Data Processing Agreement

Between the MVP company Kft., registered seat 2162 Őrbottyán, Táncsics Mihály utca 50., Hungary, company registration number 13-09-223340, trading as AI Finance Team ("Processor", "AIFT") and the customer accounting firm identified in the Order ("Customer"). This agreement is made under Art. 28 GDPR.

Incorporation. This DPA is incorporated into and forms part of the Services agreement (Terms of Service) and becomes legally binding upon the Customer entering into that agreement; no separate signature is required. A countersignable copy is available on request.

1. Roles and the processing chain

1.1 The Customer uses AIFT to process bookkeeping data of the Customer's own clients ("Client Companies").

1.2 Depending on the Customer's arrangement with each Client Company, the Customer acts as controller or as processor. Where the Customer is itself a processor, AIFT acts as sub-processor, and the Customer warrants that its agreement with the relevant controller permits engaging AIFT on these terms.

1.3 AIFT processes personal data only as described in this DPA and Schedule 1, on the Customer's documented instructions (the Services configuration constituting standing instructions), unless required otherwise by EU or Member State law.

1.4 Scope of the processor role. This DPA governs Customer Data: the bookkeeping content processed in the Customer's workspaces (invoices, bank transactions, documents, partner and counterparty data, and personal data contained therein). For account and service data (user account records, the Customer's own billing data, usage metrics, service and audit logs) AIFT acts as an independent controller, as described in AIFT's privacy notice. AIFT uses service data for product analytics only in aggregated or anonymised form, and does not retain Customer Data beyond deletion under §9.

2. Subject matter, duration, nature and purpose

As specified in Schedule 1. Duration: the term of the Services agreement plus the wind-down period in §9.

3. Confidentiality

AIFT ensures that persons authorized to process personal data are bound by confidentiality obligations, contractual or statutory.

AIFT staff hold no standing access to a Customer's workspaces. Support access requires two conditions to hold at the same time: the Customer's organization administrator has opened a support-access window for the organization, and an individual staff session is open inside that window. The Customer opens the window, may close it at any time in a single action, and closing it also ends every session running under it.

Each session lasts at most 24 hours, requires a stated reason before it starts, and is recorded with the acting person's identity, the workspace entered, the role used and that reason. The record survives later changes to the person's profile. This window is a contractual access control between the parties under Art. 28; it is not, and does not substitute for, a data subject's consent.

4. Security (Art. 32)

AIFT implements and maintains the measures in Schedule 3. Measures may evolve; AIFT will not materially reduce the overall level of protection during the term.

5. Sub-processors

5.1 The Customer grants general authorization for the sub-processors listed in Schedule 2, also published on our sub-processor register.

5.2 AIFT gives at least 14 days' notice of intended additions or replacements (published page plus email to the Customer's admin contact). The Customer may object on reasonable data-protection grounds; the parties then discuss the objection in good faith (including possible alternative measures) for up to 10 days. Failing resolution, the Customer may terminate the affected Services with a pro-rata refund of prepaid, unused fees.

5.3 AIFT imposes data-protection obligations on each sub-processor no less protective than this DPA and remains liable for their performance.

5.4 The location of AI document processing is a setting on each workspace, and the EU option (AWS Bedrock, Frankfurt) is the default for new workspaces. Where a workspace is set to the US option, or where a processing step needs a model not yet available in the EU, that inference runs on Anthropic's first-party API (Anthropic PBC, US) under Standard Contractual Clauses. Semantic-search embeddings always run at Voyage AI (US, SCCs, zero data retention). Stored data remains in the EU in every case; the setting affects processing only. See the register (Schedule 2, §5) for the full picture.

6. International transfers

Personal data is stored and primarily processed in the EU (AWS eu-central-1, Frankfurt). Where a sub-processor processes personal data outside the EEA (see Schedule 2), the transfer is safeguarded by Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework. AIFT performs and documents transfer impact assessments for its US sub-processors.

7. Assistance to the Customer

7.1 Data subject rights (Art. 12-23): AIFT provides the means to access, export, correct and delete personal data through the Services; for requests the Customer cannot self-serve, AIFT assists within a reasonable time. AIFT does not respond to data subjects directly and forwards any request it receives to the Customer.

7.2 Art. 32-36: AIFT assists with security, breach notification, DPIAs and prior consultation, taking into account the nature of processing and the information available to AIFT.

8. Personal data breach

AIFT notifies the Customer without undue delay, and no later than 48 hours after becoming aware of a personal data breach affecting the Customer's data, with the information required by Art. 33(3) as it becomes available, and cooperates in the Customer's notification obligations. Notification is not an acknowledgment of fault.

9. Deletion and return

9.1 During the term the Customer can export data in standard formats (XLSX/CSV, accounting-system export formats) at any time.

9.2 Termination or expiry of the Services agreement constitutes the Customer's documented instruction to delete. AIFT deletes the Customer's workspaces, database records and stored document files, within 30 days of termination, using its audited workspace-wipe procedure (double-key guarded, operator-run), unless EU or Member State law requires retention (notably billing records under Hungarian accounting law). Backups expire on the standard backup cycle thereafter. No separate deletion request is required.

9.3 On written request, return via export first, then deletion per 9.2.

10. Special clause: NAV Online Számla technical-user credentials

10.1 Where a Client Company connects NAV Online Számla, the technical-user login, password and XML signing key are provided by the Client Company (or by the Customer where so authorized) and stored encrypted in a dedicated secrets vault in the EU region.

10.2 These credentials are write-only in the application: no interface or API, including for the Customer's staff and AIFT staff, can read them back. They are decrypted solely by the automated synchronization service at the moment of use and are redacted from logs.

10.3 The NAV technical user is read-only and revocable by the Client Company in the NAV portal at any time; disconnecting the integration stops all further collection.

10.4 NAV invoice data retrieved is the Client Company's own taxpayer data, processed exclusively within the bookkeeping purpose of Schedule 1.

11. Audit

AIFT makes available information reasonably necessary to demonstrate compliance (this DPA, the register, the TOMs, and relevant certifications of infrastructure sub-processors such as AWS and Supabase SOC 2 / ISO 27001). Audits and inspections: on 30 days' notice, at most annually unless a supervisory authority requires otherwise or a breach has occurred, during business hours, without access to other customers' data. Liability is governed by §14 of the Terms of Service.

12. AI processing transparency (informational)

12.1 AIFT uses large-language-model services to extract, categorize, match and summarize the Customer's documents and transactions. Providers and locations are in Schedule 2.

12.2 No customer data is used to train models by any AI sub-processor under AIFT's agreements.

12.3 The Customer may connect its own third-party AI assistants (MCP interface). The interface exposes both read and write operations, so a connected assistant can change records as well as read them. Such connections are established by the Customer, governed by the Customer's own agreement with that provider, outside this DPA's sub-processor list, disableable per organization, and every access is logged and visible to the Customer.

Schedule 1: Description of processing

Schedule 2: Authorized sub-processors

Current list, locations and safeguards: see our sub-processor register (the version current at signature applies). Summary: Supabase (database, auth, storage; AWS Frankfurt), Vercel (application hosting; Frankfurt), AWS Bedrock (AI inference; Frankfurt, EU), Anthropic PBC (US, SCCs), Voyage AI (embeddings; US, SCCs, zero retention), GoCardless (open banking; EEA/UK), Sinch/Mailgun (inbound email; EU Frankfurt), Resend (outbound email; EU sending region), Stripe (billing contact data only), Cloudflare (Turnstile bot protection on authentication pages; visitor IP and browser signals only), GitHub (static help-center hosting; visitor IPs only).

Schedule 3: Technical and organisational measures

• Data residency: all databases, file storage and backups in AWS eu-central-1 (Frankfurt); application compute pinned to Frankfurt.
• Encryption: TLS in transit everywhere; encryption at rest on all storage; credentials (NAV, banking-adjacent secrets) additionally encrypted in a dedicated vault, write-only by design.
• Tenant isolation: every customer-data table enforces row-level security in the database itself, checked on every query including AI-assistant and API access. Isolation is not merely application-level.
• Access control: role-based (organization and workspace roles); mutating operations enforce roles server-side, not only in the UI; AIFT staff surfaces gated by a separate staff flag with three-layer checks; destructive operations double-key guarded and audit-logged.
• Bank credentials: never touch AIFT systems (PSD2 redirect flow at the bank; only revocable access tokens held by the licensed provider).
• Document access: private storage buckets only; time-limited signed URLs (60 seconds to 1 hour); no public URLs.
• Logging and audit: administrative operations, AI-assistant access, and match and invoice lifecycle events are logged; AI request logs auto-purge (14/90 days).
• Authentication protection: bot and credential-stuffing protection on authentication surfaces (Cloudflare Turnstile), single-use tokens.
• No tracking: no third-party analytics, no marketing cookies, no tracking pixels in the product or transactional email.
• Backups and recovery: provider-managed backups in-region (Frankfurt); restore procedures per infrastructure provider.
• Deletion: audited per-workspace wipe covering database records and stored files; double-key guard against wrong-target deletion.
• Personnel: confidentiality undertakings; least-privilege access to production; no standing staff access to Customer workspaces, which is bounded as described in §3.
• Secrets: application and infrastructure secrets are held in the encrypted environment stores of the hosting platforms, never in source control or the application database; credentials supplied by a Client Company additionally follow the write-only vault handling in §10.
• Sub-processor flow-down: DPAs with all sub-processors; SCCs or DPF for non-EEA processing; transfer impact assessments on file.