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Privacy Notice

How COHESORA handles personal data. For the INVICTT website's own notice see invictt.com/privacy.

Draft — not in force. Draft 0.1 · Not in force — no effective date has been set · Awaiting review by a qualified lawyer (UK data-protection and commercial law).

Client portal users

If your accountant invited you to the COHESORA client portal, COHESORA stores your name, e-mail address, password hash, optional MFA secret (encrypted), sign-in history, the documents and messages you send and when you open them — on your accounting firm's behalf. Your firm is the controller for this data. See Client portal terms.

1. Who is responsible

For data that accounting firms place in COHESORA about their clients and staff, the firm is the controller and INVICTT AI is the processor (see the DPA). For account and usage data of the people who sign up (name, work email, role, sign-in records), INVICTT AI is the controller. Entity: INVICTT AI. The legal entity name, registration number and registered address are not yet published and must be added before these documents can take effect.

2. What COHESORA stores

3. What COHESORA does not do

4. Why data is processed

To provide the service the firm asked for, to secure it, to send operational emails (verification, password reset, invitations, trial notices), and to meet legal obligations. The exact lawful bases are a legal decision (see below).

5. Where data goes

See Subprocessors. In summary: database in the EU (Paris), documents on a server operated by INVICTT AI, web delivery and proxying by Netlify and Cloudflare, transactional email by Resend, and Xero only when a firm connects it.

6. Retention and deletion

See the Data retention and deletion policy.

7. Your rights

Individuals can ask their accounting firm (the controller) about their data. Requests relating to account data held by INVICTT AI can be made through invictt.com/contact. The process and response times require approval.

Decisions required before this can take effect

Matters for professional legal approval or for INVICTT AI to determine. They are deliberately not answered here.