Privacy statement

Pairoli is a service of Marshmallow. In this privacy statement, “Pairoli”, “we” and “us” mean Marshmallow, with the details below.

Have a question about privacy or want to exercise one of your rights? Email privacy@pairoli.com.

Pairoli has two roles, depending on the data.

• Controller: for your account and subscription data, such as your name, email address, payment details and how you use Pairoli. We decide why and how we process that data, and this privacy statement covers it.
• Processor: for the content of the invoices, emails and statements you put into Pairoli. These can contain personal data, for example of contacts at your suppliers. We process that data on your behalf, as the customer. You are the controller for it. The arrangements for this are in the article Data processing terms of our terms and conditions (https://pairoli.com/en/terms).

We only process the data needed to make Pairoli work:

• Account data: your name, email address, your password (only stored as a hash), your language preference and, if you turn it on, your two-factor authentication settings.
• Team data: your team’s name, who is a member and in which role, the email addresses of people you invite and your personal forwarding address.
• Subscription and payment: your plan, your billing details (such as company name, address and VAT number), payment status and our invoices to you. You enter your payment details, such as your card number, with our payment provider Stripe.
• Forwarded emails: sender, subject, date received, and the content and attachments of emails sent to your forwarding address. If an email contains a link to an invoice, Pairoli may download that invoice.
• Invoices: the PDF file, the text we read from it and the details we extract, such as supplier, amount, currency, invoice date and the supplier’s VAT number, email address and IBAN.
• Statements: the file you upload, the bank or card issuer, the period and for each line the date, description, amount and currency, and which invoice belongs to which line.
• Settings and notes: your suppliers, merchant rules, notes on lines and, if you use the fetch library, which suppliers you turned on, the email address of your account with that supplier and the results of fetch runs.
• Activity log: who did what with invoices, statements and lines, and when. This lets you see who made or changed a match.
• Technical data: the IP address and browser details (user agent) of your signed-in sessions, and error reports from the app with sensitive content filtered out.
• Contact: the messages you send us, for example when you have a question.

We only use your data for the purposes below, each with a legal basis under the General Data Protection Regulation (GDPR):

• Providing Pairoli: creating your account, signing you in, receiving and reading invoices, matching statements and building your PDF. Legal basis: performance of our contract with you.
• Subscription and payment: managing your plan, collecting payments and sending invoices. Legal basis: performance of the contract, and a legal obligation for keeping our records.
• Service messages: emails that are part of Pairoli, such as confirming your email address, a weekly overview of lines that are still open and notices about important changes. Legal basis: performance of the contract. We don’t send you newsletters or other marketing email without your consent.
• Security and fixing errors: preventing misuse, protecting your account and finding and fixing errors. Legal basis: our legitimate interest in a secure, well-functioning service.
• Answering questions: replying when you contact us. Legal basis: our legitimate interest, or performance of the contract if your question is about it.

Pairoli first reads and matches invoices and statements with fixed rules. Only when that doesn’t work or in case of doubt do we use an AI model from Mistral AI, which runs in the EU.

Before we send text to Mistral, we strip sensitive data: IBANs, email addresses, phone numbers and lines with an address are removed, and only the last four digits of card numbers remain. Data needed for matching, such as the merchant name, amount and date, is sent along. If an invoice has no readable text, for example a scan or screenshot, we send an image of its pages; that cannot be cleaned beforehand.

We check what the AI returns on our servers. Pairoli only links a line to an invoice that is already in your own team. AI use is subject to a monthly limit; once it is reached, we temporarily stop using AI and you can match lines yourself.

We keep the cleaned text we send to Mistral and its answer for 30 days, so we can investigate reading errors. We do not use your data to train AI models.

Pairoli does not make decisions about you that have legal effects or similarly significantly affect you. Matches are suggestions you can always change yourself.

We don’t keep data longer than needed:

• Account: for as long as your account exists. If you delete your account in the settings, we delete your user details straight away.
• Invoices, statements and emails: for as long as the team they belong to exists. If you delete an invoice or statement, we delete its file too. If you delete a team, it is no longer accessible straight away; on request via privacy@pairoli.com we permanently delete all of the team’s data and files within 30 days.
• Original emails: the complete email as it arrived at your forwarding address is deleted automatically 90 days after receipt. The invoice and the details we extracted from it are kept.
• AI requests: the cleaned text and Mistral’s answer: 30 days.
• Activity log: 365 days; after that the entries are deleted automatically.
• Signed-in sessions: until the session expires or you sign out.
• Connection with your AI assistant: access tokens are valid for 12 hours and can be renewed for 30 days. We delete expired and revoked tokens daily.
• Records: our invoices to you and the related payment details are kept for 7 years, because tax law requires it.

We don’t sell your data and don’t share it with advertisers. To make Pairoli work, we use the sub-processors below. We have a data processing agreement (DPA) with each of them. They may only use your data for the service they provide to us.

We only give data to others when the law requires us to, for example after a lawful request from a public authority.

Pairoli runs in the EU: the app on a server in the EU, files in Frankfurt, email through Mailgun’s EU region, error reports with Sentry in Frankfurt and AI with Mistral in France.

Some sub-processors are US companies or have a US parent company, such as Laravel (Forge), Sentry, Cloudflare and Stripe. If data ends up outside the European Economic Area as a result, this only happens with appropriate safeguards, such as the EU-US Data Privacy Framework or the European Commission’s standard contractual clauses.

Among other things, we take these measures:

• Encrypted connection: Pairoli is only available over HTTPS.
• Signing in: we only store passwords as a hash, and you can turn on two-factor authentication with an authenticator app.
• Separate teams: data always belongs to one team and is only visible to that team’s members.
• Less data to AI: we strip sensitive data from text before it goes to Mistral, and we check every answer.
• Error reports without content: invoice text, statement lines, merchant names and email addresses are filtered out of error reports before they go to Sentry.
• Encrypted PDF passwords: if you set a default password for protected invoices, we store it encrypted.
• No bank or supplier passwords: Pairoli has no access to your bank or credit card and stores no login details for your suppliers.

Pairoli only uses cookies that are needed for the website and the app to work, or that remember a choice you made. We don’t use analytics cookies, advertising cookies or third-party trackers. That is why we don’t ask for your consent for cookies.

Under the GDPR you have the following rights:

• Access: you may know which of your data we process.
• Rectification: if your data is wrong, you or we correct it.
• Erasure: you can ask us to delete your data, unless we are legally required to keep it.
• Restriction: you can ask us to temporarily restrict processing, for example while we assess a correction.
• Portability: you can get your data in a common format, so you can take it with you.
• Objection: you can object to processing based on our legitimate interest.

You can exercise your rights by emailing privacy@pairoli.com. We respond within one month. To prevent someone else from requesting your data, we may ask you to confirm that the request comes from you. If your request concerns invoices or statements of a Pairoli customer, we forward it to that customer, as they are responsible for that data.

Not happy with how we handle your data? Let us know at privacy@pairoli.com and we’ll look for a solution together. You also always have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) or the supervisory authority in your own EU country.

We update this privacy statement when Pairoli or the law changes. The date at the top shows when that last happened. For important changes, such as a new sub-processor, we let you know by email in advance.