Privacy Policy

1. Who we are

Consilaro is operated by [Operator legal name], [IČO / company registration number], [Registered address] ("Consilaro", "we", "us"). For any question about this policy or your personal data, contact us at [privacy contact email].

2. Our two roles: controller and processor

We act as the controller of personal data about the people who hold a Consilaro account — workspace owners, team members and viewers — and about how they use the service. Sections 3 and 4 describe that data.

Consilaro users are businesses that manage their own clients in Consilaro. The data they enter or collect through it — about their clients, their clients’ contact persons, people who sign their documents, their client portal users and people who book a meeting with them ("Customer Data") — belongs to them. For Customer Data the Consilaro user is the controller and we are a processor acting on their instructions under Article 28 GDPR. Section 5 describes that data.

If you are a client of a business that uses Consilaro, please contact that business first about your personal data. If you contact us instead, we will pass your request on to them and help them respond.

3. Personal data we process as controller

• Account data: your name, email address and password. Passwords are stored only as a salted one-way hash, never in readable form. Optionally, your job title and phone number.
• Workspace data: your business name, address, company registration and VAT numbers, bank account details (account number, IBAN, BIC), logo, invoice numbering, currency, language and reminder settings. For a sole trader some of this is personal data.
• Team data: who belongs to your workspace and in which role, the email addresses of people you invite, and messages exchanged in team chat.
• Subscription data: your plan, billing interval, subscription status and the identifier Stripe assigns to your account. Card details are entered directly with Stripe and never reach our servers.
• Connected payment account: if you connect your own Stripe account to take invoice payments, the identifier of that account, whether it is in test or live mode, and when it was connected. We do not store keys or passwords for it, and we do not receive your clients' card details.
• Referral data: the referral link a workspace signed up through and any rewards earned.
• Feedback: messages you send to us from within the app, with your email address so we can reply.
• Security data: the IP address and browser user agent of each sign-in session, and an audit log recording which user performed which action in the workspace and when.
• Usage data: pages you view and a defined set of product events (for example "proposal sent" or "invoice paid"), linked to your account. This is collected only inside the signed-in application. Session recording and automatic capture of clicks and form input are switched off.
• Error diagnostics: technical details when something breaks, such as the page, browser and error trace. Error reports are configured to exclude user identity, request bodies, cookies and form contents.

4. Why we process it and on what legal basis

• To provide the service — your account, workspace, team features, emails the service sends (such as email address confirmation, invitations, password resets and booking notifications) and support: performance of our contract with you (Article 6(1)(b) GDPR).
• To bill your subscription and keep accounting and tax records: performance of contract and compliance with legal obligations under Czech accounting and tax law (Article 6(1)(b) and (c)).
• To keep the service and your data secure — session management, audit logging, rate limiting, abuse prevention and error monitoring: our legitimate interest in operating a secure, working service (Article 6(1)(f)).
• To understand which features are used and improve the product: our legitimate interest in developing the service (Article 6(1)(f)). You can object at any time (section 10).
• To run the referral programme: performance of contract (Article 6(1)(b)).
• To establish, exercise or defend legal claims: our legitimate interest (Article 6(1)(f)).

We do not send marketing emails. If that changes, we will ask for your consent where the law requires it.

5. Customer Data we process on your behalf

Depending on the features a Consilaro user chooses to use, we process the following on their behalf:

• Clients and contacts: names, email addresses, phone numbers, roles, company details, billing addresses, notes, tags and uploaded files.
• Business records: deals, proposals, contracts, invoices, time entries, tasks, expenses and receipts.
• Electronic signing: the signer’s name and email address, a one-time verification code (stored only as a hash and valid for 15 minutes), IP address, approximate location (country and city) derived from that IP address, browser user agent, the times the document was viewed and signed or declined, the drawn signature, and cryptographic fingerprints of the document before and after signing. This is kept as evidence that the signature is genuine.
• Client portal: the name and email address of each client portal user, the times they signed in, and the IP address from which a sign-in link or session was created.
• Booking pages: the name, email address and optional note a visitor enters, and the meeting time they choose. We do not email the visitor.
• Payment reminders: if the Consilaro user switches them on, reminder emails are sent in their name to the client contact on an unpaid invoice.
• Receipt scanning: when a user chooses to scan a receipt, the image or PDF is sent to Anthropic to read the supplier, date and amounts. Nothing is saved until the user has reviewed the result.
• Company lookups: when a user looks up a company, its registration or VAT number is sent to the public ARES and VIES registers.

6. Who we share personal data with

We use the following service providers, who process personal data only on our instructions and under data processing terms:

• Railway — application hosting and database ([hosting region]).
• Cloudflare — storage of documents, uploaded files and logos (R2), and the Turnstile bot check on the sign-in, sign-up and password-reset forms, which receives the visitor's IP address and technical signals from their browser to tell people from automated traffic.
• Stripe — subscription billing and, where a Consilaro user connects their own Stripe account, payment links on that user's invoices. Those payments are made to the user's Stripe account, not to us. For payment processing Stripe also acts as an independent controller under its own privacy policy.
• Resend — delivery of emails sent by the service.
• Inngest — scheduling and running background tasks, such as reminders.
• PostHog — product usage analytics, hosted in the EU.
• Sentry — error monitoring.
• Anthropic — reading receipts, only when a user chooses to scan one.
• ipapi.co — deriving approximate location from an IP address when a document is signed or declined.

Company lookups query ARES (operated by the Czech Ministry of Finance) and VIES (operated by the European Commission); only the company identifier is sent. A Consilaro user may choose to publish a Calendly link instead of the built-in booking page; visitors who book through Calendly do so under Calendly’s own terms, and Consilaro stores only the link.

We do not sell personal data. We may also disclose it where the law requires us to, to our professional advisers under a duty of confidentiality, or to a successor if the business is transferred, in which case this policy continues to apply.

7. Transfers outside the European Economic Area

Some of the providers above are established in, or may access data from, countries outside the EEA, in particular the United States. Where that happens, the transfer relies on an adequacy decision of the European Commission — including the EU–US Data Privacy Framework for providers certified under it — or on the Commission’s Standard Contractual Clauses. You can ask us for information about the safeguard used for a particular provider.

8. How long we keep personal data

• Account, workspace and usage data: for as long as the account exists. After an account is closed we delete or anonymise it within [number] days, except for the records below.
• Signed proposals and contracts, with their signing evidence: 3 years from signing, which is the general limitation period under section 629 of the Czech Civil Code. They are retained for that period even if erasure is requested, as permitted by Article 17(3)(e) GDPR, and we will tell you in writing when that applies.
• Our own billing and accounting records: for the periods required by Czech accounting and tax law, which can be up to 10 years.
• Short-lived credentials: signing verification codes expire after 15 minutes, signing links after 72 hours, client portal sign-in links after 15 minutes and client portal sessions after 24 hours. Email address confirmation links expire after 24 hours. App sign-in sessions last up to 30 days.
• Accounts whose email address is never confirmed: deleted 7 days after sign-up.
• Receipts uploaded for scanning but not saved: deleted when the user saves or cancels the scan.
• Backups: up to [number] days after the data is deleted from the live system.

Customer Data is kept for as long as the Consilaro user keeps it in their workspace; they decide when to delete it. It is deleted with the workspace, subject to the retention of signed documents described above.

9. Cookies and browser storage

• Strictly necessary: a session cookie that keeps you signed in, a separate session cookie for client portal users (used only within the portal), and a security cookie for Consilaro administrators. The service cannot work without them.
• Preferences: your choice of light or dark theme is stored in your browser.
• Analytics: inside the signed-in application only, PostHog stores an identifier in a cookie and in browser storage to recognise your browser between visits.

Public pages — including the sign-in page, document-signing pages, the client portal and booking pages — set no analytics cookies. We use no advertising cookies and no third-party advertising trackers.

10. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you and receive a copy;
• have inaccurate data corrected;
• have your data erased, subject to the retention described in section 8;
• restrict how we process your data;
• receive data you provided in a structured, machine-readable format (portability);
• object to processing based on our legitimate interests, including product analytics;
• withdraw consent at any time where we rely on consent, without affecting processing that took place before.

To exercise a right, contact us at [privacy contact email]. We will respond within one month, which may be extended by two further months for complex requests, and we may need to confirm your identity first. Requests about Customer Data are handled by the Consilaro user who controls it, with our help.

You also have the right to lodge a complaint with a supervisory authority. In the Czech Republic this is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Praha 7, www.uoou.gov.cz. You may also complain to the authority in the EU country where you live or work.

11. How we protect personal data

Each workspace’s data is isolated from every other workspace at the database level. All connections are encrypted in transit. Documents and uploaded files are held in private storage and opened only through links that expire. Verification codes and client portal credentials are stored only as hashes. Access by our own personnel is limited to what is needed to operate and support the service.

No system is completely secure. If a personal data breach occurs, we will notify the supervisory authority and, where required, the people affected, as the GDPR requires.

12. Automated decision-making

We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you. Receipt scanning only suggests values that a person reviews before anything is saved.

13. Children

Consilaro is a service for businesses and is not intended for anyone under 18. We do not knowingly collect personal data from children.

14. Changes to this policy

We may update this policy as the service or the law changes. The date at the top shows when it was last updated. If a change materially affects how we use your personal data, we will tell account holders by email or in the application before it takes effect.