PRIVACY POLICY

INVOICE FLY is committed to protecting and respecting your privacy. In this privacy policy (“Privacy Policy“), we explain how INVOICE FLY collects, uses, discloses and protects the Personal Information you submit to us, including, for example, when accessing and using INVOICE FLY mobile application and website https://invoicefly.com/ (hereinafter “Platform”).

Our Privacy Policy has been drafted to comply with applicable data privacy laws, in particular, the EU General Data Protection Regulation (“GDPR”). If the GDPR does not apply to you, not all terms of this Privacy Policy may be relevant to you.

As used in this Privacy Policy,

INVOICE FLY is committed to the following key principles:

1. LEGAL CAPACITY
   1. Minimum age. To provide us with your personal data, you must be at least 18 years old and/or, where applicable, have sufficient legal capacity to use our Platform.
   2. Accuracy. When you provide us with your data to use our services, you guarantee that the data and information provided is real, accurate, up-to-date, and belongs to you and not to third parties.
      In addition, you must notify us of any changes to the data provided, and you are responsible for the truthfulness and accuracy of the data provided at all times.
   3. Age and Accuracy Control. INVOICE FLY reserves the right to verify your age and identifying information at any time, if necessary, including by requesting official supporting documentation or an equivalent procedure, and, in the event of detected fraud or suspicion that you are under the indicated age, to delete, temporarily deactivate, and/or cancel your account.
2. WE LIMIT HOW, AND WITH WHOM, WE SHARE YOUR PERSONAL INFORMATION.
   1. In general, INVOICE FLY will not disclose your data to third parties.
   2. However, in addition to the transfers that we specifically indicate in the section explaining the characteristics of the different operations (point 3), we inform you of the communications that we may make, in general, and that affect all of the above processing and its legal basis.
      
      1. Providers of services essential to the performance of the service we offer you (e.g., computer hosting companies or commercial communication delivery platforms). Notwithstanding the foregoing, these entities have signed the corresponding confidentiality agreements and will only process your data in accordance with our instructions, and may not use it for their own purposes or for purposes other than the service they provide to us.
      2. Public bodies. We may disclose to the competent public authorities any data and other information in our possession or accessible through our systems when there is a legal obligation to do so, as well as when required, for example, when the purpose is to prevent or prosecute abuse of services or fraudulent activities through our Platform. In these cases, the personal data you provide us with will be retained and made available to the administrative or judicial authorities.
      3. In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or part of its assets, or any other type of corporate transaction involving a third party, we may share, disclose, or transfer user data to the successor entity (even during the pre-transaction phase).
      4. To third parties after aggregation or anonymization: We may disclose or use aggregated or anonymized data (i.e., data that cannot be linked to an identified or identifiable natural person) for any purpose.
      5. To third parties with the user’s consent or other legitimate basis: In the event that we wish to share data with third parties outside the scope of this Privacy Policy, we will, in all cases, request your consent or inform you of the same and its legitimate basis.
3. PURPOSE AND LEGAL BASIS OF THE PROCESSING
   

   Personal Information	Purpose	Legal Basis
   We collect your identification data (first and last name) and email address. Other information you voluntarily include in the communications you send us (i.e. through our section “support”). We may request additional information if necessary to fulfill your request or requirement.	To create and support your profile when you register for our service. To answer your requests. For instance, (i) if you choose to register to receive information about our products and services, (ii) if you contact our support or customer service, we will use your Personal Information in order to respond.	Processing is necessary for the purposes of our legitimate interests, i.e. to attend to your request for information, purchase of products/services or if you contact our customer service.
   Business Data, such as Business Name, Business number, address, e-mail address, phone number, website, business address, license number, industry and other information about your transactions and communications with us.	To provide our services through the Platform.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at the request of you, to provide our services.
   User-Provided Financial Data, Invoice & Estimates details such as client names, company names, tax identification numbers, billing addresses, phone numbers, amounts, payment terms, and descriptions of items, goods or services. Payment Methods. Expense details, including vendor names, payment amounts, dates, and attached receipts or supporting documents).	To provide our services through the Platform.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at the request of you, to provide our services.
   Uploaded Documents and Media (Photos, Receipts, invoices, or other financial documents uploaded for AI data extraction. PDFs or images processed to generate structured financial data.	To enable you to use media-related features such as adding a photo to an invoice via camera capture or scan payment receipts.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at the request of you, to provide our services.
   AI Generated Data (Extracted data from receipts and invoices produced by AI models). AI-generated outputs such as structured expense reports, summaries, or PDF documents. Metadata related to these AI interactions, such as processing time or document size, may also be collected.	Certain features may use AI-assisted data extraction to process information from uploaded receipts, invoices or other files.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at the request of you, to provide our services.
   Usage data. We collect and log internet or other electronic information on how you access and use our Service. For example, the act of creating an invoice or sharing an invoice	To administer our service and to improve the features and usability of the Service. To provide account support. To suggest features, products, and services that can enhance your use of our Service.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at the request of you, to provide our services.
   Device Information: such as IP address, geographic location, operating system information, referral source, pages viewed and navigation paths on the website, device permissions, hardware information, browser type and version, identifiers and others.	Localization & customization of the user experience for each specific device and location. To inform our product development.Marketing efforts and attribution. Tracking of errors and Incident management.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at the request of you, to provide our services.
   Name, address, e-mail address and other contact information	To periodically contact you to inform you of new products and/or services we provide or that we consider to be of interest to you.	Your consent
   Application data, including your name, address, CV, birthdate	Processing is required to enable us to administer the recruiting process, including the set-up of an electronic job applicant HR file, managing your application, organizing interviews. We may retain your Personal Information following your unsuccessful application so that we may contact you in case of future job vacancies. Your data may also be shared with other INVOICE FLY group companies to consider your application for other job openings.	Primarily, the processing is necessary to take steps for entering into a contract with you. We also have a legitimate interest to (i) store your data for a period of up to 6 years following the conclusion of an unsuccessful application and/or (ii) to share it with the INVOICE FLY group of entities and/or (iii) to retain and use your data as far as necessary for the establishment, exercise or defense of legal claims.
   All of the above	For compliance with legal and regulatory requirements and corporate governance obligations.	Processing is necessary for compliance with legal obligations to which we are subject.

   Where you wish to provide us with Personal Information about another person, you must ensure that you have their prior permission to do this. You must also share with them a copy of this Privacy Policy as well as any other relevant privacy statements (see above) before you ask them for this permission.

   We collect Personal Information for the purposes described above when you use our Platform and from public sources.

4. DATA PROCESSING AGREEMENT
   1. Data for which you are the “Data Controller”. Data Processing AgreementTo provide our Services, we may process (i) collected data from your invoices (i.e. client names), (ii) other upload documents and media, and (iii) generated data (extracted data from receipts and invoices).If the data you collect when using our Services contains Personal Information from third parties, you will be considered the personal data “Controller”, and you will need to obtain the prior consent of the data subjects when the applicable regulations require such consent. In such cases, INVOICE FLY will act as “Data Processor”, according to the Data Processing Agreement (DPA) that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the Controller.The standard Data Processing Agreement can be found on our website at invoicefly.com/dpa.
5. WE KEEP YOUR PERSONAL INFORMATION FOR AS LONG AS IT IS NECESSARY TO DO SO TO FULFIL THE PURPOSES FOR WHICH IT WAS COLLECTED AS DESCRIBED ABOVE.
   1. The criteria we use to determine data retention periods for Personal Information includes the following:
      
      1. Retention in case of queries: we will retain it for a reasonable period after the relationship between us has ceased in case of queries from you.
      2. Retention in case of contracting our products/services or contacting our customer service: we will retain it for the time necessary to deliver our product/service to you according to the contract conditions, as well as to attend any of your questions.
      3. Retention in case of claims: we will retain it for the period in which you might legally bring claims against us**.**
      4. Retention in accordance with legal and regulatory requirements: we will consider whether we need to retain it because of a legal or regulatory requirement, e.g. to comply with tax or fiscal duties.
      5. Retention in case of job applications: if you applied for a job offering with INVOICE FLY and have not been successful, your application data will be retained in our talent pool for a limited period as defined in Principle 3.
6. INTERNATIONAL TRANSFERS
   1. INVOICE FLY operates globally, therefore your personal information may be transferred and accessed from around the world from countries where INVOICE FLY affiliates and subsidiaries are located and where our processors operate
   2. The data will be transferred for the time required to fulfill the purpose for which it is processed. It can be shared with our service providers and INVOICE FLY affiliates for the purposes listed in Principle 3. In such cases, INVOICE FLY is the controller of the data, and the service providers are processors or joint controllers, as the case may be.
   3. We may transfer Personal Information to the following categories of recipients:
      

      Recipient Category	Countries	Purpose of Transfer	Data Types Transferred
      Cloud Service Provider (Google Cloud)	USA	Storage, Analytics, Security	Device Info, User Info
      Customer Support (Intercom)	USA	Customer service and technical support	Device Info, User Info
      Subscription Processor (RevenueCat)	USA	Subscription Management	Device Info, User Id, User Email
      Payment Processors (Stripe, PayPal)	USA	Processing of Payments	Email, User Id, Invoice and Estimate Amounts
      Analytics (Appsflyer, Mixpanel, Google Analytics, Smartlook)	USA, Czech Republic	User analytics	Device Info, User Info
      AI Providers (OpenAI, Replicate, Photoroom)	USA, France	App features (AI Logo, Remove Background, etc)	User Info
      Marketing Campaigns (MailChimp)	USA	Email marketing and account alerts	User email
      Internal Communications (Gmail, Slack, Notion)	USA	Internal Communications	User Info, Device Info
      Feedback (Tally)	Belgium	Usability Research / Feedback / Forms	User Info, Device Info

      Where personal data is transferred to service providers located outside your country of residence, INVOICE FLY applies appropriate safeguards, such as:

      1. The European Commission’s Standard Contractual Clauses (SCCs), or
      2. Equivalent contractual mechanisms recognized by the competent authority in the recipient country.

      These measures ensure a level of protection consistent with that required by the GDPR.

   4. Depending on where you are located, we implement the appropriate safeguards when transferring Personal Information to these countries.
   5. Information for individuals in the European Economic Area (“EEA”) and the United Kingdom (“UK”)INVOICE FLY may transfer personal information from the EEA or the UK to the United States (‘US’) and other countries.When INVOICE FLY engages in such transfers of personal information, it relies on:
      • Adequacy Decisions, as adopted by the European Commission, based on Article 45 of Regulation (EU) 2016/679 (GDPR) – for more information, and to access the full list of countries deemed adequate to date, please visit How EU determines if a non-EU country has an adequate level of data protection.
      • Adequacy Decisions, as adopted by the UK Secretary of State, based on Article 45 of the UK GDPR and Section 17A of the Data Protection Act 2018 – for more information, and to access the full list of countries deemed adequate to date, please visit UK GDPR guidance and resources.
      • The EC’s Standard Contractual Clauses (“SCCs”) and the UK Information Commissioner’s Office’s International Data Transfer Addendum (“IDTA”), as applicable, supplemented by additional security measures as recommended by the European Data Protection Board. The EC’s and the UK’s Information Commissioner’s Office (“ICO”) have determined that the SCCs and IDTA may provide sufficient safeguards to protect personal data transferred outside the EEA and the UK. For more information, please visit SCC for data transfers between EU and non-EU countries and UK GDPR guidance and resources.

      INVOICE FLY performs transfer impact assessments (“TIA”) and continually monitors the circumstances surrounding such transfers to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the EEA and UK data protection laws.

   6. Information for individuals from the European Union, UK, Gibraltar and Switzerland: EU-US Data Privacy FrameworkAs part of our commitment to maintaining high data protection standards when transferring personal information between the US and European Economic Area (“EEA”)/UK/Gibraltar/Switzerland, we participate in the EU-US Data Privacy Framework (‘EU-US DPF’) and the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (“Swiss-US DPF”).INVOICE FLY and all our affiliates comply with the EU-US Data Privacy Framework (EU-US DPF) and the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce.In compliance with the EU-US DPF and the UK Extension to the EU-US. DPF, and the Swiss-US DPF, INVOICE FLY commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the EU/SWISS DPF Principles.  European Union, UK, Gibraltar and Swiss individuals with DPF inquiries or complaints should first contact INVOICE FLY Data Protection Officer dpo@labhouse.io. We will investigate and attempt to resolve any complaints or disputes regarding processing of personal information within 45 days of receiving your privacy complaint.Accountability for Onward Transfers. We acknowledge our responsibility for the processing of personal information received and subsequently transferred to our third parties, agents, and service providers. INVOICE FLY remains liable under the DPF Principles if a third party, agent, or service provider processes personal information covered by this Notice in a manner inconsistent with the DPF Principles, except where INVOICE FLY can demonstrate that we are not responsible for the event giving rise to the damages.
   7. Information for individuals in California (CCPA/CPRA)If you reside in California, the following rights apply under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):
      • Right to Know the categories of personal information collected, the purpose of collection, and the categories of third parties with whom it is shared.
      • Right to Request Deletion of personal information, subject to legal or operational retention obligations.
      • Right to Opt-Out of the sale or sharing of personal information.INVOICE FLY does not sell or share personal data for monetary value, but we provide this right for transparency.
      • Right to Non-Discrimination for exercising any privacy rights.

      You may exercise these rights by contacting dpo@labhouse.io and including “CCPA Request” in the subject line.

   8. Information for individuals in Canada (PIPEDA)If you reside in Canada, please note that INVOICE FLY complies with the Personal Information Protection and Electronic Documents Act (PIPEDA).
      Canadian users have the right to access and correct personal data and to withdraw consent where processing is based on consent.
      Complaints may be submitted to the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.
   9. Information for individuals in Australia (APPs)
      
      If you reside in Australia, INVOICE FLY ensures that personal data is processed in line with the Australian Privacy Principles (APPs) established under the Privacy Act 1988.
      These frameworks provide rights equivalent to those already described in this Policy (access, rectification, erasure, limitation, objection).
7. B2B COMMERCIAL LEVEL
   1. Our Platform, services and events are aimed solely at B2B commercial level. If you are a consumer or intend to use the platform for non-commercial purposes, please do not attempt to register for the services or events or send any personal information about yourself to us. If you believe we have mistakenly or unintentionally collected personal information without appropriate consent, please contact us at support@labhouse.io and we will take steps to delete their personal information from our systems.
8. GIVE US YOUR FEEDBACK
   1. Our goal is to protect your privacy. To comment or help us improve, please contact us via email (dpo@labhouse.io). You may also contact us via written letter at INVOICE FLY’s address (Labhouse Mobile, SL., Plaça Pau Vila, 1, Ciutat Vella, 08003 Barcelona, Spain). We may ask you to provide a copy of your proof of identity.
   2. If you consider that we are in breach of our obligations under data protection laws, you may lodge a complaint with the competent Data Protection Authority, which may be the supervisory authority in your country of residence, place of work or of an alleged infringement of data protection laws.
9. CHANGES TO THIS PRIVACY POLICY
   1. This privacy policy may be modified from time to time to comply with applicable laws or to conform to our current business practices. We will post any changes to this on our Platform and, where required by law, will notify you via your contact email. When notifying such changes to you, we will also explain what the likely impact of those changes on you will be, if any. We encourage you to revisit the Privacy Statement that is posted on our Platform from time to time to check for updates.
10. ADDITIONAL INFORMATION WE WANT YOU TO KNOW:
    1. Provision of Personal Information / Automated decision making. Please note that the Personal Information we collect from you is necessary to provide the services and our Platform to you. Failure to provide such data may not enable us to provide our services to you or make our Platform accessible. We do not use automatic decision-making or profiling of individuals.
    2. Your Rights. You have various rights under data privacy laws in your country. These may include (as relevant):
       • Right to request access to the Personal Information we hold about you.
       • Right to rectification including to require us to correct inaccurate Personal Information.
       • Right to request restriction of processing concerning you or to object to processing of your Personal Information.
       • Right to request the erasure of your Personal Information where it is no longer necessary for us to retain it.
       • Right to data portability including to obtain Personal Information in a commonly used machine-readable format in certain circumstances such as where our processing of it is based on a consent.
       • Right to object to automated decision-making including profiling (if any) that has a legal or significant effect on you as an individual.
       • Right to withdraw your consent to any processing for which you have previously given that consent.
    3. Marketing Information. With your consent, where relevant, we will keep your name, address and contact details (including telephone numbers and email addresses) in our databases and may from time to time use that information to make you aware of our related products and services as well as updates on developments in our industry sector generally which may be of interest to you. We may contact you in writing, by telephone or email for this. If at any time you decide that you do not want your contact details used for these purposes, you may object or revoke your consent for receiving marketing communications by following the instructions in the relevant marketing communication (e.g., clicking on the “Unsubscribe” button) or by contacting us (see “Give Us Your Feedback” above).
    4. Security Statement. We take reasonable precautions to protect your information. In particular, we implemented appropriate technical and organizational measures designed to ensure a level of security appropriate to the risk, including as appropriate: (a) pseudonymization (such as where data is separated from direct identifiers so that linkage to an identity is not possible without additional information that is held separately) and encryption, (b) protecting the ongoing confidentiality, integrity, availability and resilience of systems and services used to process your Personal Information, (c) providing the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident; and (d) maintaining a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational security measures. When you submit information to us through our Platform, your information is protected both online and offline. All data transferred to/from the INVOICE FLY internal network, from/to an external entity, is encrypted to industry standards. Please keep in mind that messages you send to us by Internet e-mail may not be secure. We maintain appropriate physical, electronic and procedural safeguards to ensure the security, integrity and privacy of your personal information within our company. Only those employees who may require your information to perform a specific job are granted access to your organization’s identifiable information. Furthermore, all employees are kept up-to-date on our security and privacy practices.
    5. Our Use of Cookies and Analytic Tools. INVOICE FLY may use “cookies” or other tracking and tracing tools as further described in our Cookie Policy.
       Depending on the country in which you are located, you may be asked to provide your consent for our use of Cookies (except for strictly necessary Cookies). In addition, you have the following choices concerning the use of Cookies.
    6. Third Party Websites. Our Platform may contain links to third-party websites. If you follow these links, you will exit our Platform. This privacy policy does not apply to websites of third parties. INVOICE FLY cannot accept liability for the use of your Personal Information by these third parties. Your use of these websites is at your own risk. For more information on how these third parties treat your Personal Information, please check their privacy policy (if available).