SnapLedger — Privacy Policy

Version: 1.1 Effective date: 2026-06-12 Publisher: DAOILE CONSULTING - FZCO, a Free Zone Company registered with the Dubai Integrated Economic Zones Authority (DIEZ), Emirate of Dubai, United Arab Emirates ("Daoile", "we", "us", "our"). Contact: support@snap-ledger.com Service: SnapLedger, available on the web at snap-ledger.com and via our iOS and Android applications (collectively, the "Service").

This Privacy Policy explains what personal data we collect, how we use it, where we store it, and the rights you have over it. It is published in English; translations into Arabic, French, and Chinese are provided for convenience and the English master prevails in the event of any conflict.

1. Who is the controller

DAOILE CONSULTING - FZCO is the data controller for the personal data you provide when you use SnapLedger. You can reach our data-protection contact at support@snap-ledger.com.

2. What data we collect

2.1 Identity and contact data

Email address
Display name (typically first + last name)
Country of residence (individual users) or country of business registration (business users)
Telephone number (optional)
Preferred language

2.2 Business profile data (business users only)

Registered business name, trade-license number, issuing authority
Tax-registration numbers (for example, value-added tax or corporate income tax identifiers issued by your jurisdiction's tax authority)
Registered business address, industry sector

2.3 Documents and parsed financial data

Receipts, invoices, bank/credit-card statements, salary slips, balance sheets, tax returns and similar documents you upload
Structured data extracted by our AI parsers from those documents (vendor names, amounts, dates, line items, tax codes, etc.)
Manually entered transactions, classifications, and notes you add to your ledger
Reports you generate (P&L, Balance Sheet, Trial Balance, VAT 201, etc.)

2.4 Authentication data

Email/password sign-in — passwords are hashed by Firebase Authentication; we never see your plaintext password.
Sign in with Apple — Apple shares only an opaque identifier (the "sub" claim) and, if you authorise it, your email address (or a private-relay alias xxx@privaterelay.appleid.com). We do not receive your Apple ID password.
Sign in with Google — Google shares your email and a profile-display name. We do not receive your Google account password.
Two-factor authentication — if you enable authenticator-app MFA, Firebase Identity Platform manages the TOTP enrolment artefacts; we store only security audit events such as enrolment, disablement, or support-assisted clearing.

2.5 Usage and audit data

Sign-in timestamps and the country/region of the signing-in device (used for security and anomaly detection)
Admin support-session audit logs — only created when you explicitly request customer support and an admin has been authorised to act on your account
Error/crash logs — these contain stack traces and metadata only; never the contents of your documents or financial records

2.6 Subscription and payment data

Subscription tier and status
Payment metadata (we do not store your card number — that is held by Stripe under their PCI-DSS Level 1 environment)

We do not collect biometric data, location data, contact lists, advertising identifiers, or any data unrelated to bookkeeping.

3. How we use your data

We process your data only for the purposes set out below:

Purpose	Legal basis (PDPL/GDPR)
Provide the bookkeeping service you signed up for (account creation, document upload, parsing, ledger, reporting)	Performance of the contract
Run AI parsing on uploaded documents to extract structured data	Performance of the contract
Generate tax and accounting reports for your own use and for sharing with your advisers	Performance of the contract
Customer support — including admin-initiated "Customer Support Sessions" you authorise	Performance of the contract / your explicit consent
Send transactional notifications (e.g., email verification, password reset, payment receipts)	Performance of the contract
Maintain audit logs of admin actions on user accounts	Compliance with our regulatory and accounting-record obligations
Detect fraud, abuse, and security incidents	Our legitimate interests in keeping the Service safe

We do not use your financial data for advertising, profile-building, model training outside your own session, or sale to any third party.

4. AI document parsing

Documents you upload are processed by AI models hosted by Google Cloud Vertex AI (Gemini family) within the GCP region matched to your data-residency tier (see §5). We only invoke the AI to extract structured data for your own ledger; we do not use your documents or extracted data to train any AI model.

5. Where your data is stored (data residency)

We choose the storage region for your account based on the country you selected at sign-up. Within that region, your bookkeeping data, uploaded documents, AI processing, and backups all stay together — we do not replicate them to a different region.

We route in one of three ways:

In-country hosting — where Google Cloud Platform operates a data centre inside your country, your data is stored there. Examples:

Saudi Arabia → Dammam (me-central2)
Germany → Frankfurt (europe-west3)
France → Paris (europe-west9)
United Kingdom → London (europe-west2)
Spain / Portugal → Madrid (europe-southwest1)
Italy → Milan (europe-west8)
Netherlands → Eemshaven (europe-west4)
Poland → Warsaw (europe-central2)
Belgium → Saint-Ghislain (europe-west1)
Finland and Nordics → Hamina (europe-north1)
Switzerland → Zurich (europe-west6)
Israel → Tel Aviv (me-west1)
Japan → Tokyo (asia-northeast1)
South Korea → Seoul (asia-northeast3)
India → Mumbai (asia-south1)
Singapore → Singapore (asia-southeast1)
Indonesia → Jakarta (asia-southeast2)
Taiwan → Changhua (asia-east1)
Hong Kong → Hong Kong (asia-east2)
Australia → Sydney (australia-southeast1)
Brazil → São Paulo (southamerica-east1)
South Africa → Johannesburg (africa-south1)
Canada → Montréal (northamerica-northeast1)
United States → Iowa (us-central1)

Cross-border hosting (adjacent jurisdiction) — where Google Cloud has no in-country data centre but an adjacent jurisdiction qualifies for an adequacy decision or a Standard Contractual Clauses transfer:

Your country	Data is processed in	Basis for the transfer
United Arab Emirates	Qatar (Doha, `me-central1`)	UAE PDPL cross-border adequacy + Google Cloud SCCs
Bahrain, Kuwait, Oman	Qatar (Doha)	GCC-adjacent adequacy + Google Cloud SCCs
Egypt	Qatar (Doha)	Egypt PDPL Art. 14 (adequacy) + Google Cloud SCCs
Ireland	United Kingdom (London)	EU–UK adequacy decision (2021) + Google Cloud SCCs
Türkiye	Netherlands (Eemshaven)	KVKK Art. 9 explicit consent + Google Cloud SCCs
New Zealand	Australia (Sydney)	NZ Privacy Act IPP 12 + Google Cloud SCCs
Liechtenstein	Switzerland (Zurich)	EEA–Swiss adequacy
Luxembourg	Belgium (Saint-Ghislain)	Intra-EEA — no cross-border transfer

Generic hosting — countries without a strict data-localization law are served from our United States region (us-central1, Iowa) for operational reasons. We rely on your consent and the Google Cloud Standard Contractual Clauses.

Once chosen, your data does not move between regions. Backups and AI processing run in the same region. The authoritative country-to-region mapping is in our Terms of Service §6.1.

6. Sub-processors (third parties who process your data on our behalf)

Sub-processor	Purpose	Where data is processed
Google Cloud Platform (Firebase Authentication, Cloud Firestore, Cloud Storage, Cloud Functions, Vertex AI)	Hosting, authentication, database, storage, AI parsing	Region pinned to your residency (§5)
Apple Inc.	"Sign in with Apple" identity provider	Apple's infrastructure
Google LLC	"Sign in with Google" identity provider	Google's infrastructure
Stripe, Inc.	Subscription billing (we never store card data)	Stripe's PCI-DSS environment
Resend, Inc.	Transactional email delivery (verification, password reset)	Resend's infrastructure

Each sub-processor is bound by a written data-processing agreement with us. We update this list when sub-processors change; material changes trigger an in-app notice.

7. Cookies and tracking

The web application uses only essential cookies required for the Firebase Authentication session. We do not use marketing cookies, advertising trackers, third-party analytics in the application, or any cross-site tracking. A cookie banner is therefore not required in the jurisdictions whose law we follow.

8. Your rights

Whether you are protected by the UAE Personal Data Protection Law (PDPL), the EU GDPR, the UK GDPR, the California Consumer Privacy Act (CCPA), or another regional regime, you have at minimum the right to:

Access — request a copy of the personal data we hold about you;
Correction — fix inaccurate or out-of-date data, either via the in-app forms or by emailing us;
Deletion — delete your account and associated data via My Account → Delete Account, or by emailing us;
Portability — export your transactions, journal entries, and generated reports via the in-app reports view, or request a structured export by email;
Withdraw consent — uninstall the app and email us to delete your account; we will erase your data within the retention window in §9;
Lodge a complaint — with your data-protection authority (in the UAE, the PDPL regulator; in the EEA/UK, your local Data Protection Authority; etc.).

Most rights can be exercised inside the app. For anything else, write to support@snap-ledger.com. We respond within 30 days.

9. Retention

Active accounts — data retained for as long as your account is active.
Deleted accounts — fully erased within 90 days of deletion request (some metadata may persist longer in encrypted backups; those backups rotate every 30 days and we erase fully within 90 days from request).
Admin audit log — retained for 7 years as required by accounting-record regulations.
Subscription billing records — retained as required by tax law in the jurisdiction we file in (typically 5–7 years).

10. Security

We protect your data with industry-standard controls:

In transit — TLS 1.2+ on every network hop.
At rest — encrypted storage with provider-managed keys (Google Cloud Storage / Firestore default encryption, AES-256).
Authentication — Firebase Authentication with multi-factor support; OAuth flows with Apple/Google handled by their respective providers.
Region pinning — your data is stored only in the region matched to your country (§5); we never replicate to other regions.
Admin access — admin actions on user accounts are gated by a per-user "Customer Support Lock" you authorise, and every admin write is logged in an audit trail (§2.5).

No system is perfectly secure. If we become aware of a personal-data breach affecting your account, we will notify you and the relevant authority within 72 hours, in accordance with applicable law.

11. Children

SnapLedger is not directed at children. You must be 18 or older to use the Service (per our Terms of Service §1). We do not knowingly collect personal data from anyone under 18; if we learn we have, we delete it promptly.

12. Sign in with Apple — additional notes

When you sign in with Apple:

We receive: an opaque user identifier (the JWT sub claim) issued by Apple.
If you choose to share your email, we receive that email — either your real email or Apple's private-relay alias (xxx@privaterelay.appleid.com). Email forwarded to a private-relay alias is forwarded to your real address by Apple; we never see the underlying address.
We do not receive your Apple ID password or any other Apple account information.

You can revoke our access at any time at https://appleid.apple.com → Sign in with Apple → SnapLedger → Stop Using. After revocation, you can no longer sign in to your account using Apple; signing up again with the same Apple ID will create a new SnapLedger account.

13. Gmail connection (Google API Services) — Limited Use

If you choose to connect your Gmail account (SnapConnect → Email), SnapLedger requests the read-only Gmail scope (gmail.readonly) and uses it solely for a feature you initiate: you pick a date period, SnapLedger searches your mailbox for emails carrying PDF receipt or invoice attachments, shows you the matches in a review step, and imports only the attachments you explicitly select into your own document vault, where they are processed like any other document you upload (§3, §4).

We never send, modify, or delete your email, and we never change your mailbox in any way.
We do not use Gmail data for advertising, and we never sell it.
No human reads your Gmail data, except with your explicit consent for support or debugging, where required for security investigations or legal compliance, or where the data is aggregated and anonymised.
Your Gmail access tokens are stored encrypted in Google Cloud Secret Manager and are deleted when you disconnect Gmail.

SnapLedger's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

14. Changes to this policy

We may update this policy from time to time. The version number and effective date at the top of this document indicate the current revision. Material changes (those that meaningfully reduce your rights or expand the data we collect) require an in-app notice and your renewed consent before we apply them to your account; non-material changes (typographical fixes, sub-processor list updates) take effect on posting.

Prior versions of this policy remain available at the same /legal/privacy/v{version} URL on our website so you can see the version that applied when you signed up.

15. Contact

For any privacy question, request, or complaint:

DAOILE CONSULTING - FZCO Dubai Integrated Economic Zones Authority (DIEZ) Emirate of Dubai, United Arab Emirates Email: support@snap-ledger.com

We will acknowledge your request within 7 days and respond substantively within 30 days, in accordance with applicable law.