LedgerLock — Privacy Policy

Effective date: July 18, 2026
Service: LedgerLock, at ledgerlock.the-atlas-project.net
Provider: The Atlas Project (operator of the "An Atlas Project" portfolio)

The short version. LedgerLock reconciles your Stripe books and, once you connect and approve, posts corrected journal entries to your QuickBooks Online or Xero. To do that we process your account details and the financial records in your connected accounts. We use essential cookies only (the sign-in session) — no analytics, no ad pixels, no tracking, no consent banner. We do not sell or share your personal information, and because LedgerLock's close engine is deterministic software, your financial records are never sent to any AI model. For the financial records we handle on your behalf, you are the controller and we are your processor (see the DPA in §14).

§P1 Who we are; scope

This Privacy Policy explains how The Atlas Project ("we," "us," "our") handles personal information in connection with LedgerLock at ledgerlock.the-atlas-project.net (the "Service"). It applies to the Service and our marketing site. It does not cover the Third-Party Services you connect (Stripe, QuickBooks Online, Xero), which have their own privacy policies.

Controller / processor roles. For your account and billing data, we act as a controller. For the financial records the Service processes on your instruction from your connected Stripe, QuickBooks Online, or Xero accounts (which may contain personal data about your customers, such as names, emails, and transaction details), you are the controller and we are your processor — see the mini-DPA in §14.

§P2 Categories of personal information we collect

We do not use analytics or advertising cookies/pixels, and we do not build advertising profiles. If this ever changes, we will update this Policy and, where required, obtain consent first.

§P3 How and why we use personal information

• Provide the Service — authenticate you; read your Stripe ledger; reconcile it by payout; generate corrected journal entries, comparisons, and audit packs; and, once you approve, post entries to your QuickBooks Online or Xero within the scopes you granted.
• Billing — process your flat subscription via Stripe (LedgerLock is never a percentage of your money).
• Communicate — send transactional and service messages (e.g., receipts, security notices, close-run and product notices) via Resend. We send marketing email only where permitted and with an unsubscribe option.
• Secure and maintain — run abuse and quota checks, detect misuse, debug, and protect the Service and its users.
• Comply — meet legal and tax-record obligations and enforce our Terms.
• Improve — understand feature usage in aggregate. We do not use your financial records or connected content to train any AI model. LedgerLock's close engine is deterministic — no AI/LLM is used on the ledger path — so your financial data is not sent to any AI subprocessor at all.

§P4 Legal bases (GDPR / UK GDPR)

Where GDPR/UK GDPR applies, we rely on: performance of a contract (to provide the Service you signed up for); legitimate interests (to secure, maintain, and improve the Service, and for limited service communications), balanced against your rights; consent (where required, e.g., any future non-essential cookies or optional marketing); and legal obligation (e.g., tax/records). For the financial records we process on your behalf, your instructions and the mini-DPA (§14) govern, and you are responsible for the legal basis as controller.

§P5 Subprocessors and third-party recipients

We use only the following subprocessors and service providers for LedgerLock:

We do not use any AI/LLM subprocessor (e.g., OpenAI or Anthropic) for LedgerLock, because the close engine is deterministic. We do not use analytics, advertising, or data-broker services.

We enter data-processing terms with subprocessors where required and require appropriate safeguards. We will update this list and, where required, give notice before adding a subprocessor that materially changes processing of your data. We do not sell personal information and do not share it for cross-context behavioral advertising.

§P6 Cookies and similar technologies

We use essential cookies only — specifically, the Supabase authentication-session cookie needed to keep you signed in. We do not use analytics, advertising, or tracking cookies or pixels. Because we use only strictly-necessary cookies, we do not show a consent banner for non-essential cookies. If we ever introduce non-essential cookies, we will update this Policy and obtain consent where required.

§P7 Retention

We keep account and billing data for as long as your Account is active and as needed for legitimate business and legal purposes (e.g., tax records) after closure. Encrypted OAuth tokens for your connected accounts are kept only while the connection is active and are deleted when you disconnect or close your Account. Financial records and Output (reconciliations, close runs, journal entries, audit packs, scan cache) are retained per your settings and are deleted or de-identified on request or on termination, subject to residual backups purged on our ordinary cycle and records we must keep by law. Note that any entries already posted to your QuickBooks Online or Xero live in your accounting system, which you control.

§P8 Security

We use reasonable technical and organizational measures appropriate to the risk, including encryption in transit and at rest, access controls, least-privilege, row-level security in our database, and reliance on reputable infrastructure providers (Vercel, Supabase, Stripe). OAuth access and refresh tokens for your connected accounts are stored as AES-256-GCM ciphertext and are never returned to any user client. No system is perfectly secure; we cannot guarantee absolute security. We will notify affected users and regulators of a personal-data breach where required by law.

§P9 Your privacy rights

§P9.1 GDPR / UK GDPR (EEA/UK residents). Subject to conditions, you may request access, rectification, erasure, restriction, portability, and objection, and may withdraw consent where processing is based on consent. You may lodge a complaint with your supervisory authority. Where we act as processor for financial records, we will route your request to the relevant controller (our customer) or assist them.

§P9.2 CCPA / CPRA (California residents). You have rights to know/access, delete, correct, and to opt out of "sale" or "sharing." We do not sell or share personal information as those terms are defined, and we do not use sensitive personal information for purposes that would trigger a right-to-limit. We will not discriminate against you for exercising rights. Authorized agents may submit requests with proof of authorization.

§P9.3 Business-record nuance. LedgerLock processes financial records that may contain personal data about your customers or counterparties. Where such data is personal information of individuals, the rights above typically run to you as controller; we assist as processor and direct end-user requests about that data to you. California's treatment of business-to-business and employee data continues to evolve — we handle such data consistent with applicable law.

§P9.4 How to exercise rights. Email admin@the-atlas-project.net (or admin@the-atlas-project.net) from your Account address, describing your request. We will verify your identity and respond within the time required by law. For financial records we hold on behalf of a customer (processor role), we direct end users to the customer/controller.

§P10 International data transfers

We are based in the United States, and our subprocessors may process data in the US and elsewhere. Where we transfer personal data out of the EEA/UK, we rely on appropriate safeguards such as the EU Standard Contractual Clauses and the UK Addendum, or another lawful mechanism. By using the Service, you understand your information may be processed in the US.

§P11 Children

The Service is not directed to individuals under 18, and we do not knowingly collect their personal information (see Terms §16).

§P12 Changes to this Policy

We may update this Policy. We will post the new version with a revised "Last updated" date and, for material changes, provide additional notice (email or in-product). Continued use after the effective date constitutes acceptance where permitted by law.

§P13 Contact

Questions or requests: admin@the-atlas-project.net (privacy) or admin@the-atlas-project.net. Postal address: The Atlas Project, [MAILING_ADDRESS].

§P14 Mini Data Processing Addendum (LedgerLock)

This section applies to personal data the Service processes on your behalf ("Customer Personal Data") — for LedgerLock, personal data contained in your Stripe records and accounting books (e.g., your customers' names, emails, and transaction details). It mirrors Exhibit A of the Terms.

1. Roles. For Customer Personal Data, you are the controller and we are the processor (or, where you are yourself a processor — e.g., a bookkeeper acting for a client — we are your sub-processor).
2. Instructions. We process Customer Personal Data only (a) to provide and secure the Service, (b) per your documented instructions (including your configuration, account mapping, and connection scopes), and (c) as required by law (we will tell you unless legally barred).
3. Purpose limitation. We will not sell Customer Personal Data, use it for advertising, or use it to train generalized AI models. LedgerLock's close engine is deterministic software — no AI/LLM model is used on the ledger path — so your financial records are not sent to any AI subprocessor.
4. Confidentiality. Personnel with access are bound by confidentiality; human access occurs only as needed for security or support.
5. Sub-processors. You authorize the subprocessors listed in §P5 (Vercel, Supabase, Stripe, Resend, Intuit/QuickBooks, Xero). We remain responsible for their performance and will give notice of material changes with a chance to object.
6. Security. We maintain the measures in §P8 appropriate to the risk, including encryption in transit and at rest and AES-256-GCM token encryption.
7. Assistance. Taking into account the nature of processing, we will reasonably assist you with data-subject requests, security, breach notification, and DPIAs. We will notify you without undue delay after becoming aware of a personal-data breach affecting Customer Personal Data.
8. Deletion/return. On termination or your request, we will delete or return Customer Personal Data, subject to residual backups purged on our ordinary cycle and legal-retention requirements. Entries already posted to your accounting book live in your system.
9. International transfers. The SCCs / UK Addendum in §P10 apply where relevant.
10. Audit. We will make available information reasonably necessary to demonstrate compliance and allow reasonable, confidential audits on notice, subject to appropriate limits.

This mini-DPA suits self-serve customers. Enterprise customers requiring a negotiated DPA and full SCC set should contact admin@the-atlas-project.net; that document should be attorney-reviewed.

Last updated: July 18, 2026 · The Atlas Project · admin@the-atlas-project.net · admin@the-atlas-project.net · [MAILING_ADDRESS]

This document was prepared with automated assistance and has not been reviewed by an attorney. It is not legal advice.