Data processing agreement

Effective date: October 24, 2026

Parties and scope

This data processing agreement (“agreement”) is between your bookkeeping firm (“the firm”) and IT-TECH, which operates Cosigne (“we”, “us”). It applies whenever we handle personal information for the firm to provide Cosigne, and it adds to our terms of use. The firm accepts this agreement when it accepts the terms of use.

It is the written contract that Québec’s Act respecting the protection of personal information in the private sector requires when a business communicates personal information to a service provider (section 18.3). Where the federal Personal Information Protection and Electronic Documents Act (PIPEDA) applies, it is also the contract by which the firm makes sure the information gets comparable protection while we handle it.

Definitions

• Firm: the bookkeeping firm that creates the Cosigne account. A business owner who signs up for their own company is treated as the firm for this agreement.
• Personal information: any information about an individual that allows them to be identified, directly or indirectly.
• Client file: a client’s QuickBooks Online company that the firm connects to Cosigne through Intuit’s sign-in.
• Firm data: the personal information in the firm’s connected client files and in the firm’s work in Cosigne.
• Users: the people the firm invites to use Cosigne, such as its master bookkeeper and bookkeepers.
• Subprocessor: a service provider we use that handles firm data for us.
• Confidentiality incident: access to, use or communication of personal information not authorized by law, the loss of personal information, or any other breach of its protection.

Roles

The firm is the party responsible for firm data. It decides which client files to connect, who may use them and for what. We are its service provider: we handle firm data only on the firm’s behalf, to provide Cosigne.

Intuit, Anthropic and OpenAI are not our subprocessors. Intuit provides QuickBooks Online, the source of the data, which the firm connects through Intuit’s sign-in. Each bookkeeper chooses to use their own AI assistant, Claude or ChatGPT, under their own agreement with Anthropic or OpenAI.

Our privacy notice covers the information about the firm’s own account and its users.

Whose information, and what

Firm data can be about:

• the firm’s clients;
• the people named in the clients’ books: their customers, vendors, employees and others;
• the firm’s users.

It includes:

• a full copy of each connected client file’s QuickBooks records, kept in sync: the company’s information and address; the chart of accounts; tax codes, rates and agencies; customers and vendors, with the names, addresses, emails and other contact details recorded in QuickBooks; items, classes, departments, terms and payment methods; and transactions (purchases, bills, invoices, sales receipts, journal entries, deposits, payments, bill payments, credit memos, vendor credits, transfers and refund receipts), 12 months of which are copied;
• a summary of each transaction for search: date, document number, customer or vendor name, total, currency, memo and accounts;
• the sign-in tokens Intuit issues for each connected client file, stored encrypted;
• the firm’s work: drafts, rules, answers to questions, review summaries, exports and settings;
• an activity log of who did what and when, including the details given for each action;
• the users’ names, email addresses, roles and client restrictions, the firm’s name, and its AI assistant connections (connection tokens are stored only as hashes).

Purposes and instructions

We handle firm data only to provide Cosigne as described in the terms of use, and on the firm’s instructions. The firm gives its instructions through the service, for example by connecting or disconnecting client files, restricting bookkeepers to their clients, approving or refusing drafts and deleting data, or in writing to the contact below.

We do not sell firm data, use it for advertising or use it to train AI models.

We do not send firm data to any AI provider ourselves: the app has no AI chat of its own. When a bookkeeper connects their own AI assistant, the data it reads goes to that bookkeeper’s account with Anthropic (for Claude) or OpenAI (for ChatGPT), under their agreement with that provider. That is the firm’s choice; see “Where firm data is stored, and what leaves Canada” below.

If we believe an instruction breaks the law, we will tell the firm and may decline to follow it.

Confidentiality

Only the people at IT-TECH who need firm data to run, support or secure Cosigne can access it, and each of them is bound by a written confidentiality obligation.

Security measures

• One database per firm. Firms never share a database.
• A bookkeeper restricted to some clients can’t reach the others by any path, including their AI assistant.
• Each firm is backed up, encrypted with its own key. Restores are tested automatically. Backups are kept 35 days.
• Deleting a firm destroys its key. Its backups become unreadable within 35 days.
• Intuit sign-in tokens are stored encrypted. Intuit and payment keys are kept out of the code, and users never see developer keys. Intuit and Stripe keys are stored on the server in files only its administrator can read, and are given to the app as Docker secrets.
• AI assistant connection tokens are stored only as hashes. Access tokens last one hour and are rotated; a reused token revokes the connection.
• One part of the system writes to QuickBooks, and only after a bookkeeper approves. Closed periods are never changed.

Subprocessors

The firm authorizes us to use these subprocessors:

• OVHcloud: hosting of the app server, the firms’ live databases and the encrypted backups, in Beauharnois, Québec.
• Resend: sending the app’s emails (sign-up confirmations, invitations, password resets, billing notices and deletion warnings).
• Stripe: card payments and billing. Stripe receives billing data only.

Each subprocessor is bound by written terms that protect the information at least as well as this agreement.

We will tell the firm by email at least 30 days before we add or replace a subprocessor, and update the list on this page. The firm may object in writing during that period. If we can’t address the objection, the firm may cancel its subscription before the change applies, and export its data first.

Where firm data is stored, and what leaves Canada

Firm data is stored in Canada: the app server and the firms’ live databases are at OVHcloud’s data centre in Beauharnois, Québec. The encrypted backups are kept at OVHcloud in Beauharnois, Québec.

Some information is processed outside Québec and Canada:

• Emails: Resend is based in the United States, so an email’s contents, including the recipient’s address and name, the firm’s name and the message, may be processed outside Canada.
• Billing: Stripe may process billing data outside Canada, under its own privacy policy.
• AI assistants: when a bookkeeper uses their own Claude or ChatGPT, the data it reads is sent to that bookkeeper’s account, under their agreement with Anthropic or OpenAI, and leaves Canada.

The decision to let the firm’s bookkeepers use an AI assistant is the firm’s. The firm is responsible for assessing it, including any privacy impact assessment the Act requires before personal information is communicated outside Québec. We support that assessment with documentation: what the connector lets an AI assistant read, how client restrictions apply in it, and how drafts and approvals work. For the information processed outside Canada by Resend and Stripe, we give the firm the details it needs for its own assessment.

Confidentiality incidents

If we have reason to believe that a confidentiality incident involving firm data has occurred, or that someone has tried to breach the confidentiality of firm data, we will tell the firm’s master bookkeeper without delay, and no later than 72 hours after we become aware of it.

We give the firm the information it needs to record the incident in its register and to decide whether to notify the Commission d’accès à l’information and the people concerned: what happened and when, which information and which people are involved, the risk of serious harm we see, and what we have done to reduce it. We take reasonable measures to reduce the risk of harm and to prevent a new incident, and we keep the firm informed.

Requests from individuals

The firm answers requests from the people whose information is in its clients’ books, such as requests for access, correction, or a copy in a structured, commonly used technological format. We help it answer them:

• the firm can read and export its data from the service at any time, including while it is read-only;
• corrections to a client’s books are made in QuickBooks, directly or through drafts a bookkeeper approves, and the copy in Cosigne follows when it syncs;
• we delete firm data on the firm’s request.

If a person contacts us directly about firm data, we send the request to the firm without delay and do not answer it ourselves unless the firm asks us to.

Retention, return and deletion

• We keep firm data while the firm has an account, so the service works.
• The firm can read and export its data at any time, including while it is read-only.
• A disconnected client file stops syncing; its copied data is deleted after 30 days unless it is reconnected.
• If a trial ends without a card, a subscription is unpaid or the firm cancels, the firm becomes read-only. We send warnings on day 23 and day 29, and delete the firm on day 30. Adding a card before then restores everything.
• Deleting a firm destroys its encryption key. Its backups become unreadable within 35 days.
• We do not keep firm data after the agreement ends, except where the law requires us to.

Audits and information requests

On the firm’s written request, we answer its reasonable questions about how we protect firm data, and allow the checks it needs to verify that we meet this agreement’s confidentiality requirements.

Liability

Each party’s liability under this agreement is as set out in our terms of use.

Term and termination

This agreement applies while the firm has a Cosigne account, on the free trial or a subscription. It ends when the subscription ends, but its obligations continue until we have deleted the firm data as described above.

Precedence

If this agreement and the terms of use disagree on a matter of personal information, this agreement prevails.

Governing law

This agreement is governed by the laws of Québec and the laws of Canada that apply there.

Language

This agreement is available in French and English. Both versions are equally valid.

Changes to this agreement

We will post any change on this page with a new effective date. We will tell firms by email before a significant change applies.

Contact

Our person in charge of the protection of personal information can be reached at info@getcosigne.com.