LEDGER GENIE PRIVACY POLICY (v1.3)

Effective Date: February 2026

Ledger Genie (“Ledger Genie” or the “Platform”) is a Software-as-a-Service (SaaS) accounting automation platform developed, operated, hosted, and managed by IBN Technologies (“IBN”, “we”, “us”, or “our”).

This Privacy Policy explains how information is collected, used, disclosed, processed, and protected when customers, authorized users, and service personnel access or use the Ledger Genie platform, applications, websites, and related services (collectively, the “Services”).

This Privacy Policy is aligned with Ledger Genie’s Terms of Service and, where applicable, IBN’s BPO / Managed Services Master Service Agreement (MSA). In the event of any conflict, the Terms of Service and applicable MSA shall prevail.

By accessing or using the Services, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

1. OWNERSHIP, ROLE, AND SCOPE

Ledger Genie is an IBN-owned proprietary platform.
IBN is responsible for the design, development, hosting, maintenance, security, and operation of the Platform.

Ledger Genie provides a technology and workflow enablement platform only. The Services are intended to support accounting automation, quality assurance, and review workflows and do not constitute accounting, tax, legal, or financial advisory services.

The Platform may be used by:

Authorized personnel of the customer, and/or
Authorized employees or contractors of IBN, including BPO, QA, and managed service teams, as part of Human-in-the-Loop (HITL) accounting, bookkeeping, reconciliation, and quality control processes.

All AI-generated outputs are non-final, informational, and subject to human review and approval. Final responsibility for accounting accuracy, compliance, filings, and financial decisions remains with the customer.

2. DATA CONTROLLERSHIP AND PROCESSING ROLE

Customers remain the data owners of their accounting and financial information.

IBN, through the Ledger Genie platform, acts as a data processor and platform operator.

Where IBN provides BPO or managed services, IBN personnel access customer data strictly under client authorization and contractual scope.

IBN does not determine statutory accounting outcomes and does not assume responsibility for client regulatory obligations.

3. INFORMATION WE COLLECT

3.1 Information Provided by Users

IBN collects information voluntarily provided to Ledger Genie, including:

Account registration and contact details
Business and workflow configuration data
User credentials and access roles
Communications with IBN support, operations, or BPO teams

Users represent that they have the legal authority to provide or connect such data.

3.2 Connected Accounting Platforms

When customers connect third-party accounting systems (including QuickBooks Online and similar platforms):

Access is granted via secure authorization mechanisms (e.g., OAuth)
IBN does not store third-party platform passwords
Data access is limited to what is required to deliver the Services
IBN acts solely as a data processor for connected data

Customers may revoke access at any time.

3.3 Automatically Collected Information

IBN may collect limited technical and operational data, including:

IP address and device identifiers
Browser type and operating system
Usage logs, timestamps, workflow actions, and audit events
Approximate geographic location

This information is used for platform security, auditability, analytics, compliance, and service improvement.

4. USE OF INFORMATION

IBN uses collected information to:

Operate, host, maintain, and improve Ledger Genie
Enable AI-assisted automation and HITL workflows
Authenticate users and prevent misuse
Provide customer support and managed services
Process subscriptions and billing
Enforce contractual terms and protect legal interests

IBN may use aggregated or anonymized data for analytics and platform optimization.

4A. LEGAL BASIS FOR PROCESSING

IBN processes personal data under one or more of the following legal bases, as applicable:

Performance of a contract
Compliance with legal obligations
Legitimate business interests (including platform security, fraud prevention, and service improvement)
User consent, where required by law

5. ARTIFICIAL INTELLIGENCE & HUMAN-IN-THE-LOOP MODEL

Ledger Genie employs machine learning technologies developed and operated by IBN.

Key principles:

Each customer operates within a logically isolated AI environment
AI training occurs only on the customer’s own historical usage
Data is not pooled or shared across customers
AI outputs are assistive and non-deterministic

Ledger Genie does not autonomously finalize or post accounting entries. All outputs require explicit human review and approval by authorized client or IBN personnel.

6. DATA RETENTION AND EXPORT

IBN retains data only for as long as reasonably necessary to:

Deliver the Services
Fulfill contractual and legal obligations
Protect IBN’s legal rights

Upon account termination:

Data may be made available for export for a limited period
Data is deleted according to internal retention policies
Residual backups may persist temporarily for security, audit, or compliance purposes

Eligible data may be exported in commonly used formats such as CSV, JSON, or Excel.

7. DATA SHARING AND CROSS-BORDER PROCESSING

IBN may share information with:

Cloud hosting and infrastructure providers
Payment processors
Security, analytics, and monitoring vendors
Legal or regulatory authorities where required

Data may be stored or processed in the United States, United Kingdom, and India to support availability, performance, disaster recovery, and regulatory compliance, subject to reasonable safeguards and industry-standard protections.

IBN does not sell personal data.

7A. SUB-PROCESSORS

IBN may engage third-party sub-processors to support cloud hosting, analytics, payment processing, and security monitoring. Such sub-processors are contractually bound to confidentiality and data protection obligations consistent with this Privacy Policy.

8. USER AND CLIENT RESPONSIBILITIES

Customers are solely responsible for:

Authorizing access for users, including IBN personnel
Configuring rules, workflows, approvals, and automation settings within the Platform
Reviewing and approving AI-generated outputs
Maintaining accurate accounting records
Complying with applicable accounting, tax, and regulatory requirements

IBN and Ledger Genie are not responsible for errors arising from:

Human judgment or approval decisions
Client-configured rules or workflows
Third-party systems or integrations

9. SECURITY

IBN implements reasonable administrative, technical, and organizational safeguards to protect platform data. However, no system can guarantee absolute security. IBN is not responsible for incidents caused by factors beyond its reasonable control.

9A. DATA INCIDENT NOTIFICATION

In the event of a personal data breach that poses a material risk to customers or users, IBN will take reasonable steps to notify affected parties in accordance with applicable law.

10. USER RIGHTS

Depending on jurisdiction, users may have rights to access, correct, or delete personal data. Requests are subject to verification and legal limitations. IBN reserves the right to deny requests that are excessive or not legally required.

11. LIMITATION OF LIABILITY

To the maximum extent permitted by law, IBN and Ledger Genie disclaim liability for indirect, incidental, or consequential damages arising from use of the Platform, including reliance on AI-generated outputs or actions taken by authorized human users.

12. CHILDREN

Ledger Genie is intended for users aged 18 and older. IBN does not knowingly collect personal data from minors.

13. DIRECT MARKETING

IBN may send service-related communications and limited marketing messages regarding Ledger Genie features, updates, and offerings.

Users may opt out of non-essential marketing communications at any time. Operational and transactional communications related to account activity, security, billing, or service delivery may continue regardless of marketing preferences.

14. COOKIES

Ledger Genie uses cookies and similar technologies to enable core platform functionality, security, analytics, and performance monitoring.

Disabling cookies may impact platform availability or functionality. Ledger Genie is not responsible for service degradation resulting from cookie restrictions imposed by users.

15. ONLINE PAYMENT

Payments for Ledger Genie are processed through third-party payment providers. IBN does not store or process full payment card details.

Payment processing is governed by the policies of the respective payment providers. IBN disclaims responsibility for payment-related issues arising from third-party payment platforms.

16. CANCELLATION POLICY

Customers may cancel their Ledger Genie subscription in accordance with the Terms of Service or applicable Master Service Agreement.

Cancellation does not automatically entitle the customer to refunds unless expressly stated in the applicable agreement. IBN reserves the right to retain limited information post-cancellation for legal, audit, security, or dispute-resolution purposes.

17. RIGHT TO REQUEST DELETION

Users may request deletion of personal data, subject to applicable laws and contractual obligations.

IBN may retain certain information where required :

Comply with legal or regulatory requirements
Enforce contractual rights
Resolve disputes
Maintain security and audit logs

Deletion requests may be denied or limited where legally permissible.

18. CHANGES TO THIS POLICY

IBN may update this Privacy Policy at its discretion. Continued use of the Services constitutes acceptance of the revised policy.

19. CONTACT INFORMATION

For privacy-related inquiries, contact: