Privacy Policy

1. Interpretation and Definitions

Company

(“Skrooge”, “we” or “us”) refers to SKROOGE ACCOUNTING – L.L.C – S.P.C, Abu Dhabi, Zone Nawat Building, 5th Floor, 3 Al Mawasim St, Al Hisn, W7 01, Unit No. 414.

Country

refers to the United Arab Emirates.

Services

means our website skrooge.ai, the Skrooge App (app.skrooge.ai), the Skrooge Bot on WhatsApp (+971 54 991 0620) and Telegram (@skrooge_ai_bot), the Skrooge Gmail connection and the Skrooge Chrome extension, and our accounting, bookkeeping and tax services.

You

means the individual or legal entity using the Services.

Personal Data

means any information that relates to an identified or identifiable individual.

Usage Data

is data collected automatically when you use the Services.

Cookies

are small data files stored on your device.

Service Providers

are third-party companies that process data on our behalf to help us provide the Services.

2. Types of Data Collected

Personal Data

may include:

• Email address
• First and last name
• Phone number
• Company name and registration details
• Business licence, tax or identification numbers
• Passport copies or other ID documents (for identity verification)
• Banking or payment details (for invoicing or billing)

Data you share with us to receive the Services

may include:

• Documents and messages you send through the Skrooge App or the Skrooge Bot
• Emails forwarded to us from your mailbox
• Bank statements and transactions
• Data we pull from Zoho Books and from accounts you connect, such as Ziina or Stripe

This data may include personal data about other people, such as your staff, suppliers or customers. By sharing it, you confirm that you are allowed to share it with us.

Usage Data

may include:

• IP address
• Browser type and version
• Time and date of visit
• Device identifiers
• Pages visited

Tracking technologies: we use cookies, beacons, tags and scripts to analyse usage and improve your experience. See section 8.

3. Use of Personal Data

We use your data to:

• Register and authenticate accounts
• Provide our accounting, bookkeeping and tax services, including posting entries to your books and running compliance checks
• Improve the accuracy of Skrooge’s proprietary AI/ML systems, with your permission (see section 6)
• Communicate with you about our Services, updates or offers
• Prevent fraud or misuse of the Services
• Analyse usage and develop new features
• Comply with legal obligations

You may receive service-related or marketing messages unless you opt out.

4. Disclosure of Information

We share data only with Service Providers that help us deliver the Services:

• Amazon Web Services (AWS): hosting, storage, email delivery, document text recognition (AWS Textract) and AI models from Anthropic run inside AWS Bedrock
• Zoho Books: your accounting ledger
• Anthropic, OpenAI and Mistral: AI processing
• Meta (WhatsApp) and Telegram: if you message us on WhatsApp or Telegram. They carry these messages under their own terms.

To run our business, we also use a customer relationship management system and email and messaging tools for sales and support, which hold your company’s contact details and our correspondence with you, and a product analytics service (PostHog), which records how you use the Skrooge App. None of these receive your accounting documents or transactions.

Our Service Providers process data only on our instructions.

We may also share data:

• When UAE law, a court or a government authority requires it
• As part of a business transaction, such as a merger or sale, under the same protections
• With your consent or at your direction, for example with your auditor, your bank or your new accounting provider

We do not sell your data.

5. Retention of Data

We keep your data for as long as you use our Services. When you leave, we hand over your Zoho Books organisation and the documents we hold to you or to the accounting provider you choose. After the handover, keeping your records for the period required by law is your responsibility.

For 30 days after the handover, you can ask us for a copy of anything we still hold. After that, we no longer guarantee access, and we delete your data. Encrypted backups containing it expire within a further 35 days.

We keep data after that only in two cases:

• If you allowed us to use it to improve our systems (see section 6), until you withdraw that permission.
• Where the law requires it, such as your identity verification records, which UAE anti-money-laundering rules require us to hold for five years, and the invoices we issued to you.

6. AI and Automated Processing

Skrooge’s AI reads your documents, transactions and messages to post journal entries in your accounting books and run compliance checks.

• Our AI providers. AWS (Bedrock and Textract), Anthropic, OpenAI and Mistral receive only the data needed for each task, such as a document or a batch of transactions. They use it only to return a result and to check for misuse. AWS keeps no copy after returning the result. Anthropic, OpenAI and Mistral delete their copy within 30 days by default, unless a request is flagged for misuse.
• Other companies’ AI models. Your data is never used to train AI models owned or offered by other companies, including our AI providers.
• Skrooge’s proprietary AI/ML systems. With your permission, which you give when you accept our Terms & Conditions, we use the data you share with us and our accountants’ decisions on it to train and improve the accuracy of Skrooge’s proprietary AI/ML systems. These include models we build ourselves and models we build on top of open-source AI models. They run on our own infrastructure, belong only to Skrooge, and are never shared with, sold or licensed to anyone else. Your data itself is never shown to other clients. Emails our Chrome extension reads from your Gmail are excluded (see section 11).
• Withdrawing permission. You can withdraw this permission at any time by emailing support@skrooge.ai. We will then stop using your data this way and will not keep it for this purpose after you leave. Models trained before you withdrew are not affected.
• Human review. An accountant reviews AI-assisted work before anything is filed or submitted on your behalf. If a decision that affects you is made solely by AI, you can ask for a person to review it and contest it.

7. Transfer of Data

The Skrooge App and the data you give us are stored on AWS in the United States. Your accounting ledger is kept by Zoho Books in the Zoho data centre chosen for your organisation. Our AI providers process requests in the United States (Anthropic, OpenAI, AWS Textract), the European Union (Mistral) and, for Anthropic Claude models run through AWS Bedrock, in AWS regions worldwide; the data itself remains stored in the United States. Messages you exchange with the Skrooge Bot pass through Meta’s or Telegram’s servers, and our business tools may also store data outside the UAE.

These transfers outside the UAE rely on data processing agreements with our Service Providers that require them to protect your data to the standard set by the PDPL, and on the fact that the transfer is necessary to provide the Services you contracted. Where we rely on your consent, you may withdraw it at any time.

8. Cookies and Tracking

We use cookies and similar technologies to:

• Remember preferences and login status
• Analyse traffic patterns
• Improve security

You can control cookies through your browser settings. Some features may not work if cookies are disabled. Our Cookie Policy explains this in more detail.

9. Legal Basis for Processing

We process your data on the following legal bases under the PDPL:

• Contract: to provide the Services you signed up for
• Legal obligation: for example, identity verification and record keeping
• Consent: to improve Skrooge’s proprietary AI/ML systems and to send you marketing messages. You can withdraw consent at any time.

10. Security

We protect your data with encryption in transit and at rest, role-based access and round-the-clock monitoring. Our Security page explains how.

If a data breach is likely to cause serious harm to your privacy or the security of your data, we will notify you and the UAE Data Office promptly, as required by the PDPL.

No system is 100% secure. Please keep your login details safe.

11. Google User Data

If you connect Gmail, Skrooge accesses Google user data as follows:

• Gmail connection. To send us new emails, Skrooge asks only for permission to create a label, a filter and a forwarding rule. It cannot read your mailbox. We receive only the emails your filter forwards to your Skrooge address. They reach us as normal emails, like any email you forward to us yourself, and we treat them like other data you share with us (see section 6).
• Skrooge Chrome extension (optional). To forward emails you received before connecting, the extension asks for permission to read and send emails in your Gmail. It uses this permission only to find the emails that match your filter and forward them to your Skrooge address.

We use emails the extension reads only to provide the Services to you and never use them to train AI models used for other clients. We never sell any of your emails or use them for advertising. Our team reads your emails only to provide the Services you asked for, for security, or where the law requires it.

Skrooge’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Our Gmail integration has passed Google’s annual security assessment (CASA Tier 2).

You can switch off the Gmail connection or remove the extension at any time, and revoke Skrooge’s access in your Google Account settings.

12. Governing Law

This Privacy Policy is governed by the laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

13. Your Rights

You have the right to:

• Access your personal data
• Request correction or update of inaccurate data
• Request erasure under certain conditions
• Object to or restrict processing in specific cases
• Data portability: receive your personal data in a structured, machine-readable format where technically feasible, or have it sent to another provider
• Withdraw consent at any time without affecting past processing
• Object to automated decision-making
• Lodge a complaint with the UAE Data Office

To exercise these rights, contact us at support@skrooge.ai.

14. Children’s Privacy

Our Services are not intended for anyone under 18. We do not knowingly collect personal data from minors. If you believe a minor has given us personal data, please contact us to have it removed.

15. Changes to This Policy

We may update this Policy from time to time. We will post updates on our website and email active clients about material changes. Where a change requires your consent, we will ask for it.

16. Your Acknowledgment

By using our Services, you confirm that you have read and understood this Privacy Policy, including the international data transfers described in section 7.

17. Contact Us