Privacy Policy

Section 01Who we are

Duoledger is Making Tax Digital bookkeeping software for people with UK property income, self-employment income, or both. The service is provided by Duoledger Ltd, a company registered in England and Wales (company number 17450275, registered office 61 Albert Bridge Road, London SW11 4QA).

For the personal data described in this policy, Duoledger Ltd is the data controller. We are registering with the Information Commissioner's Office (ICO) as a data controller and will publish our registration reference on this page as soon as it is issued. Our data protection contact is privacy@duoledger.co.uk.

We are not required to appoint a statutory Data Protection Officer, but a named person is accountable for privacy at Duoledger and answers every request sent to the address above.

Section 02The short version

The rest of this policy sets out the detail required by the UK GDPR and the Data Protection Act 2018, including our lawful bases, our processors and your rights.

Section 03The data we collect

We collect only what the service needs to work. In practice that falls into eight groups.

Special category and criminal offence data

We do not ask for special category data. Bookkeeping records can incidentally reveal such information — for example a transaction description that names a medical provider, or a tenant's details you record in a note. Please avoid entering more than you need. Where such content does appear, we process it only as part of providing the bookkeeping service to you and apply the same protections described in section 11.

Data about other people

Your records may contain personal data about tenants, clients, suppliers or co-owners. For that data you are the controller and we act as your processor, handling it only on your instructions and for the purposes of running the service. You are responsible for having a lawful basis to enter it and for telling those people how their data is used where required.

Section 04Why we use your data, and our lawful basis

Under the UK GDPR we need a lawful basis for every use of personal data. Ours are set out below.

Where we rely on legitimate interests you can ask us for our balancing assessment, and you can object at any time using the contact details in section 16.

Section 05Open Banking and bank feeds

Bank feeds are optional. If you use them, we connect through TrueLayer, an account information service provider authorised and regulated by the Financial Conduct Authority. Only FCA-authorised firms are permitted to access bank data through Open Banking APIs in the UK.

• You authenticate directly with your bank. Duoledger never sees or stores your online banking credentials.
• Access is read-only. We cannot move money, set up payments or change anything in your bank account.
• We request account details, balances and transaction history only for the accounts you select.
• You can withdraw consent at any time in Duoledger, or in your bank's app or online banking. We stop retrieving new data as soon as the consent is revoked.
• Under FCA rules, ongoing access requires periodic reconfirmation rather than re-authentication with your bank every 90 days (TrueLayer explains the change). We will prompt you when a reconfirmation is due.

Imported transactions are categorised automatically where we are confident, and routed to a review inbox where we are not. No import is filed to HMRC without your explicit review and instruction. Revoking a bank connection does not delete transactions already imported into your books, because those are now your accounting records; you can delete them yourself, or ask us to.

Section 06Receipt capture and automated processing

When you upload a receipt or invoice, the image is stored in a private, per-user location and passed to an AI extraction service to read the vendor, date, amount and description. The result is shown to you as an editable preview, and nothing is written to your books until you confirm it.

• Extraction currently runs on Cloudflare Workers AI, processed as an inference request rather than retained by the model provider for training.
• We do not use your receipts, transactions or bookkeeping records to train our own models.
• Automated categorisation and OCR are decision support, not automated decision-making with legal effect. Every figure remains editable and you are the one who confirms it.
• You can delete an uploaded receipt at any time. Deleting the receipt does not automatically delete a transaction you created from it.

Section 07HMRC submissions and anti-fraud data

If you connect your HMRC account, you grant Duoledger permission through HMRC's own authorisation screens to read your obligations and send updates on your behalf. We store the resulting access and refresh tokens encrypted, and you can disconnect at any time in Duoledger or in your HMRC account.

HMRC requires every piece of MTD software to send fraud prevention headers with each API call. These describe the device and connection used to submit — for example device identifiers, operating system and browser version, screen size, timezone, local and public IP addresses and licence identifiers. We are legally obliged to send them accurately, and we cannot switch them off. HMRC processes that data under its own privacy notice for the prevention and detection of fraud.

Duoledger is registered with HMRC's Software Developer Support Team and is working through the recognition process for Making Tax Digital for Income Tax. Until recognition completes, you can keep your books in Duoledger and file through your existing route; no data migration is needed when filing becomes available.

Section 08Who we share your data with

We do not sell personal data and we do not share it for third-party advertising. We use a short list of service providers, each under a written contract that limits them to processing on our instructions.

We may also disclose data:

• to an accountant, agent or co-owner you invite or authorise;
• to professional advisers, auditors, insurers or our own accountants where necessary;
• where required by law, court order or a lawful request from a regulator or tax authority;
• to a buyer or successor if the business or part of it is sold or reorganised, in which case we will tell you before your data becomes subject to a different privacy policy.

This list is kept current. If we add or replace a processor that materially affects how your data is handled, we will update this page and, where the change is significant, tell you by email.

Section 09International transfers

We aim to keep customer records in the UK or the EEA. Some providers listed above operate or support their services from outside the UK. Where personal data leaves the UK, we rely on one of the following safeguards:

• UK adequacy regulations, including the UK Extension to the EU–US Data Privacy Framework where the provider is certified;
• the International Data Transfer Agreement, or the EU Standard Contractual Clauses together with the UK Addendum;
• a transfer risk assessment plus technical measures such as encryption in transit and at rest.

You can request a copy of the relevant safeguard for any provider by emailing us.

Section 10How long we keep your data

You can export your books at any time from within the app, and we recommend doing so before you close your account.

Section 11How we protect your data

• Encryption in transit using TLS 1.3, and at rest using AES-256.
• Row-level authorisation enforced on the server for every read and write, so records are scoped to the account that owns them.
• Integration secrets and HMRC tokens held in a dedicated encrypted store, not in application code or plain database columns.
• Monetary values stored as integer pennies to prevent rounding drift in your records.
• Least-privilege administrative access, multi-factor authentication on internal accounts, and audit logging of privileged actions.
• Automated backups with restore testing, and change control over deployments.
• No storage of full card numbers anywhere in our systems — card data is handled by Stripe.

No system is completely secure. If a personal data breach is likely to result in a risk to your rights and freedoms, we will report it to the ICO within 72 hours of becoming aware and tell you without undue delay where the risk is high. You help by using a strong, unique password, enabling any available second factor, and telling us promptly at privacy@duoledger.co.uk if you suspect unauthorised access.

Section 12Cookies and similar technologies

We use a small number of cookies and equivalent local storage. Strictly necessary items — session and authentication, security, load balancing, and remembering your cookie choice — are set without consent because the service cannot work without them.

Anything else, including product analytics and advertising measurement, is set only if you accept it in our cookie banner. You can change or withdraw your choice at any time through the banner controls, and you can clear cookies in your browser settings. Declining non-essential cookies does not limit any bookkeeping feature.

Where we run advertising measurement, we configure it in consent mode so that no measurement events are sent before you agree, and we do not upload your bookkeeping or bank data to any advertising platform.

Section 13Marketing

We send service emails you cannot opt out of while you hold an account — for example payment receipts, security notices, deadline reminders tied to your obligations, and material changes to these terms.

Product news, tips and offers are separate. We send them only where you have opted in, or where you are an existing customer and the message concerns similar services under the soft opt-in in the Privacy and Electronic Communications Regulations. Every marketing email carries an unsubscribe link, and you can also email us to stop them. Unsubscribing from marketing does not cancel your subscription.

Section 14Your rights

Under UK data protection law you have the right to:

• Be informed — through this policy and the notices in the app.
• Access a copy of the personal data we hold about you.
• Rectification of inaccurate or incomplete data.
• Erasure where we no longer need the data and no legal obligation requires us to keep it.
• Restriction of processing while a dispute about accuracy or basis is resolved.
• Portability — receive the data you gave us in a structured, commonly used, machine-readable format, or have it sent to another provider where technically feasible.
• Object to processing based on legitimate interests, and to direct marketing at any time with no exceptions.
• Withdraw consent where consent is our basis, such as bank connections and non-essential cookies.
• Not be subject to solely automated decisions with legal or similarly significant effects. We do not make such decisions.

Much of this is self-service: you can view and edit your records, export your books, manage bank and HMRC connections, and delete your account from within the app. For anything else, email privacy@duoledger.co.uk. We respond within one month and will tell you if we need to extend that by up to two further months for a complex request. There is no charge unless a request is manifestly unfounded or excessive. We may ask for proof of identity before releasing data.

Section 15Children, and changes to this policy

Children

Duoledger is for adults running a property or self-employment business. The service is not directed at children and we do not knowingly collect data from anyone under 18. If you believe a child has created an account, tell us and we will remove it.

Third-party sites

Our pages link to sites we do not control, such as GOV.UK, HMRC and our providers. Their privacy practices are their own and this policy does not cover them.

Changes

We update this policy as the product develops — the live bank feed and HMRC filing modules are current examples. The version and date at the top always reflect the current text. For material changes we will notify account holders by email or an in-app notice at least 14 days before they take effect, unless a change must be made sooner for legal or security reasons. Previous versions are available on request.

Section 16Contact and complaints

See also our Terms and Conditions, which govern your use of Duoledger.