Data Processing Agreement (DPA)
This Data Processing Agreement (“DPA”) forms part of the Terms of Service between Cristin Griu, trading as ZentraSnap (“ZentraSnap”, “Processor”, “we”, “us” or “our”) and the person or organisation using the ZentraSnap service (“Customer”, “you” or “your”).
This DPA applies where ZentraSnap processes Personal Data on behalf of the Customer in connection with the ZentraSnap service.
This DPA is intended to satisfy the requirements of Article 28 of Regulation (EU) 2016/679 (“GDPR”) and applicable Irish data-protection law, including the Data Protection Act 2018.
Client Portal: accounts, sharing and communications
Account types and access. Professional accounts support accounting, bookkeeping, tax, lending, financial advice and other authorised document work. Professional is an account label, not a certification of identity, qualifications or regulatory status. Professional accounts may use bank-statement, legacy reconciliation and invoice/receipt extraction with available credits without a paid subscription. An active paid Professional subscription is required for Client Portal features and new Professional file storage. Each Professional account can have up to 20 clients, including pending access requests. Cancelled, declined, expired, revoked, blocked or removed connections do not use a client slot. Client accounts are free, have a separate 1 GB (1,000,000,000-byte) total allowance and do not include extraction tools. Pending uploads and items in Trash count towards the allowance.
Access requests. A paid Professional can request access to an existing Client account using its email address. ZentraSnap does not provide a public client directory. The client is shown the requesting professional’s name, contact email and practice name where available. Access requires acceptance while signed in to the intended Client account; receiving or opening an email alone grants no access. Requests expire after seven days and may be cancelled or declined. Clients can block further requests and later unblock the professional. Unblocking does not itself restore access.
What approval shares. Approval covers all existing and future files in the client workspace, rather than only an individual folder. Multiple named professionals may be approved separately. Approved professionals with active paid access can browse folders, search, preview, download files and folder ZIPs, and extract supported documents. They cannot upload into, rename, move or delete the client’s originals. They can see available client profile information: name, email address, profile picture, selected country, contact phone number and last sign-in date. Profile information is supplied by the account or authentication provider and may be incomplete. Clients should approve only intended recipients; professionals must use shared information only for authorised purposes and protect copies they obtain.
Working copies and revocation. Extracting a client document uses the professional’s credits. Working copies and results are held in the professional’s workspace under its storage and retention rules and are not automatically shared back with the client. Clients can revoke access; this blocks subsequent authorised retrieval through ZentraSnap. Subscription expiry also suspends the professional’s shared-client access and ability to send new requests. Neither action can recall information already loaded in a browser, downloaded, emailed or copied into a professional’s workspace. Removing a client from a professional’s list ends that connection and clears that professional’s notes; it does not delete the client’s account or originals. These service-access rules do not transfer ownership of documents or determine either party’s data-protection role.
Professional notes. Professionals can save up to 500 characters of notes in a client profile. Notes are stored in the service and are not shown to the client or other professionals through the ordinary interface. They may contain personal data and remain subject to applicable access, correction and deletion rights. The professional should include only information necessary for the authorised work. Revoking access does not itself erase the notes; removing the client from that professional’s list or deleting either participating account clears those notes from active records. Applicable recovery-history rules still apply.
Email requests. An approved paid Professional can send a general or document request from the client profile, with a required title and message and an optional due date. The subject identifies the professional by name or email and includes the request title; the message and any due date are included in the email body. Replies are directed to the professional’s contact email and are handled by the parties’ email providers, not stored as new conversations in ZentraSnap. The form does not attach original documents. A queued request is not proof of delivery or that the client has read it. The sender is responsible for the recipient, message contents and lawful use of the email facility. Service emails must not be used for unsolicited marketing or harassment.
Notifications and delivery providers. Access requests and other supported account events may generate in-app notices and service emails. Opening the notification panel marks the listed notices as read; this does not establish that the underlying request has been completed. Resend (Plus Five Five, Inc.) delivers these emails and processes sender and recipient addresses, sender identity, subject, message body, optional due date, invitation or service links and delivery information as needed. Personal or financial information entered into a request is included in the email sent to Resend and the recipient’s mail provider. See Resend’s data-processing terms. EU document storage does not mean that authentication or email processing takes place exclusively in the EU.
Portal records and retention. ZentraSnap processes account type, country, contact details, email-verification status, access requests and decisions, notes, request-delivery records, notifications and limited security events. In-app notifications are scheduled for deletion after 90 days, email-queue and delivery records after 30 days, and portal audit events after one year. Cleanup is asynchronous. Queued email contents are encrypted server-side and cleared following successful delivery or cancellation of the queued request; an undelivered payload can remain until queue cleanup. Invitation tokens are stored as hashes. Access-relationship and blocking records remain as needed to operate the relationship and honour access decisions, subject to account deletion and valid deletion requests.
Deletion and retained copies. Account deletion revokes relationships, clears the deleted account’s profile and relevant notes from active portal records, and initiates file cleanup. Historical in-app communications, if present from earlier versions, remain subject to their existing access and deletion rules; account deletion removes the deleted user’s authored reply text and attachment references. Other participants may retain their own records. Emails already delivered and downloaded or independently retained working copies cannot be recalled through account deletion. The separate retention rules for Files, Recent extractions, infrastructure recovery history, legal records and email providers continue to apply.
Data-protection responsibilities. Account types do not determine the parties’ legal roles. ZentraSnap acts as controller for account administration, security and service-operation information as described in the Privacy Policy. Providing the requested account and sharing functions relies on performance of the relevant service contract where applicable; proportionate security and abuse prevention rely on legitimate interests, and mandatory records on legal obligations. Where ZentraSnap processes documents, professional notes or request contents on a customer’s behalf, the DPA applies. A client’s approval is an access instruction, not a substitute for the lawful basis, authority or privacy notices needed for the parties’ processing. Professionals remain responsible for their subsequent use of shared information.
Documented instructions. Authorised uploads, sharing approvals and revocations, extraction commands, notes, email-request submissions and deletion commands form part of the customer’s documented instructions within the Service. The customer must have authority for those instructions, including required instructions from a controller where the customer is a processor. This processing is included in Annexes 1 and 2 and the authorised-subprocessor information in Annex 3. Disclosure is limited to the authorised participants and providers needed to carry out those instructions, subject to applicable law.
1. Definitions
1.1 Client Data
“Client Data” means Personal Data contained in, derived from or otherwise associated with documents or files submitted to ZentraSnap by or on behalf of the Customer, including bank statements, invoices, receipts, spreadsheets, text files, images, extracted document data and associated identifying metadata such as file names, folder names and folder structure. It also includes Personal Data in professional notes, request titles and messages, due dates, recipient information and sharing metadata processed on the Customer’s behalf.
Client Data may include names, addresses, financial account information, transaction information, invoice information, contact details and other Personal Data contained in submitted documents.
1.2 Customer
Depending on the circumstances, the Customer may act as either:
- a Controller of Client Data; or
- a Processor acting on behalf of another Controller.
Where the Customer acts as a Processor, ZentraSnap acts as a Subprocessor. References in this DPA to the Customer's instructions or responsibilities apply accordingly. Professional and Client are product account types and do not determine whether a person is a controller, processor or data subject. This DPA applies only to processing for which ZentraSnap acts as processor or subprocessor; independent controller processing is described in the Privacy Policy.
1.3 Subprocessor
“Subprocessor” means a third party engaged by ZentraSnap to process Client Data on behalf of the Customer in connection with providing the Service.
1.4 Applicable Data Protection Law
“Applicable Data Protection Law” includes the GDPR, the Irish Data Protection Act 2018 and any other applicable laws governing the processing of Personal Data under this DPA.
The terms Controller, Processor, Data Subject, Personal Data, Personal Data Breach, Processing and Supervisory Authority have the meanings given to them under the GDPR.
2. Roles of the Parties
2.1 Customer: The Customer is the Controller of Client Data or, where applicable, a Processor acting on behalf of another Controller. The Customer determines the purpose for which Client Data is submitted to ZentraSnap and is responsible for establishing an appropriate lawful basis for that processing.
2.2 ZentraSnap: ZentraSnap acts as a Processor or Subprocessor in relation to Client Data. ZentraSnap processes Client Data only to provide the document-extraction, file-storage, authorised client-sharing, notes and request-email functionality instructed by the Customer, in accordance with:
- this DPA;
- the Terms of Service;
- the Customer's use and configuration of the Service; and
- any other lawful documented instructions agreed between the parties.
2.3 Account and Service Usage Data: This DPA does not govern Personal Data for which ZentraSnap independently acts as Controller, such as ZentraSnap account information, authentication data, support information, subscription information, business-administration records and service-usage or credit-accounting records. Such processing is governed by the ZentraSnap Privacy Policy.
Service-usage and credit-accounting records may include user identifiers, subscription and billing-cycle information, credit balances, credits used, document and page counts, OCR page counts, invoice and receipt counts, extracted transaction counts, usage-event identifiers, processing status and timestamps.
ZentraSnap's usage-accounting database is not intended to store document contents such as transaction descriptions, transaction amounts, account balances, bank-account numbers, invoice contents or receipt contents. The separate files database stores file-management metadata, including identifying names and folder relationships, which remains Client Data where it concerns personal data processed on the Customer’s behalf.
3. Subject Matter, Nature and Purpose of Processing
3.1 Subject Matter
ZentraSnap processes Client Data in order to provide automated financial-document extraction, private document storage, folder management, previews, retrieval, retention of extraction results, authorised client sharing, professional notes and request-email delivery.
3.2 Bank Statements
When the Customer submits a bank statement for extraction, a processing copy is temporarily uploaded to private object storage provided through Cloudflare R2. Supported image files may first be converted into PDF format locally within the user's browser. The document is then processed using cloud computing infrastructure supplied by Modal Labs.
Processing may include:
- downloading the temporary document;
- reading native PDF text;
- rendering pages where required;
- optical character recognition (“OCR”), including through Microsoft Azure AI Document Intelligence where OCR is required;
- applying ZentraSnap's document-extraction machine-learning models;
- identifying transaction dates, descriptions, debit values, credit values and balances;
- generating document-coordinate information for review and highlighting;
- temporarily storing extraction status and structured results; and
- returning the extracted information to the Customer.
The bank-statement processing copy is normally deleted from temporary Cloudflare R2 storage after the processing job completes or fails. Copies retained in Files or Recent extractions follow section 12 instead. As an additional safeguard, temporary bank-statement files, extraction results, processing status information and related temporary objects in Cloudflare R2 are subject to an automated lifecycle policy configured to expire them after one day.
Cloudflare's current DPA applies to customers using its services and expressly addresses processor/subprocessor obligations and international transfers.
3.3 Invoices and Receipts
Invoices and receipts submitted through ZentraSnap's invoice and receipt extraction functionality are transmitted to the paid Google Gemini API for automated analysis.
Processing may include identifying and extracting:
- supplier or vendor information;
- customer information;
- invoice numbers;
- document dates;
- monetary totals;
- VAT or other tax information;
- line items; and
- other structured information present in the document.
For paid Gemini services, Google's current terms provide that prompts, files and responses are not used to improve Google's products and are processed pursuant to Google's applicable Data Processing Addendum. Google may nevertheless retain limited information in accordance with its applicable security, abuse-prevention, logging, legal and regulatory requirements.
3.4 Vercel Application Infrastructure
ZentraSnap uses Vercel to host its web application and server-side API infrastructure. Certain Client Data, including extraction results, file-management metadata, preview content and downloaded documents, may transit through ZentraSnap's authenticated server-side application routes hosted on Vercel.
3.5 No Sale of Client Data
ZentraSnap does not sell Client Data.
3.6 Machine-Learning Training
ZentraSnap will not use Client Data submitted through the production Service to train or fine-tune ZentraSnap's own machine-learning models unless the Customer has separately and expressly agreed to such use.
ZentraSnap will not intentionally enable optional Subprocessor functionality that permits Client Data to be contributed for general AI model training without the Customer's separate authorisation.
Modal's current contractual terms similarly state that Modal will not train AI models using Customer Data without prior written consent.
3.7 Files and Recent extractions
At the Customer’s instruction, ZentraSnap receives and stores supported documents in private Cloudflare R2 storage and records ownership and file-management metadata in a separate Cloudflare D1 database. Cloudflare Workers handle storage operations, authorised uploads and downloads, and scheduled cleanup. Functions include creating nested folders, renaming, moving, pinning, previewing, downloading, deleting and restoring items.
Paid accounts may retain completed extraction results and original documents in Recent extractions, subject to successful saving, the applicable allowance and the retention schedule in section 12. Results can be reopened for review and saved to Files. Uploading to Files or previewing a stored file does not itself initiate AI extraction or send the file to an extraction provider. Supported spreadsheet and text previews are processed in the browser.
4. Documented Instructions
4.1 ZentraSnap shall process Client Data only on documented instructions from the Customer unless processing is required by European Union or Irish law. The Customer's use of ZentraSnap to upload or retain documents, initiate extraction, save or edit results, organise or pin folders, preview or download items, restore or delete information, or configure Service functionality constitutes documented instructions for the purposes of this DPA.
4.2 If ZentraSnap is required by law to process Client Data other than on the Customer's instructions, ZentraSnap will inform the Customer before such processing unless legally prohibited from doing so.
4.3 If ZentraSnap reasonably believes that an instruction from the Customer infringes Applicable Data Protection Law, ZentraSnap shall inform the Customer without undue delay and may suspend the affected processing until the matter is resolved.
This reflects the processor obligations required by Article 28 GDPR.
5. Obligations of the Customer
The Customer shall:
5.1 Lawfulness: Ensure that its collection, use and submission of Client Data complies with Applicable Data Protection Law and that it has an appropriate lawful basis and authority to instruct ZentraSnap to process the data.
5.2 Transparency: Provide Data Subjects with any privacy information or notices required under applicable law.
5.3 Data Minimisation: Submit only Client Data reasonably necessary for the intended extraction, storage, sharing, notes or client-communication purpose.
5.4 Customer Instructions: Ensure that its instructions to ZentraSnap comply with Applicable Data Protection Law.
5.5 Security: Take appropriate measures to secure its own accounts, devices, networks, browsers, credentials and downloaded files or extraction results.
6. Obligations of ZentraSnap
ZentraSnap shall ensure that any person authorised to process Client Data is subject to an appropriate obligation of confidentiality. Access to Client Data by ZentraSnap personnel shall be limited to circumstances reasonably necessary for security, support, troubleshooting, legal compliance or operation of the Service.
Taking into account the state of the art, implementation costs and the nature, scope, context and purposes of processing, ZentraSnap shall maintain technical and organisational measures appropriate to the risk of processing. Current measures are described in Annex 2.
ZentraSnap shall seek to process and retain only the Client Data reasonably necessary to provide and secure the Service.
ZentraSnap shall restrict production infrastructure credentials and administrative access to authorised persons.
7. Subprocessors
7.1 General Authorisation: The Customer provides general written authorisation for ZentraSnap to engage the Subprocessors listed in Annex 3.
GDPR Article 28 permits general written authorisation provided that customers are informed of intended additions or replacements and have an opportunity to object.
7.2 Subprocessor Obligations: Where ZentraSnap engages a Subprocessor to process Client Data, ZentraSnap shall ensure through an appropriate written agreement that the Subprocessor is subject to data-protection obligations appropriate to the processing and consistent with applicable Article 28 requirements.
ZentraSnap remains responsible to the Customer for the performance of its Subprocessors' data-protection obligations to the extent required by Applicable Data Protection Law.
7.3 Changes: ZentraSnap shall provide reasonable advance notice of an intended addition or replacement of a Subprocessor that will materially process Client Data. Notice may be provided by email, in-app notification, publication through ZentraSnap's website or another reasonable mechanism.
Where reasonably practicable, ZentraSnap will provide at least 15 days' notice before a new Subprocessor begins processing Client Data. Where an urgent replacement is reasonably necessary for security, service continuity or legal compliance, ZentraSnap may provide notice as soon as reasonably practicable.
7.4 Objections: The Customer may object to a new Subprocessor on reasonable data-protection grounds. The parties shall attempt in good faith to resolve the objection. If no reasonable alternative is available, the Customer may discontinue the affected Service or terminate its use of ZentraSnap before the Subprocessor begins the relevant processing, subject to the applicable Terms of Service.
8. International Data Transfers
Files and Recent extractions use private Cloudflare R2 buckets configured for the European Union jurisdiction and a separate EU-jurisdiction Cloudflare D1 database for file metadata. These storage settings do not mean that every application operation, support activity or extraction provider is confined to the EU. Processing copies and other providers follow their own applicable locations and transfer safeguards.
ZentraSnap and its Subprocessors may process Client Data outside Ireland or the European Economic Area. Where Client Data is transferred to a country that does not benefit from an applicable European Commission adequacy decision, ZentraSnap shall ensure that an appropriate transfer mechanism is used where required by law.
Such mechanisms may include:
- the European Commission Standard Contractual Clauses;
- the EU-U.S. Data Privacy Framework where applicable;
- another safeguard permitted under Article 46 GDPR; or
- another lawful transfer mechanism available under the GDPR.
Modal's current DPA expressly provides for the use of Standard Contractual Clauses and other GDPR-compliant transfer mechanisms. Google Cloud's current DPA similarly addresses SCCs and processor-to-processor transfers.
9. Data Subject Rights
9.1 Customer Responsibility: The Customer remains responsible for responding to requests from Data Subjects exercising rights under applicable data-protection law.
9.2 ZentraSnap Assistance: Taking into account the nature of the processing, ZentraSnap shall provide reasonable assistance to the Customer, including through appropriate technical and organisational measures, to enable the Customer to respond to Data Subject requests concerning:
- access;
- rectification;
- erasure;
- restriction;
- data portability;
- objection; and
- other applicable rights.
The Irish Data Protection Commission specifically identifies this assistance obligation as a mandatory Article 28 requirement.
9.3 Requests Received by ZentraSnap: If ZentraSnap directly receives a request from a Data Subject relating to Client Data processed on behalf of a Customer, ZentraSnap shall not independently respond to the substantive request unless authorised or legally required to do so. Where reasonably possible, ZentraSnap shall notify the relevant Customer or direct the Data Subject to the relevant Controller.
9.4 Stored and Temporary Data: Assistance covers retained documents, extraction results, associated identifying metadata, professional notes and request contents to the extent still held. Notes being private in the ordinary interface does not exempt them from applicable data-subject rights. Customers can retrieve files and folder ZIP archives and use deletion controls, or request assistance with return, correction, restriction or deletion. Temporary processing copies or expired extractions may already have been deleted when a request arrives; ZentraSnap cannot return copies it no longer holds. Requests for Client Data will be handled on the Customer’s instructions and in accordance with applicable law.
10. Personal Data Breaches
10.1 Notification: ZentraSnap shall notify the Customer without undue delay after becoming aware of a Personal Data Breach affecting Client Data processed on the Customer's behalf.
10.2 Information: To the extent reasonably available, ZentraSnap shall provide information concerning:
- the nature of the Personal Data Breach;
- the categories of affected Client Data and Data Subjects;
- the likely consequences;
- measures taken or proposed to address the breach; and
- information reasonably required for the Customer to meet its obligations under Articles 33 and 34 GDPR.
Information may be supplied in phases where all details are not immediately available.
10.3 Cooperation: ZentraSnap shall take reasonable steps to investigate, mitigate and remediate Personal Data Breaches affecting Client Data within ZentraSnap's processing environment.
10.4 Customer Systems: ZentraSnap is not responsible for security breaches caused solely by the compromise of systems, devices, credentials or networks controlled by the Customer, although ZentraSnap will provide reasonable assistance where the event also affects Client Data processed through the Service.
11. Security, DPIAs and Regulatory Assistance
Taking into account the nature of the processing and information reasonably available to ZentraSnap, ZentraSnap shall provide reasonable assistance to the Customer concerning its compliance with:
- Article 32 GDPR — security of processing;
- Articles 33 and 34 — Personal Data Breach notification;
- Article 35 — Data Protection Impact Assessments; and
- Article 36 — prior consultation with Supervisory Authorities.
This assistance is expressly part of the processor duties identified by the Irish Data Protection Commission.
12. Return and Deletion of Client Data
12.1 During Normal Processing: For bank statements, the processing copy is normally deleted from ZentraSnap's temporary Cloudflare R2 storage after the extraction completes or fails. This does not delete copies retained in Files or Recent extractions. Temporary source documents, extraction-result files, job-status records and related temporary R2 objects are additionally subject to an automated Cloudflare R2 lifecycle policy configured to expire them after one day.
12.2 Results: Extracted results are returned to the Customer through the ZentraSnap application. The Customer is responsible for downloading results or, where available under its paid plan, saving them to Files before the temporary access window expires.
12.3 End of Processing: Upon termination of the processing relationship, or upon a valid instruction from the Customer, ZentraSnap shall, at the Customer’s choice, return or delete Client Data under its control and delete remaining copies, unless retention is required by applicable law. The Customer may arrange export and deletion using the Service or by contacting ZentraSnap. Subscription expiry alone is not an instruction to immediately delete stored files; the DPA continues to govern any retained Client Data. Where data is stored only temporarily and has already been deleted in accordance with the Service's retention architecture, ZentraSnap will have no remaining copy to return.
12.4 Subprocessor Retention: Subprocessors may maintain temporary copies, security records, logs or backups for periods permitted under their applicable agreements and retention policies. ZentraSnap shall require its Subprocessors to delete Client Data in accordance with applicable contractual and legal obligations.
12.5 Files and Recent extractions retention schedule
| Data | Retention |
|---|---|
| Files | Saved documents, folder information and saved extraction data remain available until deleted by the customer, account deletion, or return/deletion at the end of the processing relationship. Subscription expiry alone does not currently start an automatic deletion countdown. |
| Recent extractions | For paid accounts, completed extractions can be retained with their original documents and extracted data within a separate 250 MB allowance. Access expires 48 hours after the temporary entry is created. Editing or reopening it does not extend that period. Saving it to Files before expiry moves it under the saved-file retention rules. |
| Trash | Deleted saved files and folders move to Trash for up to 30 days. They can be restored during that period by a Client account or an account with paid Professional storage access, or permanently deleted earlier. A folder deletion includes its contents. Items in Trash continue to count towards the storage allowance until removed. |
| Deleted recent extractions | Temporary extractions bypass Trash. Deleting one removes access and requests removal of its retained originals and results. |
| Account deletion | Account deletion revokes access and triggers deletion of saved files, retained extractions and associated file metadata. Export anything you need before deleting the account. A minimal revoked-account identifier may remain to prevent stale requests from restoring access. |
| Client accounts | Clients have a free 1 GB (1,000,000,000-byte) allowance for saved files, including pending uploads and items in Trash. Client originals follow the saved-file and Trash rules. Client accounts have no retained extraction history. |
| Free Professional accounts | Free Professional accounts can extract documents using available credits without a paid subscription, but have no allowance for new saved files or retained extraction history. Results can be exported from the current browser session. Temporary copies needed to process documents and deliver results, and processing-provider retention, still apply. Former subscribers may retrieve or delete existing saved items as explained below. |
When paid access ends. For Professionals, new uploads and changes to stored data require paid storage access. Clients retain their separate free allowance; an expired professional subscription suspends that professional’s access to client data. An account without a current paid entitlement can still download or delete its existing saved items, subject to account security restrictions. Contact cristingriu25@gmail.com to arrange return or deletion of remaining data when ending the processing relationship. Subscription cancellation is separate from account deletion.
Deletion timing. Expiry and deletion first remove access through the service. Scheduled cleanup then removes the underlying objects and associated file metadata. Physical removal is asynchronous and can take longer during retries or service disruption. Temporary storage lifecycle rules provide an additional cleanup safeguard. Abandoned uploads and superseded extraction-result copies are also scheduled for cleanup; saved extraction revisions are not a customer-accessible version archive.
Recovery history. Deleted file metadata may remain in Cloudflare D1 recovery history until it ages out of the applicable recovery window, currently up to 30 days. This is separate from document contents in R2 and does not provide a customer file-recovery guarantee. Recovery history is restricted to authorised recovery operations, not ordinary account access. If used for recovery, applicable deletion instructions must be reapplied before restored data is made available. See Cloudflare’s recovery documentation.
These rules apply to Files and Recent extractions. Extraction-processing copies, provider security logs and account, billing and legal records have the separate retention rules described in the Privacy Policy and DPA. Retention required by law is limited to the relevant data and purpose.
13. Audits and Demonstration of Compliance
13.1 Information: ZentraSnap shall make available to the Customer information reasonably necessary to demonstrate compliance with Article 28 GDPR.
13.2 Audit Evidence: Where reasonably sufficient, compliance may initially be demonstrated through:
- this DPA;
- technical documentation;
- security documentation;
- Subprocessor DPAs;
- independent certifications or audit reports made available by applicable providers; and
- responses to reasonable security or data-protection questionnaires.
13.3 Audits: Where the information described above is insufficient to demonstrate compliance, or where an audit is required by Applicable Data Protection Law or a competent Supervisory Authority, ZentraSnap shall allow for and reasonably contribute to an audit relating to the processing covered by this DPA. Audits shall, where practicable:
- take place on reasonable prior written notice;
- occur during normal business hours;
- avoid unreasonable disruption to the Service;
- respect confidentiality and the security of other customers; and
- be limited to systems and processing relevant to the Customer's Client Data.
Nothing in this section restricts audit rights that cannot lawfully be limited under the GDPR.
14. Records and Regulatory Cooperation
ZentraSnap shall maintain information concerning its processing activities where required under applicable data-protection law.
ZentraSnap shall reasonably cooperate with the Customer and competent Supervisory Authorities concerning processing covered by this DPA where required by law.
15. Liability
Liability arising from this DPA is subject to the limitation-of-liability provisions in the ZentraSnap Terms of Service except to the extent that such liability cannot lawfully be excluded or limited under the GDPR or other applicable law.
Nothing in this DPA limits the statutory powers of a Supervisory Authority or rights that cannot legally be restricted by contract.
16. Duration and Termination
This DPA becomes effective when the Customer becomes bound by the ZentraSnap Terms of Service and remains effective for as long as ZentraSnap processes Client Data on the Customer's behalf.
Provisions that by their nature are intended to survive termination, including confidentiality, deletion, audit, liability and international-transfer obligations, shall survive for as long as necessary to fulfil their purpose.
17. Order of Precedence
If there is a conflict concerning the processing of Client Data between:
- this DPA; and
- the ZentraSnap Terms of Service,
this DPA shall prevail to the extent of that conflict.
Where Standard Contractual Clauses apply to an international transfer and conflict with this DPA, the Standard Contractual Clauses shall prevail to the extent required by law.
DETAILS OF PROCESSING
A. Subject Matter
Provision of ZentraSnap's financial-document extraction, private file storage and authorised Client Portal service, including sharing, professional notes and request-email delivery.
B. Nature and Purpose
The processing may include:
- receipt, storage and retrieval of documents and saved extraction data;
- PDF and image processing;
- OCR using Microsoft Azure AI Document Intelligence where required;
- recognition of text, words, confidence information and document coordinates;
- machine-learning inference;
- AI-based document extraction;
- parsing and classification of financial information;
- creation of structured transaction or invoice data;
- temporary processing-status storage;
- folder organisation, pinning, previews and downloads by authenticated users;
- client access approvals, revocations and permission enforcement;
- storage and updating of professional notes and preparation, queueing and delivery of client-request emails;
- security and abuse prevention; and
- retention, restoration and deletion of stored and temporary data.
C. Duration
Processing continues for the duration necessary to provide the requested extraction and storage functionality. Files, Recent extractions, Trash, account deletion and recovery metadata follow the retention schedule in section 12.5. The DPA continues to apply while Client Data remains under ZentraSnap’s control.
For bank-statement processing copies, the one-day temporary-storage lifecycle rule remains an additional cleanup safeguard. It does not apply to saved Files or replace the Recent extractions access window.
Certain Subprocessors may maintain limited temporary logs, security information, backups or function-processing data according to their applicable contracts and retention policies.
Where Azure Document Intelligence is used, Microsoft may temporarily retain submitted OCR input and analysis results for up to 24 hours in accordance with its service retention policy.
D. Categories of Data Subjects
Client Data may relate to:
- • the Customer's clients/customers
- • account holders
- • employees
- • directors
- • business owners
- • sole traders
- • suppliers and vendors
- • customers of clients
- • payees and payers
- • representatives/contact persons
- • other persons identified within uploaded documents or file metadata
E. Categories of Personal Data
Client Data may include:
- • names
- • business names
- • physical addresses
- • email addresses
- • telephone numbers
- • account numbers
- • IBANs
- • sort codes
- • bank identifiers
- • transaction dates
- • transaction descriptions
- • debit/credit amounts
- • account balances
- • supplier/customer info
- • invoice numbers
- • receipt information
- • VAT or tax identifiers
- • VAT/tax amounts
- • invoice line items
- • payment information
- • file/folder names, structure and document metadata
- • OCR-derived text
- • document-coordinate info
- • professional notes and request contents
- • request titles, due dates and recipient details
- • sharing decisions and relationship identifiers
• other Personal Data contained within submitted documents.
F. Special Categories of Personal Data
ZentraSnap is not specifically designed to collect Special Category Personal Data. However, financial documents may incidentally contain information from which sensitive characteristics could potentially be inferred, for example through transaction descriptions.
The Customer is responsible for avoiding the submission of unnecessary Special Category Personal Data and ensuring that any such processing is lawful. ZentraSnap shall process such information only insofar as it is contained in documents or associated metadata submitted for the requested extraction or storage task.
TECHNICAL AND ORGANISATIONAL MEASURES
ZentraSnap currently employs measures including:
Production infrastructure and administrative systems are restricted to authorised persons. Infrastructure credentials, API credentials, storage credentials and service secrets are maintained server-side and are not intentionally exposed to end users.
Access to protected ZentraSnap functionality is restricted using authenticated user sessions. Clients can manage their own files within their free allowance; Professionals require paid access for new storage. Server-side ownership and active relationship checks control shared reads. Client originals can be changed only by their owner, including checks on source and destination folders for moves. Former subscribers retain retrieval and deletion access as described in section 12.5.
Web application and API communications use HTTPS/TLS.
ZentraSnap uses infrastructure providers that support encryption of stored data. Cloudflare states that R2 objects are automatically encrypted at rest. Modal states that its platform uses encryption for customer data in transit and at rest.
Saved files, Recent extractions and bank-statement processing copies use private Cloudflare R2 storage. File metadata is kept in a separate EU-jurisdiction D1 database. Buckets are not public document repositories. Infrastructure credentials remain server-side; temporary upload and download authorisations are scoped and time-limited.
Stored files and temporary extractions have separate access-expiry and scheduled-deletion rules. Deletion requests cover folder descendants. Account deletion revokes file access and requests cleanup. Recovery metadata follows section 12.5; the bank-statement processing bucket retains its separate one-day lifecycle safeguard.
ZentraSnap seeks to minimise the amount and duration of Client Data stored for processing.
ZentraSnap selects service providers that provide contractual data-protection and security commitments appropriate to their role.
ZentraSnap uses server-side ownership and permission checks for protected operations. Shared-client access requires an active approved relationship and paid Professional entitlement; these checks cover browsing, previews, downloads, folder archives and extraction-source retrieval. Credentials remain outside client-side application code. Email-queue contents are encrypted server-side and invitation tokens are stored as hashes. Revocation prevents subsequent authorised service access but cannot recall previously obtained copies.
Reasonable security, rate-limiting and operational monitoring measures may be used to detect abuse and protect the availability and integrity of the Service.
AUTHORISED SUBPROCESSORS
| Subprocessor | Purpose | Client Data potentially processed |
|---|---|---|
| Cloudflare, Inc. / applicable Cloudflare entity | Private R2 storage for saved files, retained extractions and bank-statement processing; D1 file and Client Portal records; Workers storage, sharing, email queue and cleanup operations | Uploaded documents and images, saved and temporary extracted data, file/folder names, ownership, folder relationships, sizes, timestamps, professional notes, request contents in encrypted queues, access decisions, notification and audit records, and processing metadata |
| Modal Labs, Inc. | Cloud computing and GPU infrastructure for bank-statement extraction, machine-learning inference and OCR | Bank-statement content, rendered document data, OCR text and extracted transaction data |
| Google / applicable Google contracting entity | Paid Gemini API processing for invoices and receipts | Invoice/receipt documents, images, prompts and extracted structured information |
| Microsoft Corporation / applicable Microsoft Azure contracting entity | Azure AI Document Intelligence OCR for scanned, image-based or unsuccessful bank-statement extraction | Bank-statement pages/images, OCR-recognised text, document coordinates, confidence information and analysis results |
| Vercel, Inc. | Hosting and server-side application/API infrastructure | Client Data that transits authenticated server routes, including extraction requests/results, file-management and shared-client metadata, profile information, professional notes, email-request contents, previews and file downloads |
| Resend / Plus Five Five, Inc. | Transactional notifications and client-request email delivery | Sender and recipient addresses, sender name, notification or request title, request message, optional due date, invitation link and delivery status; the request form does not attach original files |