Data processing terms

For the records you keep in Telore — your books, invoices, bills, documents, payroll, the data your bank and payment connections bring in, and the personal data of your customers, suppliers, employees, directors and anybody else that appears in them — you are the controller and we are your processor. For the account each of your people signs in with, for keeping Telore secure, for billing, support and how Telore is used, we are the controller, and our privacy policy applies. These terms are about the first.

Subject matter: the personal data in your records. Nature and purpose: storing, organising, calculating, presenting and exporting it to provide the accounting service you use, reading it from the providers you connect, sending the documents and messages you ask us to send, and filing what you approve with HMRC or Companies House. Duration: for as long as you use Telore, and then for the period in "At the end" below. Data subjects: your customers, suppliers, employees, directors, shareholders and other people you pay or are paid by. Types of data: names, contact details, addresses, tax and company identifiers, bank account details, amounts and descriptions of payments, invoices and bills, and payroll details such as pay, tax codes and National Insurance numbers. We do not ask for special category data; if a record you keep reveals some — a statutory sick pay entry, for example — we process it only as part of that record.

We process your personal data only on your documented instructions. Those instructions are these terms, the terms of service, what you do in Telore — every connection you make, document you send and filing you approve is an instruction — and anything else you ask of us in writing. If we are required by law to process it in another way, we will tell you first unless the law forbids it. If we believe an instruction breaks data protection law, we will tell you and need not follow it.

Everybody at Telore who can reach your data is bound to keep it confidential. Only a small number of named staff can look at a company at all, only to give support, keep the service safe or meet a legal obligation, only after giving a reason, and only to read: every look is recorded and kept for six years, and nothing can be changed, sent or deleted that way.

We take the technical and organisational measures Article 32 of the UK GDPR requires, appropriate to the risk of financial records. They include: your data held in the United Kingdom, in Amazon Web Services' London region; encryption in transit for every connection to and within Telore, and at rest for the database, every stored file and its backups; the credentials of each bank and payment connection encrypted again with a key of our own; files kept in private storage that is never public, and shown only through links that expire after 30 minutes and are made only for somebody who has proved they may see them; every query scoped to the company it belongs to; staff access as described above, with a passkey and a second factor; the servers reached only through an audited management channel, never by an open remote login; error reports that carry no financial records, names or provider data; daily backups; and records of every sign-in and security event. We review these measures and may change them, but never so that they protect your data less.

You give us general authorisation to use sub-processors. The current list, with what each one does, what it receives and where, is at telore.com/legal/sub-processors. We will email the owners of every company at least 30 days before we add or replace a sub-processor. If you object on reasonable data protection grounds, tell us within that time; we will try to find a way to address it, and if we cannot, you may end the agreement before the change takes effect and receive a refund of any fees paid for the period after that. Every sub-processor is bound by a written contract giving your data the same protection as these terms, and we remain responsible to you for what it does.

Your records are held in the United Kingdom. Where a sub-processor processes personal data outside the UK, we make the transfer only with a safeguard UK law recognises: the UK adequacy regulations, the International Data Transfer Agreement, or the UK Addendum to the EU standard contractual clauses. The sub-processors page says which applies to each.

Telore lets you find, correct, export and delete the records you hold about a person, so most requests from people about their data can be answered by you directly. If a request about your records reaches us, we will pass it to you without undue delay and will not answer it ourselves unless you ask us to. We will help you, as far as we reasonably can, to answer requests, to carry out a data protection impact assessment, and to consult the Information Commissioner's Office where you need to.

If we become aware of a personal data breach affecting your records, we will tell you without undue delay, and in any event within 48 hours of becoming aware of it, by email to the owners of the company. We will tell you what happened, what data and how many people are involved as far as we know, what we have done and are doing about it, and who you can talk to; and we will keep you informed as we learn more, so that you can meet your own obligation to report it within 72 hours. Telling you is not an admission of fault.

You can download everything at any time with "Download everything". When you close a company, its records stay available to you, read only, for the period our retention policy sets, so that you can meet your own record-keeping obligations; you can tell us in writing to delete them sooner. When the period ends, or when you instruct us, we delete the records, except anything the law requires us to keep, which we keep only for that purpose. Deleted data leaves our backups as they are replaced, within 35 days.

We will make available to you the information you reasonably need to show that these terms are being met, and answer a reasonable written questionnaire about them once a year. Where that is not enough, or a regulator requires it, you or an independent auditor bound to confidentiality may audit our compliance with these terms, at your cost, on at least 30 days' notice, during business hours, and in a way that does not expose other customers' data.

The limits of liability in the terms of service apply to these terms, except where the law does not allow them to. If these terms and the terms of service differ about personal data, these terms apply.

We may update these terms to reflect a change in the law, in the service or in our sub-processors. We will email you before a change that reduces the protection your data has, and no change will do so without your agreement.