Draft for review by counsel

This text has not yet been reviewed by a lawyer and may change before it takes effect. It describes what the software does today.

Points for counsel to check
  • The deadline for telling the firm about a personal data breach (section 9 says only without undue delay) and what the notice must contain, given the firm's own duties to the Data Protection Board and each affected person under the DPDP Rules, 2025.
  • Notice period and right to object before Dinero adds or replaces a sub-processor (section 7).
  • How long copies in the database provider's backups last after deletion, and whether to say so (section 11).
  • Whether Dinero should keep acceptance records and the deletion record after a firm leaves, and for how long.
  • The firm's duties for clients who are children or persons with disability (verifiable consent of a parent or guardian under section 9 of the Act). CA ClientOps does not check age.
  • Audit rights: whether the firm may inspect Dinero, or relies on information and reports (section 12).
  • AI checks (this version adds Anthropic as a sub-processor, only for firms that turn them on): confirm Anthropic's commercial terms for the API (no training on inputs, how long inputs are kept, where they are processed), and whether firms must tell their clients in their own notice that files may be read by an AI service.

Data processing agreement

The contract under which Dinero Technologies Pvt Ltd processes personal data for a CA firm, as required by section 8(2) of the Digital Personal Data Protection Act, 2023.

Version 2026-10-13

1. Roles

This agreement is between the CA firm that uses CA ClientOps and Dinero Technologies Pvt Ltd, 403, Vinita Building, Gokhale Road, Naupada, Thane 400602, Maharashtra. It forms part of the terms of service.

Under the Digital Personal Data Protection Act, 2023 (the "Act"), the firm is the Data Fiduciary for the personal data of its clients and their contact people, and of its own staff. Dinero is the firm's Data Processor: it processes that data only on the firm's behalf, to run CA ClientOps for the firm.

2. What is processed, and why

Whose data: the firm's clients (individuals, proprietors, partners and directors of client businesses) and the people the firm records as their contacts; and the firm's partners, managers and staff.

What data:

  • names, phone numbers, email addresses and preferred language of client contacts;
  • client details the firm enters, such as name, area and GSTIN;
  • the documents clients and staff upload, such as sales and purchase data and bank statements, which hold financial information;
  • messages sent to clients, their delivery status, and replies such as STOP;
  • when a client contact accepted the firm's privacy notice, their upload page sessions, and one-time codes (kept only as hashes);
  • staff accounts and the audit trail of changes.

Why: to collect documents for the firm's compliance work. That means sending checklists and reminders, receiving, checking and storing files, showing staff what is in and what is missing, keeping an audit trail, and exporting or deleting data when the firm asks.

When the firm turns AI checks on, uploaded PDFs and photos are also read by an AI service (section 7) to suggest which checklist item a file is, the period it covers and whether it is readable. These are suggestions only: nothing changes on a checklist until a person at the firm accepts one, and clients never see them.

For as long as: the firm uses CA ClientOps, and until its data is deleted under section 11.

3. The firm's instructions

The firm instructs Dinero through how it uses CA ClientOps and its settings: who its clients and contacts are, its checklists, whether messaging is off, in test or live, whether AI checks are on, its retention period, removing a contact or a client, exporting, and deleting the firm's data.

Dinero processes the data only on those instructions, or when the law requires it. If the law requires processing the firm did not ask for, Dinero will tell the firm first, unless the law forbids that.

4. What the firm does

  • Gives its clients notice and gets their consent where the Act needs it. The upload page shows the firm's notice and records each contact's acceptance before they can upload; with the firm's setting on, only the opening request goes to a contact until they accept.
  • Enters only the data it needs and keeps it accurate.
  • Chooses a retention period the law allows for its records (8 years unless the firm changes it, between 1 and 20).
  • Answers its clients' requests to see, correct or erase their data, using the tools in section 10.
  • Keeps its people's accounts safe and removes people who leave.

5. What Dinero does

  • Uses the data only to provide CA ClientOps to the firm. Dinero does not sell it, does not use it for advertising and does not combine it with other firms' data.
  • Makes sure everyone at Dinero who can reach the data is bound to keep it confidential.
  • Keeps the security safeguards in section 8 in place.
  • Helps the firm meet its duties under the Act, as set out below.

6. Support access

Dinero support sees a firm's details only when a partner grants support access, for 24 hours, 72 hours or 7 days, and the partner can end it at any time. Without a grant, Dinero's console shows only counts. Each grant, each end and each view is a line in the firm's audit trail.

A small number of Dinero engineers can reach the database directly to run and repair the service. They use that access only for that purpose.

7. Sub-processors

Dinero uses these services to run CA ClientOps. Each is bound by contract to protect the data at least as well as this agreement does.

  • Supabase Inc.: Hosts the database: accounts, clients, contacts, checklists, messages and the audit trail. Mumbai, India.
  • Cloudflare, Inc.: Runs the application (Cloudflare Workers) and its connection to the database (Hyperdrive), and stores the files clients and staff upload, and data exports (R2). The application is set to run in Mumbai, next to the database; Cloudflare's network may serve pages from the location nearest the visitor. Files are kept in an Asia-Pacific location, which may be outside India.
  • Resend: Sends email: invitations, password resets, the morning email to staff, and client emails when a firm uses email. May process email outside India.
  • Meta (WhatsApp Cloud API): Sends WhatsApp messages to a firm's clients and reports delivery. May process messages outside India. Only when the firm switches messaging on.
  • Functional Software, Inc. (Sentry): Receives error reports: the error message and technical details, which can name a record. Outside India. Only when Dinero switches error reporting on.
  • Razorpay Software Pvt Ltd: Takes subscription payments. Dinero never sees or stores card details. Razorpay's own systems; Razorpay is an Indian payment company. Only once paid plans start.
  • Anthropic, PBC: Reads a PDF or photo a client or the firm uploaded, with the names of the checklist items and the period, to suggest which item it is, the period it covers and whether it is readable. The client's name, GSTIN, phone number and email are not sent with it, but the file itself is sent as it is. A person at the firm confirms every suggestion. Outside India (United States). Only when the firm turns AI checks on.

Dinero will tell the firm before adding or replacing a sub-processor, by publishing a new version of this agreement, which partners accept before continuing. A firm that does not agree may export its data and leave.

8. Security safeguards

  • Each firm's data is kept apart by row-level security in the database, so one firm's queries can never read another firm's rows.
  • Partners must use two-factor sign-in. Passwords are stored only as one-way hashes; authenticator secrets are encrypted.
  • Upload links, sign-in links and one-time codes are stored only as hashes, work for a limited time and are limited in how often they can be tried.
  • Each file's real content is checked on arrival against the allowed types and sizes. Files are served only to the firm's staff, or to the client after a one-time code.
  • Signed-in devices are recorded and can be signed out; a password change or a reset signs out every other device.
  • Every change, every data export and every download of the audit trail leaves a line in the firm's audit trail.
  • Traffic is encrypted in transit (HTTPS).

9. Personal data breaches

If Dinero becomes aware of a personal data breach affecting the firm's data, it will tell the firm's partners without undue delay, with what is known: what happened, which data and people may be affected, what Dinero has done, and who to contact. Dinero will help the firm inform the Data Protection Board of India and the people affected, as the Act and its rules require.

10. Helping with people's rights

CA ClientOps gives the firm the tools to answer requests from its clients and staff:

  • staff can correct a client's or contact's details on the client's page;
  • a partner can remove a contact, or a client and everything about them, from Settings, Privacy and data;
  • a partner can export all of the firm's data as spreadsheets and files;
  • a contact who replies STOP gets no more automatic reminders.

For anything the tools do not cover, write to info@dinerotechnologies.in and Dinero will help.

11. Retention and deletion

  • Each client file is deleted automatically when the firm's retention period ends. The record that it was received stays, so the firm can show what came in and when.
  • A data export is deleted 7 days after it is ready.
  • When a partner deletes the firm's data, every record about the firm, its clients and its people is deleted at once, and the stored files are deleted shortly after. Dinero keeps one record that it happened: the firm's name, the date, the name and email of the partner who asked, and how many records and files were deleted.

12. Information

Dinero will give the firm the information it reasonably needs to show it is meeting the Act, including how CA ClientOps protects data. Partners and managers can read and download the firm's audit trail at any time.

13. Changes

Each version of this agreement has a version number. When Dinero publishes a new version, every partner is asked to accept it before continuing to use the app.