefer to use the Web App without sharing information with an accountancy firm, you should instead sign-up to the Web App autonomously. You can also contact us at firstname.lastname@example.org to request that your data stop being visible to the accountancy firm which invited you.
We may share some or all of your personal data with the third parties set out below for the purposes set out in the table above (“Purposes for which we will use your personal data”):
We do not autonomously transfer or host your personal data outside the European Economic Area (EEA).
In the event that you consent to the sharing of your personal data through the Platform with an Accountancy Firm located outside the EEA, this will result in a transfer of personal data to outside the EEA. Any such transfer will be based on your explicit consent, and will be further safeguarded by the implementation of Standard Contractual Clauses between Audapio and the Accountancy Firm.
Accountancy Firms located outside of the EEA which accept the Platform’s Terms and Conditions are deemed as having entered into a written agreement (as data importer) with Audapio (as data exporter) containing the Standard Contractual Clauses, as laid out by European Commission Decision no. 2004/915/EC of 27 December 2004 (as may be amended from time to time). The Standard Contractual Clauses will apply to all transfers of personal data occurring via the Platform, from Platform users located in the EEA to Accountancy Firms located outside of the EEA.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website/Web App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your device using application data caches and browser web storage (including HTML5) and other technology.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
For example, we may use your Financial, Transaction, Location and Device Data to train artificial intelligence models to improve our Services of internal and external audit analysis (for our legitimate interests). We will retain this personal data for as long as reasonably necessary for this purpose.
For further information on specific retention periods applicable to your personal data, please e-mail us at: email@example.com.
Our Services are not intended for use by anyone younger than 18 years old. Please do not use our Services if you are under 18.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
|Right of access||As a rule you are entitled to:|
|Right to rectification||As a rule, you are entitled to ask us to correct or complete any inaccurate or incomplete personal data we hold on you.|
|Right to erasure (“right to be forgotten”)||Under certain circumstances, you are entitled to ask us to delete or anonymise personal data we hold on you.|
|Right to restriction of processing||Under certain circumstances, you are entitled to ask us to restrict the use of personal data we hold on you, for a limited period of time.|
|Right to data portability||As a rule, you are entitled to ask us for a copy of your personal data in a structured, commonly used and machine-readable format. You can then transfer that copy to any other controller at will.|
You can also ask us to transfer these personal data to another controller for you, if this is technically feasible for us.
|Right to object||You are entitled to object to any use of your personal data which is based on the performance of a task in the public interest, or based on our own legitimate interests. These objections should be based on your particular situation/circumstances.|
You are also entitled to object to any use of your personal data for marketing or associated purposes, for any reason.
|Right to withdraw consent||If you have given us consent to use your personal data for a specific purpose, you are entitled to withdraw that consent at any time.|