# ReconLoom Privacy Notice

**Operator:** ReconLoom (Sole Entrepreneur, operating remotely)  
**Effective date:** 2026-10-11  
**Last updated:** 2026-10-11  
**Privacy contact:** privacy@reconloom.com  
**Security reports:** security@reconloom.com

## 1. Who we are
ReconLoom is a local-first reconciliation product for Excel and CSV exports. It is operated by ReconLoom, a Sole Entrepreneur operating remotely. This notice describes how we handle information in connection with the Free, Demo and Pro Trial services. Paid Pro checkout is not currently available.

This notice is written to be readable across jurisdictions. It describes our data-handling practices in terms that align with the General Data Protection Regulation (GDPR) applicable in the European Economic Area and the United Kingdom, the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA), India's Digital Personal Data Protection Act 2023 (DPDP Act), and common data-protection frameworks used in the Middle East and Asia. Where a specific jurisdiction imposes additional or differing requirements, those requirements govern to the extent they apply.

## 2. What data we process
**Reconciliation source files and rows.** Uploaded CSV, XLS and XLSX files, filenames, worksheet names, spreadsheet cells, rows, column headers, transaction values, bank or account values, reconciliation results and review contents are processed on the user's device. They are not sent to ReconLoom servers as part of reconciliation.

**Local recovery data.** To support recovery, ReconLoom may store run metadata, source-file fingerprints, mappings, rules, review decisions, finalization state, templates and export receipts on the user's device using IndexedDB and, for large workloads, the Origin Private File System (OPFS).

**Trial and entitlement metadata.** Trial records use the email and pseudonymous device information needed to verify access, enforce trial limits and prevent abuse.

**Analytics.** Limited analytics may include an anonymous browser identifier, event type, page or path, referrer or acquisition source, UTM campaign metadata and country derived by the hosting provider.

**Pro-interest email.** An email submitted through the Pro-interest feature is encrypted and retained for up to two years.

**Support email contents.** Contents of support requests are received by the support provider for reply and investigation.

## 3. Legal bases and purposes
This table describes our intended legal bases under frameworks such as the GDPR. It is a statement of our intended approach, not a claim that each basis has been independently verified or approved. Where a specific jurisdiction requires a different basis or additional safeguards, those requirements govern to the extent they apply.

| Category | Purpose | Intended legal basis |
| --- | --- | --- |
| Reconciliation source files and rows | Matching, review, export, recovery | Processed on the user's device; no transfer to us |
| Local recovery data | Recovery and user-selected reuse | User-controlled local storage |
| Trial and entitlement metadata | Verification, entitlement, abuse prevention | Legitimate interest in enforcing published limits |
| Analytics | Traffic, acquisition and conversion analysis | Legitimate interest; configurable |
| Pro-interest email | Product interest follow-up | Consent via submission |
| Support email contents | Reply and investigation | Legitimate interest in providing support |

## 4. Data minimization and retention
Source rows are processed on the device and are not transmitted. Analytics events are retained for up to 90 days. Pro-interest emails are retained for up to two years. Trial-limit records may be retained separately to enforce usage limits. You can clear saved local run information through product controls or browser storage settings.

## 5. Your rights
For applicable access, correction, deletion, portability, restriction, objection or opt-out requests, contact privacy@reconloom.com. Verify identity proportionately. Do not ask users to email sensitive source files. Deleting browser storage does not automatically delete trial, analytics, billing-interest or support records stored by separate services.

**GDPR (EEA/UK):** intended rights of access, rectification, erasure, restriction, portability and objection. You may also withdraw consent at any time where processing relies on it. Response procedures have not been independently verified.

**CCPA/CPRA (California):** intended rights to know, delete, correct, opt out of the sale or sharing of personal information, and limit the use of sensitive personal information. We do not sell personal information. Response procedures have not been independently verified.

**India DPDP Act:** intended rights of access, correction, erasure, grievance redressal and to nominate an individual to exercise rights on another's behalf. Response procedures have not been independently verified.

**Middle East and Asia:** rights vary by jurisdiction. Contact privacy@reconloom.com to exercise any applicable right. Jurisdiction-specific response procedures have not been independently verified.

## 6. International transfers
ReconLoom uses service providers to process limited trial, analytics and hosting metadata. The locations of processing, applicable transfer rules, provider contractual arrangements and any required safeguards have not yet been fully verified. ReconLoom does not currently claim that all international-transfer obligations have been satisfied.

Reconciliation source rows are processed on the user's device and are not transferred internationally.

## 7. Security
Apply data minimization, authenticated entitlement access and software hardening, but no software can guarantee absolute security. Report suspected vulnerabilities to security@reconloom.com without including real customer data.

## 8. Changes
This notice may be updated. The effective date reflects the current version. Material changes will be reflected in the updated effective date and, where required, by notice to affected users.

## 9. Contact
Privacy questions: privacy@reconloom.com. Security reports: security@reconloom.com. Product support: support@reconloom.com.