Legal · Effective April 18, 2026

Privacy Policy

This Privacy Policy describes how Ledger Layer (“we”, “us”, “Ledger Layer”) handles personal information in connection with the Ledger Layer service (the “Service”), this website, and related communications. It applies to customers, prospects, Authorized Users of the Service, and visitors to https://ledgerlayer.app. It is read together with our Terms of Service and Advisory Disclaimer.

Our privacy stance in one paragraph.We do not process personal data within the financial datasets, workbooks, or accounting content Customers submit to the Service, and Customers contractually agree not to submit such data. We do, however, process limited personal data that qualifies as such under the GDPR and CCPA — specifically, the business contact information required to operate user accounts (work email, name, role) and the operational telemetry (including IP address and request logs) necessary to run a secure, auditable B2B application. We do not sell personal information, we do not use your content to train AI models, and the Service is architected to pass only structural metadata — not financial cell values — to AI model providers, under contracts that prohibit retention and training.

1. Scope and Controller / Processor Roles

For personal information collected about website visitors, prospects, and our own account administrators, Ledger Layer acts as a data controller. For personal information that a Customer causes to be stored or processed in its workspace (for example, the business contact record of an Authorized User that a Customer invites), Ledger Layer acts as a data processor on the Customer's instructions. Ledger Layer is not engaged to process personal data embedded within Customer financial datasets or workbooks, and Customers agree in the Terms not to submit such data. A signed Data Processing Addendum (“DPA”) incorporating the 2021 EU Standard Contractual Clauses and the UK International Data Transfer Addendum is available on request.

2. Categories of Personal Information We Collect

We collect the following limited categories:

CategoryExamplesSource
Business contactWork email, name, role, company, localeYou, at sign-up or invite acceptance
AuthenticationHashed password, MFA device identifiers, session tokensYou, when you secure your account
BillingPlan, invoice history, Stripe customer ID, billing addressYou, via Stripe checkout
Operational telemetryAudit-trail events, API request logs, IP address, user agent, request timingAutomatically, to run and secure the Service
Support contentTicket subject, message body, attachmentsYou, when you contact support
MarketingNewsletter email, UTM tags, page views, form submissionsYou, via our website

3. Personal Data Outside the Scope of the Service

The Service is engineered for financial, accounting and disclosure metadata. It is not designed to receive, and Customers contractually agree not to submit, any of the following through any file, API call, MCP tool, agent invocation, email, or other channel:

  • Personal data of end-individuals embedded within financial datasets or workbooks, beyond the business contact information necessary to operate an account — including government identifiers, dates of birth, or biometric identifiers.
  • Protected health information, or any data regulated by HIPAA.
  • Payment card data regulated by PCI DSS, full bank account numbers, or account credentials.
  • Special-category data under Article 9 of the GDPR, CCPA sensitive personal information categories, or children's personal data.
  • Classified, export-controlled, or national-security-related information.

Customer responsibility. Customers are solely responsible for ensuring that any data they submit to the Service complies with applicable data-protection laws (including the GDPR, UK GDPR, CCPA/CPRA, PIPEDA and equivalent regimes) and that they have an appropriate lawful basis, notice, and — where required — consent before submitting personal data of any kind. Ledger Layer relies on those representations and is not in a position to inspect the substance of submitted data.

If you inadvertently submit any data described above, notify us at support@ledgerlayer.app and we will arrange deletion. Ledger Layer has no obligation to treat such data as if it were permitted data.

4. How We Use Personal Information

We use the limited information described above to:

  • Operate, secure and improve the Service (provision accounts, authenticate users, audit trail, incident response, rate limiting, abuse prevention).
  • Bill for the Service and meet related tax and financial record-keeping obligations.
  • Provide customer support and respond to your requests.
  • Send operational communications that are essential to the Service (security advisories, release notes, billing notices, incident notifications). These continue for as long as an account is active.
  • Send the Ledger Layer newsletter (product updates, standards briefings), from which you may unsubscribe at any time.
  • Comply with law, exercise or defend legal claims, and enforce the Terms.

Our lawful bases under the GDPR / UK GDPR are, as applicable, performance of a contract, legitimate interests in operating a secure B2B SaaS, legal obligation, and consent for the marketing newsletter.

Operational telemetry specifically. Request logs, IP address, user-agent string, and audit-trail events qualify as personal data under the GDPR. We process them strictly for security, fraud prevention, abuse detection, incident response, rate limiting, and service integrity, and we limit collection to what is necessary and proportionate for those purposes. Telemetry is not used for profiling, advertising, or secondary commercial purposes; access is restricted to personnel with a job-function need; and retention is capped as described in Section 8.

5. AI Models — What We Send and What We Don't

The Service integrates large language model providers (currently OpenAI and Anthropic) for workbook parsing, narrative drafting, and agent-style orchestration. These providers act as sub-processors of Ledger Layer under written agreements that prohibit retention, secondary use, and training on data submitted by Ledger Layer, and that impose confidentiality, security, and deletion obligations aligned with Article 28 of the GDPR. Where commercially available, we use zero-data-retention and no-training enterprise terms with these providers.

The design intent and implementation of the Service is narrow:

  • Architected to pass only: structural metadata (sheet names, column headers, cell types, row counts), schema hints, and parsing prompts.
  • Controls designed to prevent transmission of: financial cell values, lease payment amounts, IBR rates, party names from your data, or other workbook content that could identify an individual or reveal your underlying numbers. While we operate redaction and scope controls at the integration boundary, we do not represent that the system is infallible; edge cases such as structured fragments inside headers or free-text cells may incidentally be transmitted, and our contracts and technical controls are designed to contain the impact if they are.
  • Not used for AI training. Your content is not used by Ledger Layer, OpenAI, or Anthropic to train or fine-tune any model.
  • All accounting calculations themselves — schedules, ROU assets, liabilities, revenue waterfalls, disclosures — are performed by Ledger Layer's deterministic engine, not by any AI model.

6. Sub-Processors

We rely on a small set of vetted sub-processors to deliver the Service:

ProviderRoleRegion
StripePayments, subscription billing, taxUS / EU
OpenAIWorkbook metadata parsing, narrative drafting (no training)US / EU
AnthropicAgent orchestration, narrative drafting (no training)US
Cloud hostingCompute, storage, backups, loggingCustomer-region-aligned where available
Transactional emailSecurity and operational email deliveryUS / EU
Error monitoringApplication-error telemetry (scrubbed of content)US / EU

We maintain a current list of sub-processors and notify Customers of material additions at least thirty (30) days in advance via the operational channel. The DPA incorporates sub-processor flow- down obligations.

7. International Data Transfers

Personal information may be transferred to, and processed in, countries other than the one in which you are resident. Where such transfers are made out of the EEA, UK, or Switzerland, we rely on the 2021 EU Standard Contractual Clauses, the UK International Data Transfer Addendum, and the Swiss FADP adequacy mechanism as applicable, together with supplementary measures where required by Schrems II guidance. The DPA documents these transfer mechanisms in full.

8. Retention

We retain personal information only for as long as necessary for the purposes described in this Policy:

  • Account data — while the account is active and for up to 90 days after termination, after which it is deleted or anonymized.
  • Audit-trail events — retained for seven (7) years from creation to support the finance audit lifecycle, consistent with how finance teams use the Service.
  • Billing records — retained for the period required by applicable tax and commercial-law record-keeping rules (typically seven (7) to ten (10) years).
  • Support tickets — retained for two (2) years.
  • Marketing contacts — retained until you unsubscribe, plus a short suppression-list window to prevent re-mailing.
  • Backups — rolling window of 35 days. Deletion requests are honored on the primary system immediately and propagate to backups on the next backup cycle.

9. Security and Breach Notification

We operate the Service with: TLS 1.2+ in transit; AES-256 at rest; per-tenant logical isolation; role-based access control; hardware-backed MFA for production access; least-privilege service accounts; audit logging of administrative actions; automated vulnerability scanning; and a documented incident-response runbook. No system is infallible — we describe our measures in the DPA and the security addendum.

Breach notification. We will notify affected Customers of a confirmed personal data breach (as defined by Article 4(12) of the GDPR) affecting their data without undue delay after becoming aware of it, and in any event within the timelines required by applicable law — including the 72-hour supervisory-authority notification window under Article 33 of the GDPR / UK GDPR where Ledger Layer acts as controller. Notices are delivered to the primary administrator email on file and include the information required by Article 33(3): nature of the breach, categories and approximate number of data subjects and records concerned, likely consequences, and measures taken or proposed to address it. Where Ledger Layer acts as a processor, we will notify the Customer (controller) on the same without-undue-delay basis so they can meet their own regulatory obligations.

10. Your Rights — GDPR / UK GDPR / Swiss FADP

If you are in the EEA, UK, or Switzerland, you may request to:

  • Access the personal information we hold about you.
  • Rectify inaccurate or incomplete personal information.
  • Erase your personal information, subject to legal retention obligations.
  • Restrict or object to certain processing, including direct marketing.
  • Port data you provided to us in a structured, machine-readable format.
  • Withdraw consent at any time where processing is based on consent.
  • Lodge a complaint with your supervisory authority (for example, the UK ICO, the Irish DPC, or the Swiss FDPIC).

Where Ledger Layer is a processor acting on a Customer's instructions, we will assist that Customer in responding to data-subject requests as required by Article 28 of the GDPR. Direct requests to support@ledgerlayer.app.

11. Your Rights — CCPA / CPRA (California)

California residents have the right to know what personal information we collect and how we use it, to request deletion or correction, to limit the use of sensitive personal information, and to opt out of “sales” and “sharing” as those terms are defined by the CCPA/CPRA. We do not sell personal information, and we do not “share” it for cross-context behavioral advertising. We will not discriminate against you for exercising any CCPA/CPRA right. Send verifiable consumer requests to support@ledgerlayer.app.

12. Cookies and Tracking

On our marketing site and in the Service we use a small number of cookies and similar technologies. We do not deploy third-party advertising cookies, we do not use cross-site trackers, and we honor Global Privacy Control signals as opt-out requests.

CategoryPurposeProviderRetention
Strictly necessarySession, load balancing, CSRF protectionLedger Layer (first-party)Session (browser close) to 24 hours
AuthenticationSigned-in session, MFA state, remember-meLedger Layer (first-party)Up to 30 days, revoked on logout
PreferencesCookie-banner state, locale, UI preferencesLedger Layer (first-party)Up to 12 months
Analytics (first-party)Aggregated page views and conversion attribution; no cross-site profilePrivacy-preserving first-party analytics (cookieless where possible; a short-lived identifier is used only to de-duplicate visits)Up to 30 days at identifier level; aggregates retained up to 25 months
PaymentsFraud and risk scoring during Stripe CheckoutStripe (set on Stripe domain only)Per Stripe's cookie policy

Where local law requires prior consent for non-essential cookies, our cookie banner collects that consent before setting them. You can change your choices at any time from the cookie banner footer link or by clearing cookies in your browser.

13. Children

The Service is a B2B product intended for business use by individuals acting on behalf of an employer or client. It is not directed to children under 16, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us at support@ledgerlayer.app and we will delete it.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be announced by email or in-product notice at least thirty (30) days before they take effect, and the new effective date will appear at the top of this page.

15. Contact

Questions, requests to exercise privacy rights, and reports of suspected security incidents should be directed to support@ledgerlayer.app. For EU/UK representative requests, contact the same address and we will route your request to the appropriate representative.

SummaryLedger Layer is engineered for financial, accounting and disclosure metadata; personal data of end-individuals does not belong inside the financial datasets Customers submit, and Customers agree not to submit it. We do process the limited personal data needed to run a secure B2B SaaS — business contact information and operational telemetry — with a clear lawful basis and strict necessity. We do not sell personal information, we do not use your content to train AI, AI providers act as sub-processors under no-retention / no-training contracts, and the Service is architected to transmit only structural metadata to them. Customers remain responsible for the lawfulness of any data they choose to submit.
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