Privacy Policy - The IQ Suite

1. Scope and Summary

This Privacy Policy explains how The IQ Suite, including ReconcileIQ, CodeIQ, LedgerIQ, PrepIQ, IQ Books and related tools ("Service", "we", "our", or "us"), collects, uses, stores and protects personal data and financial data.

We process sensitive financial workflows, so our approach is data minimisation, encryption, auditability and user control. Some tools process files only in your browser or on a process-and-delete basis. Other account-backed workflows, such as IQ Books ledgers, transaction coding, platform posting, VAT and ITSA review, statutory accounts, HMRC or Companies House filing support, subscription billing and audit trails, need server-side database records so you can review, correct, post and evidence the work.

2. Who We Are and Our Data Protection Roles

The IQ Suite is provided by Jack Whitehead, a sole trader trading as IQ Suite, of 24 Wallacre Road, Wallasey, Wirral, CH44 2DY, United Kingdom. That is the data controller for the processing described in this policy where we act as controller. The IQ Suite, ReconcileIQ, reconcileiq.com and bankreconciler.app are names and domains of this one business. Contact us through reconcileiq.com/contact.

Controller: We act as controller for account administration, authentication, billing, product analytics, security logs, support requests and our own service operations.
Processor: When you upload, import, sync or submit client or business records through the Service, you are normally the controller and we process that data on your instructions.
Independent third parties: Accounting platforms, HMRC, payment providers and analytics providers may act as independent controllers or processors under their own terms when you connect or use them.

3. Information We Process

3.1 Account and Subscription Data

Name, email address, password hash, authentication status, login events and account settings.
Company, practice, client-account, organisation ownership, member roles, invitations and team information you add to the Service.
Plan, subscription, credit usage, overage settings, invoices, payment status and Stripe customer or subscription identifiers.
Support messages, feedback, referral records, product preferences and communication settings.

3.2 Financial and Client Data

Bank statements, bank accounts, cashbooks, imported CSVs, book exports, general ledger exports, transaction drafts, journals, opening balances, invoices, quotes, credit notes, receipts, supplier bills, statements, OCR documents, attachments, VAT records, CIS records, ITSA records, chart of accounts, contacts, account codes, transaction categories and reconciliation results.
IQ Books records such as customers, suppliers, products, stock movements and stocktakes, fixed assets and depreciation, projects, recurring templates, bank rules, audit logs, reports, statutory accounts, iXBRL tagging data and year-end close records.
Platform data imported from or posted to services such as Xero, QuickBooks, Sage, Pandle, FreeAgent, YNAB and merchant platforms such as eBay, Amazon, PayPal, Stripe, Etsy and Square.
OAuth tokens, platform account identifiers, sync metadata, posting results and error messages needed to provide integrations.
HMRC-related data, where filing or MTD features are enabled, such as VAT registration numbers, National Insurance numbers, HMRC business IDs, obligations, returns, quarterly updates, final declarations, submission responses, authority tokens and required fraud-prevention/audit metadata.
Companies House-related data, where statutory accounts or filing features are enabled, such as company registration numbers, eligibility inputs, statutory mappings, approval status, iXBRL validation output and filing responses.

3.3 Bank Feed Data via BankSync

Where you connect a bank feed, IQ Suite receives bank account, transaction and balance data through BankSync (banksync.io). BankSync's open banking connections in the UK are provided by Salt Edge, an FCA-registered account information service provider. You hold your own BankSync account and give your consent to the bank there; IQ Suite never sees your online banking credentials and cannot move money or change your bank connections.

What we receive: the bank and account identity (institution, account name, masked account number, currency, type), the ledger balance, and each transaction's date, amount, description, merchant name where the bank supplies one, and provider category.
How it arrives: BankSync delivers new transactions to our signed endpoint and we also read your accounts from BankSync on a schedule. Our access is read-only (BankSync scopes workspaces:read, banks:read and institutions:read).
What we do with it: the lines are staged, checked against transfers and invoices, coded by CodeIQ and projected into your IQ Books ledger as draft bank transactions for your review. Transaction descriptions, amounts and dates from your bank feed are sent to Google Gemini for coding suggestions on the same terms as any other transaction data (see section 6).
Retention: staged feed lines are kept for as long as the organisation they belong to exists, because they are the evidence behind the ledger entries made from them. The raw delivery bodies we receive from BankSync are cleared after 30 days. Ledger entries created from feed lines are bookkeeping records under your control.
Disconnecting and deletion: disconnecting a bank in IQ Books stops us reading it and new data stops arriving. Ending the bank's consent is done in your BankSync account. To have the bank data we already hold deleted after disconnecting, ask us through reconcileiq.com/contact and we delete the staged lines and their delivery records, subject to the retention exceptions in section 9.

3.4 Device, Usage and Security Data

IP address, browser and device information, request timestamps, session identifiers, error logs and security events.
Website analytics from tools such as Google Analytics, Microsoft Clarity and Cloudflare analytics, subject to applicable consent and browser controls.
Local browser data such as authentication tokens, session state, recent reconciliation history, product preferences and cached analysis state.
RiQ chat or voice-command content, transcripts, confirmation-card choices and interaction metadata where you use chat or voice features.

4. How We Use Data

To provide native bookkeeping, organisation management, bank reconciliation, transaction coding, VAT review, invoice matching, merchant statement parsing, ledger analytics, working paper and reporting workflows.
To operate IQ Books features including migrations, contacts, sales and purchase documents, online payment links, bank rules, recurring templates, stock, fixed assets, projects, audit logs, statutory accounts, iXBRL, year-end close, VAT MTD, ITSA and CIS workflows.
To connect to accounting platforms, merchant services, payment services, HMRC and Companies House APIs when you authorise us to do so.
To generate AI-assisted OCR, coding suggestions, review explanations, account suggestions, report commentary and RiQ chat or voice-command previews for your review.
To maintain accounts, subscriptions, credits, overage billing, fraud prevention, support, security, audit trails and service availability.
To improve the Service, debug errors, monitor performance and develop new features.
To comply with legal, tax, accounting, regulatory, fraud-prevention and data protection obligations.

5. Lawful Bases

Depending on context, we rely on one or more of the following lawful bases under UK GDPR or EU GDPR:

Contract: to provide the Service you request and manage your subscription.
Legal obligation: to meet tax, billing, fraud-prevention, accounting and regulatory requirements.
Legitimate interests: to secure, improve, troubleshoot and administer the Service, provided those interests are not overridden by your rights.
Consent: for optional pattern sharing, non-essential marketing communications and cookies or analytics where consent is required.
Processor instructions: where we handle client or business records on your behalf as processor.

6. AI Processing

The only external large-language-model provider we currently use for AI-assisted features is Google Gemini via API. We send only the information needed for the feature being used, such as invoice text or images for OCR, transaction context for coding review, chart-of-accounts context for account suggestions, selected analysis context for RiQ, or chat/voice-command context needed to preview an action.

We use Gemini API as a developer API, not the consumer Gemini chat product.
For paid Gemini API services, Google states that prompts and responses are not used to improve Google products, and processing is covered by Google's applicable data processing terms.
We do not knowingly opt in to sharing customer financial prompts, responses or logs with Google for model training.
Transaction data sent to Gemini may include bank transaction details (date, amount, description, merchant) from statements you upload, platform imports or bank feeds received through BankSync. We do not send account numbers or online banking credentials.
AI output is advisory. Users must review accounting, tax, VAT, posting, filing and RiQ action previews before relying on them.

7. Pattern Learning and Anonymisation

CodeIQ can learn from transaction coding patterns. Personal pattern learning for your own account may be used to improve future suggestions for you. Separate network pattern contribution is optional and controlled by your consent.

Where you opt in, we extract limited merchant-to-account patterns and remove personal identifiers, account numbers, dates, amounts, balances, document contents and client-specific details before any wider use.
Patterns are reviewed and aggregated before they are used to improve suggestions for other users.
You can opt out of pattern contribution at any time. Opting out does not remove access to the Service.

8. Sharing and Subprocessors

We share data only where needed to provide, secure, bill or legally operate the Service. Categories include:

Infrastructure and security: cloud hosting, database, storage, monitoring, logging and Cloudflare security services.
AI processing: Google Gemini API and related Google data processing terms for AI-assisted features.
Payments: Stripe for subscriptions, invoices, billing portal, card handling, online invoice payments, saved payment methods, credit purchases and overage payments. We do not store full card numbers.
Analytics: Google Analytics, Microsoft Clarity and Cloudflare analytics for website and product performance, subject to applicable controls.
Integrations: accounting platforms, merchant platforms, HMRC and Companies House when you connect accounts, import data, post transactions or submit filings.
Bank feeds: BankSync, and through it Salt Edge for UK open banking connections, when you connect a bank feed. BankSync is an independent controller for your BankSync account under its own privacy policy; we receive data from it and do not send your ledger back to it.
Legal and safety: regulators, law enforcement, professional advisers or dispute-resolution bodies where required or appropriate.

9. Retention

Retention depends on the workflow:

Browser-only workflows: data may remain on your device until you clear browser storage or delete in-app history.
Temporary uploads: raw uploaded files used only for conversion or reconciliation are deleted after processing unless the relevant feature explicitly saves them for your session or evidence trail.
Account-backed sessions: transaction rows, ledger entries, review decisions, posting results, invoices, bills, attachments, VAT checks, statutory accounts, tax records, client records and audit trails may be stored while your account or session remains active so you can review, correct, post, export and evidence the work.
Platform tokens: OAuth tokens are retained until you disconnect the integration, the token expires, your account is deleted or retention is otherwise no longer needed.
Bank feed data: staged feed lines stay for the life of the organisation they were imported into (see section 3.3); raw BankSync delivery bodies are cleared after 30 days; BankSync access tokens are revoked and removed when you disconnect.
Billing and compliance records: subscription, invoice, payment, tax and fraud-prevention records may be retained as required for legal, accounting, dispute, tax or security purposes.
Backups and logs: encrypted backups and operational logs are retained for limited operational and security periods, then overwritten or deleted according to our internal retention schedules.

You may request deletion of account data. Some records may need to be retained where required by law, security, billing, audit or dispute obligations.

10. Security

All information handled by the Service is encrypted in transit and at rest, using HTTPS/TLS for transit and encrypted server storage/database disks for at-rest protection.
Sensitive records are protected using access controls and encryption appropriate to the risk.
Passwords are hashed, and platform credentials or tokens are restricted to authorised service use.
We use role-based and need-to-know access controls, server hardening, monitoring, patching, file validation and secure error handling.
Where HMRC APIs are used, the Service is designed to support required fraud-prevention headers, audit data and production-access expectations.
We maintain incident response procedures and will notify affected users and regulators where required by applicable law.

11. International Transfers

We are UK-focused, but some providers may process or access data from the UK, EEA, United States or other locations. Where personal data is transferred internationally, we rely on recognised safeguards such as adequacy regulations, standard contractual clauses, UK addenda, data processing agreements or equivalent lawful transfer mechanisms.

12. Your Rights

Subject to applicable law and our role as controller or processor, you may have rights to:

Access personal data we hold about you.
Correct inaccurate data.
Request deletion or restriction of processing.
Object to processing based on legitimate interests.
Withdraw consent where processing is based on consent.
Request portability of personal data you provided to us.
Lodge a complaint with the UK Information Commissioner's Office or another relevant supervisory authority.

If we process data on behalf of your accountant, practice, employer or client, we may need to direct your request to that controller.

13. Cookies, Local Storage and Analytics

We use cookies, localStorage, sessionStorage and similar browser technologies for login, security, preferences, product state, reconciliation history, analytics and fraud prevention. You can clear local browser data through your browser settings, but doing so may remove saved history or sign you out.

14. Children

The Service is intended for businesses, accountants, bookkeepers and adult users. It is not directed to children or users under 18.

15. Changes to This Policy

We may update this Privacy Policy as the Service, law or our subprocessors change. Material updates will be indicated by the "Last Updated" date and, where appropriate, in-product notice or email.

16. Contact

For privacy questions or rights requests, contact: info@bankreconciler.app