Privacy Policy

Last Updated: March 1, 2026Version: 1.0

This Privacy Policy ("Policy") describes how ZeroFin ("ZeroFin," "we," "us," or "our") collects, uses, discloses, and otherwise processes personal information in connection with our AI-native financial operations platform, our website, and our AI assistant, Mr. CFO.

01

Scope and Roles

1.1Applicability

This Policy applies to individuals who visit our website, use the ZeroFin platform, or interact with our services (collectively, the "Services").

1.2ZeroFin as a Data Processor

For the majority of the data processed by the platform—including bank statements, audit reports, invoices, and historical accounting records uploaded by our Customers ("Customer Data")—ZeroFin acts as a Data Processor (or "Service Provider" under the CCPA/CPRA).

Customer Responsibility

Our Customers (typically the entities subscribing to the Services) act as the Data Controller. Customers are solely responsible for establishing a lawful basis for processing, providing required transparency notices to their employees, contractors, or vendors, and responding to data subject rights requests relating to Customer Data, except as expressly agreed in a separate Data Processing Addendum (DPA).

Purpose Limitation

ZeroFin does not determine the purposes or means of processing Customer Data beyond what is necessary to provide the Services as instructed by the Customer.

1.3ZeroFin as a Data Controller

ZeroFin acts as a Data Controller (or "Business" under the CCPA/CPRA) only for information used to manage account relationships, billing, marketing, and the technical security and optimization of our infrastructure.

02

Categories of Data Collected

2.1Information Provided Voluntarily
Account and Authentication Data

Name, professional email address, job title, password hashes, multi-factor authentication (MFA) tokens, and recovery data.

Customer Support Communications

Records of correspondence, including support tickets, chat logs with Mr. CFO, and any attachments provided during troubleshooting.

Financial and Transaction Metadata

Payment processor transaction IDs, billing addresses, and partial credit card information (last four digits) used for subscription management.

2.2Information Collected Automatically
System Logs and Security Telemetry

IP addresses, browser types, operating systems, access timestamps, and device identifiers used for threat detection and system monitoring.

Diagnostic Data

Error reports, crash logs, and performance metrics used to maintain platform stability.

Usage Analytics

Information regarding how users interact with platform features and Mr. CFO prompts.

2.3Third-Party Data within Customer Records

Financial records uploaded by Customers may contain personal data of third parties, including but not limited to employee payroll details, contractor tax IDs, and vendor contact information. ZeroFin processes this data solely as a processor under Customer instruction.

03

Purposes and Lawful Bases for Processing

We adhere to the principles of Data Minimization and Purpose Limitation. Personal data is processed only for purposes compatible with those described below:

Category of ProcessingPurposeLawful Basis (GDPR/UK GDPR)
Service DeliveryReconstructing financial history, generating journal entries, and AI analysis.Performance of Contract
Account ManagementAuthentication, MFA, and administrative communications.Performance of Contract
Platform SecurityFraud prevention, security telemetry, and threat mitigation.Legitimate Interests (Safety & Integrity)
Product OptimizationAnalyzing error reports and diagnostic data to improve AI accuracy.Legitimate Interests (Service Improvement)
Billing & ComplianceProcessing payments and maintaining statutory accounting records.Performance of Contract / Legal Obligation
MarketingSending updates or newsletters (where permitted).Consent / Legitimate Interests

Legitimate Interest Balancing: Where we rely on legitimate interests, we perform a balancing test to ensure our interests do not override your fundamental rights.

Consent Withdrawal: Where processing is based on consent, you may withdraw it at any time; however, withdrawal does not affect the lawfulness of processing performed prior to withdrawal.

Marketing Opt-Out: Where we rely on legitimate interests for business-to-business marketing communications, you may object at any time by using the unsubscribe link in the communication or contacting us at privacy@zerofin.ai. We will honor such requests in accordance with applicable law.

04

AI and Automated Processing Disclosure

4.1Decision Support Only

ZeroFin utilizes machine learning and AI algorithms to automate financial categorization and historical reconstruction.

No Solely Automated Decisions

ZeroFin does not engage in solely automated decision-making that produces legal or similarly significant effects regarding individuals under GDPR Article 22.

No Profiling

ZeroFin does not engage in profiling that produces legal or similarly significant effects concerning individuals. Any categorization or financial analysis generated by the platform is intended solely to support Customer decision-making.

Human-in-the-Loop

All AI-generated outputs, including suggested journal entries and runway forecasts, are decision-support tools only.

Customer Responsibility

The responsibility for final verification, human review, and the legal accuracy of financial filings remains exclusively with the Customer.

05

U.S. State Privacy Rights (CPRA, VCDPA, CPA, CTDPA, UCPA)

5.1No Sale or Sharing

ZeroFin does not sell personal information and does not share personal information for cross-context behavioral advertising as defined under the California Privacy Rights Act (CPRA) and similar state laws.

Sensitive Personal Information (CPRA)

ZeroFin processes Sensitive Personal Information (such as financial account credentials or tax identifiers) solely for purposes reasonably necessary to provide the Services requested by Customers, detect security incidents, prevent fraud, comply with legal obligations, or as otherwise permitted under applicable law. We do not use or disclose Sensitive Personal Information for purposes requiring a separate right to limit under the CPRA.

5.2Resident Rights

Depending on your state of residence, you may have the following rights: access, deletion, correction, portability, and opt-out where applicable. We will not deny services or change prices if you exercise your privacy rights (Non-Discrimination).

5.3Request Submission

To exercise these rights, email privacy@zerofin.ai. You may designate an authorized agent to submit requests on your behalf; we require written proof of such authorization and will verify your identity directly.

06

Data Subject Rights Process

6.1Verification

Upon receipt of a request, we perform verification steps proportionate to the sensitivity of the data, which may include email verification, MFA challenges, or matching identifiers against our records.

6.2Timelines
GDPR/UK GDPR

Responses are provided within 30 days.

U.S. State Laws

Responses are provided within 45 days.

We reserve the right to extend these periods where permitted by law, provided we notify you of the reason.

6.3Denials and Appeals

Requests may be denied if they are manifestly unfounded, excessive, or conflict with legal obligations. If a request is denied, we will provide an explanation. Residents of CO, VA, and CT have the right to appeal denials by contacting appeals@zerofin.ai.

Where required under applicable law, individuals may lodge a complaint with their local supervisory authority. For individuals located in the European Economic Area, the United Kingdom, or Switzerland, you have the right to lodge a complaint with your national data protection authority, including the Information Commissioner's Office (ICO) in the UK or your local EU supervisory authority.

07

Subprocessors and International Transfers

7.1Subprocessor Obligations

ZeroFin utilizes third-party subprocessors bound by written agreements imposing strict confidentiality, security, and data protection obligations. A current list is maintained at zerofin.ai/subprocessors. We notify Customers of updates via the platform or email.

7.2International Transfers

Data is hosted primarily in the United States. For transfers from the EEA, UK, or Switzerland, we utilize Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum, supported by Transfer Impact Assessments (TIAs) and technical safeguards for onward transfers.

08

Data Retention and Security

8.1Retention Criteria

We retain personal information based on the following: the duration of the Customer's contract; statutory requirements (e.g., tax/accounting compliance); necessity for dispute resolution or fraud prevention; and preservation requirements in connection with litigation, investigations, or legal holds.

8.2Deletion and Backups

Backups may persist for up to 30 days beyond the primary deletion cycle. Where required, we may retain specific records subject to legal hold, regulatory inquiry, or dispute resolution obligations until such matters are resolved. Anonymized data may be retained indefinitely.

8.3Security Measures

We implement commercially reasonable technical and organizational measures to protect data. However, no method of transmission or storage is completely secure; we cannot guarantee absolute security.

09

Cookies and Tracking

We classify cookies as Strictly Necessary, Analytics/Performance, or Optional Marketing. Users can manage preferences via our Cookie Consent Manager. We do not currently respond to browser-based "Do Not Track" signals.

10

General Provisions

10.1Children's Data

The Services are not directed to individuals under 18. If we discover child data has been collected, it will be deleted immediately.

10.2Business Transfers

In the event of a merger, acquisition, or asset sale, personal information may be transferred to the successor entity, subject to this Policy.

10.3Limitation of Obligations

This Policy does not create contractual or fiduciary obligations beyond those required by applicable law or specific written agreements.

11

Contact Information

Email

team@zerofin.io

Address

Company Registered Address

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