Privacy notice

1. Who this notice is for

This notice covers personal data that Dinero Technologies Pvt Ltd ("Dinero", "we") handles about partners, managers and staff who use CA ClientOps at a firm, people who sign a firm up, and visitors to its public pages.

It does not cover the firm's clients. For them the firm is responsible, and Dinero handles their data only on the firm's behalf under the data processing agreement. Clients see the firm's own privacy notice on their upload page before they send anything.

2. Who we are

Dinero Technologies Pvt Ltd, 403, Vinita Building, Gokhale Road, Naupada, Thane 400602, Maharashtra. Email info@dinerotechnologies.in.

3. What we hold about you

• Your account: your name, work email, role and firm.
• Your password, kept only as a one-way hash (bcrypt), never in readable form.
• Two-factor sign-in: the authenticator secret, encrypted, and your recovery codes, kept only as one-way hashes.
• Your devices: one record for each device you sign in on, with the browser's description and when it was last used, so you can sign a device out.
• What you do in the app: an audit trail line, with your name, for each change you make, each export and each audit download.
• Sign-up: the firm's name and city, your name, your email and the IP address the form came from.
• Acceptance: which version of the terms, this notice and the data processing agreement you accepted, when, your IP address and the browser's description.
• Rate limits: counts of sign-in and sign-up attempts, keyed by a one-way hash of your email or IP address, deleted after a day.
• Emails we send you: invitations, password resets, the morning email of the day's work (which you can switch off), and notices that an export is ready.

4. Why we use it

• To sign you in and keep accounts safe, including limits on repeated attempts.
• To run CA ClientOps for your firm, and to show your firm who did what.
• To send you the emails the service needs.
• To record that the firm and its people agreed to these documents.
• To bill the firm once paid plans start.
• To find and fix faults.

We do not sell personal data, use it for advertising, or build profiles of you.

5. Cookies

The app sets only the cookies it needs to work:

• the sign-in cookie, which keeps you signed in for up to 12 hours on that device;
• a short cookie of 5 minutes while you enter a two-factor code;
• a cookie for 12 hours if a partner chooses to look around before finishing the firm's setup;
• on a client's upload page, a cookie that keeps that client's page open on their phone.

There are no advertising or analytics cookies and no tracking scripts in the app. The app's fonts are served by the app itself. The public proposal page at the site's home loads fonts from Google Fonts, so your browser contacts Google when you open it.

6. Who else handles it

These services handle data for CA ClientOps, each under contract:

• 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's console shows only counts for a firm unless a partner grants support access for a fixed time; each view is then recorded in the firm's audit trail. A small number of Dinero engineers can reach the database directly to run and repair the service.

We share personal data with others only when the law requires it.

7. Where it is kept

The database is in Mumbai, India. Uploaded files and exports are kept in an Asia-Pacific location, which may be outside India. Email, WhatsApp and error reports may be handled outside India by the services above, and so may files a firm sends for AI checks when it turns them on. The Digital Personal Data Protection Act, 2023 allows this unless the government restricts a country; if it does, we will move the data.

8. How long we keep it

• Your account, devices and audit trail lines stay while your firm uses CA ClientOps. A partner can deactivate your account; the record of what you did stays in the firm's audit trail.
• Client files are deleted automatically when the firm's retention period ends (8 years unless the firm changes it).
• When a firm deletes its data, everything about the firm and its people is deleted. Dinero keeps one record that it happened: the firm's name, the date and the name and email of the partner who asked.
• A sign-up link works for 24 hours. The sign-up record itself is deleted 30 days after it is made.
• Rate-limit counts are deleted after a day.

9. How we protect it

• Every firm's data is kept apart in the database itself, not just in the app: a firm can only ever read its own rows.
• Partners must use two-factor sign-in. Sign-in links and codes are kept only as one-way hashes, work once and expire.
• Each signed-in device can be signed out at any time, and a password change signs out every other device.
• Files are checked on arrival and served only to the firm's staff, or to the client with a one-time code.
• Traffic is encrypted in transit (HTTPS).

10. Your rights

Under the Digital Personal Data Protection Act, 2023 you may ask for a summary of the personal data we hold about you, ask us to correct, complete, update or erase it, name someone to act for you if you cannot, and raise a grievance with us.

Write to info@dinerotechnologies.in. Some changes, such as your name or role, are made by a partner at your firm. If you are not satisfied with our answer, you may complain to the Data Protection Board of India.

11. Changes to this notice

Each version of this notice has a version number. When we publish a new version, everyone at the firm is asked to read and accept it before continuing to use the app.