Privacy Policy

“Accountancy Automations” (the “Platform”, “we”, “us”) is operated by Move 37 (“Move 37”), [company registration number], registered at [company address]. You can reach us at [contact email].

The Platform is a multi-tenant service used by accountancy practices. Because two distinct data relationships exist, our role under the UK GDPR depends on the data:

• Client accounting data (the financial records of a practice’s end clients, ledgers, documents, balances). The practice is the data controller; Move 37 acts as a data processor, handling this data only on the practice’s documented instructions under a Data Processing Agreement.
• Practice account data (the names, work emails, and roles of the practice’s own staff who log in). For this, Move 37 is the data controller.

• Account & identity data : name, work email, assigned role (System Admin, System Manager, Company Owner, Company Manager), and authentication data.
• Client financial data : trial balances, bank balances, transactions, nominal ledgers, and aged debtor/creditor reports read from your connected ledger (FreeAgent or Xero).
• Source documents : bank statements, invoices, loan statements, and similar evidence read from your connected document store (Dropbox), which may contain personal data about your clients and third parties.
• Public register data : company details, filing history, and statements of capital retrieved from Companies House.
• Client documents read for a draft reply : when a client writes in and the sender is confidently matched to a client, the Platform may read a few relevant files from that client’s folder in your document store (see section 4A). File names and paths are stored; file contents are not, except the encrypted text kept for a partner’s own inbox drafts (section 4A).
• Draft communications : draft client emails prepared for your review in Microsoft 365 / Outlook (drafts only; never sent automatically).
• Usage & audit data : an immutable, append-only log of actions taken in the Platform, and technical logs needed to run the service securely.

We process personal data to:

• prepare and maintain working papers, and produce a partner-ready review pack;
• prove balance-sheet lines against evidence, draft proposed journals, and raise client or reviewer queries;
• authenticate users and enforce role-based access;
• maintain the audit trail and keep the service secure and reliable.

For practice account data we rely on legitimate interests (operating and securing the service) and, where applicable, performance of a contract. For client accounting data, the practice (as controller) is responsible for the lawful basis; we process it solely as its processor under our agreement.

The Platform uses Claude (provided by Anthropic) as its reasoning layer to analyse ledger data and evidence and to draft outputs. Two commitments apply:

• No autonomous action. The AI proposes journals, raises queries, and writes notes. It does not post to a live ledger, send client emails, or file anything. A human at your practice approves every client-facing action.
• No training on your data. In line with our data-provider terms, end-client accounting data processed through the Platform is not used to train foundational AI models.

The Platform does not copy or index your document store. When a draft reply to a client is prepared, it reads a small number of files from that client’s confirmed folder in the practice’s document store (Dropbox, read-only), for that one draft only.

• Processed in memory. File contents are processed in memory for the duration of the one draft and are then discarded. Contents and summaries of documents are never stored, except the encrypted text kept for a partner’s own inbox drafts, described below.
• What is stored. Only the file names and paths used, their size and modified date, and an audit entry recording which files were read.
• A person confirms the folder. The folder linked to each client is chosen or confirmed by a member of your practice, and the Platform can only read inside the practice’s own folder.
• Text kept for a partner’s own inbox. For drafts in a partner’s own inbox, Prova keeps the extracted text of a client’s Dropbox files, encrypted, for up to 90 days per file version so it doesn’t read them again; it is deleted when the client’s folder link changes or the client is removed.
• Hidden instructions. To spot hidden instructions, Prova also reads the formatted version of an email it drafts a reply to; it checks it in memory and keeps only whether something hidden was found.
• Scanned PDFs (OCR). Reading scanned pages with OCR is off by default. It is used only if the Company Owner switches it on in Settings, and sends those pages to the OCR sub-processor named below.

We do not sell personal data. We share it only with sub-processors that help us run the service, each under contractual data-protection terms:

• Supabase : application database, authentication, and workflow storage.
• Cloudflare : DNS, edge routing, and security.
• Anthropic : the Claude AI reasoning layer. Client data is not used to train Anthropic’s models.
• OpenRouter : routes AI requests to Anthropic’s models. Our requests are configured to deny data collection by providers, and can be restricted to zero-data-retention endpoints by the Platform administrator.
• Mistral AI : optical character recognition (OCR) of scanned PDFs, reached through OpenRouter: used for scanned bank statements, hire-purchase and debtor documents that cannot otherwise be read, and for client documents in email drafting only when your practice enables OCR in Settings.
• Your connected integrations : FreeAgent, Xero, Dropbox, Microsoft 365 / Outlook, and Companies House, which you authorise per company and which act under their own privacy terms.

We may also disclose data where required by law or to protect the rights, safety, or security of users and the service.

• Tenant isolation at the database. Access is enforced by row-level security keyed on the company, so a practice can only reach its own data, not just an application check.
• Encryption. Data is encrypted in transit (TLS) and at rest.
• Least-privilege access & role-based controls across the four user roles, with credentials managed via environment secrets, never stored in source code.
• Immutable audit logging. Material actions are recorded in an append-only log for traceability.
• Read-only ledger access in the current version, the Platform reads from your ledger and never writes back to it.

Some sub-processors may process data outside the UK. Where that happens, we rely on appropriate safeguards recognised under UK data-protection law (such as the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses). Contact us for details of the safeguards in place.

We retain personal data for as long as needed to provide the service and to meet legal, accounting, and audit obligations, after which it is deleted or anonymised. For client accounting data we act as processor, so retention and deletion follow the practice’s instructions and its own retention obligations. Audit-log entries are retained as part of the service’s integrity record. [Confirm specific retention periods with legal counsel.]

Under the UK GDPR you have the right to access, rectify, erase, restrict, or object to the processing of your personal data, and the right to data portability. Where we act as processor for client data, please direct such requests to the relevant accountancy practice (the controller); we will assist it in responding.

To exercise your rights regarding data we control, contact us at [contact email]. You also have the right to complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk.

The Platform uses only essential cookies required to keep you signed in and to secure your session. We do not use advertising or third-party tracking cookies.

The Platform is a professional tool not directed at children and is not intended for anyone under 18. We do not knowingly collect data from children.

We may update this policy from time to time. Material changes will be reflected by the “last updated” date above and, where appropriate, communicated to practices.

Questions about this policy or our data practices? Contact Move 37 at [contact email], or write to us at [company address]. [If a Data Protection Officer is appointed, add their contact here.]