Privacy Notice

Version 1.1 — effective 16 September 2026

Who we are. Circona ERP is operated by CIRCONA TECHNOLOGIES Ltd ("Circona", "we"), a company registered in England and Wales, company number 14299970, registered office 17 King Edwards Road, Ruislip, London HA4 7AE, United Kingdom. Data-protection contact: alex@circona.io.

What this notice covers. This notice explains how we handle personal data when you use Circona ERP (erp.circona.app and api.circona.app) and the Circona Hub (hub.circona.app, the management and analytics application that works with the ERP), including when you connect a bank account, and when you contact us through our websites circona.io and circona.app. It is written for the people who use the service on behalf of a company (a "tenant") and for anyone whose data appears in a tenant's books.

1. Our role

• For your user account (name, e-mail, login, activity log) Circona is the data controller.
• For the business records a tenant keeps in the ERP (invoices, partners, bank transactions, ledger entries) the tenant company is the controller and Circona is its processor: we handle that data only to provide the service and on the tenant's instructions.

2. Bank account connections (Open Banking)

When a tenant connects a bank account, access is obtained through Enable Banking Oy (Otakaari 5, 02150 Espoo, Finland, company ID 2988499-7), a registered Account Information Service Provider supervised by the Finnish Financial Supervisory Authority. Circona acts through Enable Banking's licence; we never see your online-banking credentials.

• What we receive: the accounts you chose to share (account name, IBAN, currency), their balances, and their transactions (dates, amounts, counterparties' names and account identifiers, payment references and descriptions).
• Why: to import bank statement lines into the tenant's own bookkeeping so that receipts and payments can be matched to invoices and posted to the ledger. This is done at the tenant's request and only after an authorised user of the tenant has given explicit consent at the bank.
• Read-only. The connection can only read account information. Circona cannot initiate payments or change anything at your bank.
• Consent period. Access is valid for the period the bank grants (at most 90 or 180 days depending on the bank), after which it stops until it is renewed.
• Revoking. You can end the access at any time under Company → Integrations → Disconnect in the ERP, or by withdrawing the consent at your bank or through Enable Banking. Statement lines already imported stay in the tenant's books, because they are part of its accounting records.

3. Other data we process

• User accounts: name, e-mail, role, company, login times and IP addresses (security log).
• Tenant business records entered or imported by the tenant: partners, products, documents, payments, ledger entries, uploaded documents.
• Support requests you send us.
• Optional AI features (document extraction, drafting): the document or text you submit is sent to the AI provider named in Company → Integrations to produce the result; it is not used to train models.
• Voice features (not yet available): when we offer them, spoken input will be transcribed by a speech-to-text provider (for example Deepgram, or an alternative provider we may choose) named in Company → Integrations, and this notice will be updated to say which one is used before the feature is switched on.

4. Website enquiry and signup forms

When you send an enquiry on circona.io or sign up for a trial on circona.app, the details you enter (name, e-mail, company, phone, website and your message) are delivered to us by Web3Forms, a form-delivery service, and land in our mailbox. Circona is the controller for this data. We use it only to answer you and to set up the access you asked for, and we keep it for as long as needed to follow up your request, after which we delete it unless you become a customer. The websites themselves set no tracking cookies.

5. Where data is stored and who helps us process it

Data is stored on servers in the European Union. We use these processors under written data-processing terms: Railway (application hosting and database), Vercel (web application delivery), Cloudflare (network, website hosting, file storage in EU jurisdiction), Enable Banking Oy (bank account information), Revolut Bank UAB (card payments for the web store, where a tenant uses it), Anthropic or OpenAI (AI features, only when enabled by the tenant), a speech-to-text provider such as Deepgram (voice features, only once offered and enabled by the tenant), Web3Forms (delivery of website form submissions) and Zoho Mail (our e-mail). We do not sell personal data and do not share it with anyone else unless the law requires it.

6. How long we keep it

• Bank transactions, ledger entries and documents: for as long as the tenant keeps its books with us and thereafter for the retention period accounting law imposes on the tenant (seven years in Estonia, six years in the United Kingdom).
• User accounts and security logs: while the account exists and for 12 months after it is closed.
• Bank connection tokens: until the consent expires or is revoked, then deleted immediately.

Closing an account. A tenant can close its account by writing to alex@circona.io, and a user can ask the tenant's administrator to remove their user account. After a tenant account is closed the tenant may export its data for 30 days; we then delete it, except what accounting law requires the tenant to keep for the period above.

7. Your rights

Under the UK GDPR and the EU GDPR you may ask for access to your personal data, correction, deletion, restriction, portability, and you may object to processing based on our legitimate interests. Write to alex@circona.io. For data held in a tenant's books, we will pass your request to that tenant, which decides as controller. You may also complain to the UK Information Commissioner's Office or to the data-protection authority of your own country.

8. Security

Access to the ERP requires a personal login. Data is encrypted in transit; bank access tokens and keys are stored encrypted on the server side and are never exposed to the browser. Every posting to the ledger is recorded in an immutable, hash-chained audit trail.

9. Cookies and e-mail

The ERP uses only the technical storage needed to keep you signed in. It does not use advertising or tracking cookies. We e-mail you only about your account, your support requests and material changes to this notice; we do not send marketing e-mail unless you ask for it.

10. Changes

We will post changes to this notice on this page and, for material changes, notify tenants in the application.