Privacy Policy

Last updated: 6 September 2026 · Deutsch

This policy explains how PivotalPoint OÜ (“we”) handles personal data when you use the FinVerify conversion service (the “Service”). It is written to be read, not skimmed. Where it makes a promise, the promise is specific.

1. Controller

PivotalPoint OÜ, Estonia. Contact: finverify@pivotalpoint.io. The Swiss Federal Act on Data Protection (FADP) and the GDPR apply. A named person at PivotalPoint performs the review; that person is identified on request.

2. What we process

  • Your uploaded bank statements and the converted output (Excel, CSV or camt.053). These contain financial and personal data about you or, if you upload a third party’s statement, about that third party.
  • Your delivery email address, your answers to the questionnaire (output format, whose account, why camt is unavailable, notes), the payment reference from Stripe, and a truncated hash of your IP address.
  • Payment data is processed by Stripe under its own terms. We never see your card number.

3. Why, and on what legal basis

  • To perform the conversion and reconciliation you paid for (performance of a contract).
  • To send you the result and a receipt (performance of a contract).
  • To prevent abuse of the upload endpoint (legitimate interest; limited to the truncated IP hash).
  • Optional AI pre-processing, only if you tick the opt-in box at upload (consent, revocable until processing starts).

If you upload a third party’s statement, you confirm that you are authorised to have it processed. We act as your processor for that data.

4. Where the data is

Uploaded files, converted output and questionnaire answers are stored in Google Cloud Storage in Zurich, Switzerland (region europe-west6). The upload endpoint runs in the same region. No copy is made to any other region.

Exception you control: if you tick the AI opt-in, the text layer of your statement is sent to Google’s Gemini API for extraction. Google may process it outside Switzerland and the EU. Without the opt-in, extraction is manual or runs on infrastructure in Zurich.

5. How long we keep it

  • Uploaded files and converted output: deleted within 24 hours after delivery. As a backstop, the storage bucket deletes every object automatically after 72 hours, whether or not delivery happened.
  • Questionnaire answers, without the files: kept for up to 12 months in aggregate form (format requested, whose account, reason camt was unavailable) to decide whether the Service continues. Your email address is removed from this record at deletion of the files.
  • Payment records: kept by Stripe and in our accounting as required by law.

6. What we never do

  • We never use your files to test, benchmark, improve or train any software or model. If we ever want a test corpus, we will ask you separately, and you can say no with no effect on the Service.
  • We never sell or share your data with anyone other than the processors below.
  • We never look at your files for any purpose other than producing your conversion.

7. Website measurement

We use Google Analytics 4 to see which pages people reach and which of them lead to an order. It sets first-party cookies in your browser (named _ga and _ga_…) that hold a randomly generated identifier, so that repeat visits from the same browser are counted once rather than twice. Google receives the page address, the referring page, your browser and device type, and an approximate location derived from your IP address; Google states that it does not log or store the IP address itself for Analytics.

Legal basis: our legitimate interest in knowing whether this site works at all. Data is processed by Google Ireland Limited and may be transferred to Google LLC in the United States under the EU Standard Contractual Clauses and the EU-US Data Privacy Framework.

This measurement is entirely separate from your uploaded statements. Analytics never receives file contents, file names, your delivery email or the answers you give on the upload form. If you would rather not be counted, any content blocker or the Google Analytics opt-out add-on stops it, and the Service works exactly the same.

8. Processors

  • Google Cloud (storage and compute, Zurich) — infrastructure.
  • Stripe — payment.
  • Google Ireland Limited — website measurement (Google Analytics), when enabled.
  • Our email provider — delivery of results and receipts.
  • Google Gemini API — only with your opt-in, for extraction.

9. Your rights

You can ask for access, correction, deletion, or a copy of your data, and object to processing, by emailing finverify@pivotalpoint.io. Because files are deleted within 24 hours of delivery, a deletion request usually confirms something that has already happened. You can complain to the Swiss FDPIC or the Estonian Data Protection Inspectorate.

10. Security

Encryption in transit and at rest, access limited to the person performing the review, no public access to the storage bucket, uniform bucket-level access, automatic expiry. No system is perfectly secure; this one is small on purpose.

11. Changes

If this policy changes, the date above changes and the new version applies to uploads made after that date.