1. Scope
This policy covers personal data we process when you use freemi.ai, the Freemi Books web app (freemi-books--maagic-40bf7.us-central1.hosted.app and any future production domain), and the related onboarding and billing flows.
2. Data controller
Freemi Ltd (Ireland) is the data controller. Contact us at hello@freemi.ai for any privacy enquiry — including access, rectification, deletion, restriction, portability, objection, or to withdraw consent.
3. Lawful basis
- Contract — to deliver the bookkeeping platform you signed up for.
- Legal obligation — to retain accounting records as required by Irish tax law.
- Consent — for marketing emails and optional cookies (you can withdraw at any time).
- Legitimate interest — for product analytics, fraud detection, and service improvement, balanced against your rights.
4. What we collect
- Account data: name, work email, password hash, workspace name, VAT number.
- Bookkeeping data you provide or import: invoices, bills, customers, suppliers, employees, journals.
- Bank-feed data via TrueLayer: account balances and transactions for the accounts you explicitly authorise. Read-only; we never see your bank password.
- Usage telemetry: pages visited, features used, error reports — pseudonymised.
- Payment data: processed by Stripe; we receive only metadata (last 4, country, status), never your full card number.
5. Open Banking (TrueLayer)
Bank connections use TrueLayer under PSD2. TrueLayer is regulated by the FCA and the Central Bank of Ireland. You consent to the read-only data scope on TrueLayer's page, not on ours — we never see your banking credentials. Access tokens are stored encrypted at rest (AES-256) with a 90-day rotation window. You can revoke access at any time from Settings → Bank connection or directly via your bank.
6. Where data lives
Application servers run on Google Cloud (Firebase App Hosting, us-central1 for the demo — production deployments move to eu-west1 with the same provider). Firestore data is stored in Google Cloud's European multi-region. TrueLayer holds bank tokens on EU/UK infrastructure. We do not transfer your accounting data outside the EU/UK except through Google sub-processors that have signed SCCs.
7. Retention
- Active account data: for as long as your workspace is active.
- Accounting records: 6 years after the end of the relevant accounting period (Section 886 TCA 1997).
- Audit log entries: immutable; chained and retained for the same 6-year window.
- Bank tokens: until you disconnect, the bank revokes, or 90 days inactivity (whichever first).
- Marketing data: deleted within 30 days of unsubscribe.
8. Your rights
Under GDPR you can request access, rectification, erasure, restriction, portability, and to object to processing. Email hello@freemi.ai. We respond within 30 days. You can also complain to the Irish Data Protection Commission at dataprotection.ie.
9. Sub-processors
- Google Cloud / Firebase — hosting, Firestore, Auth, Secret Manager.
- TrueLayer — Open Banking data access.
- Stripe — payment processing.
- OpenRouter — large-language-model inference for the Freemi AI assistant. Prompts are processed but not retained for training.
10. Changes
We'll post material changes here and notify active workspaces by email at least 14 days before they take effect. The "last updated" line below records every revision.