Data Privacy & Protection Policy¶
| Field | Value |
|---|---|
| Owner | Puneet Gupta (Co-Founder) |
| Classification | Internal (shareable under NDA) |
| Version | 1.0 |
| Effective date | 2026-06-11 |
| Next review | 2027-06-11 |
1. Purpose¶
Define how Revzio protects personal data and complies with applicable data protection obligations when processing data through the Pixis FinOps platform.
2. Role: processor¶
For customer data, Revzio acts as a data processor, processing personal data only on the documented instructions of the customer (the data controller). Responsibilities such as obtaining consent from data subjects and determining lawful basis rest with the controller.
3. Principles¶
Revzio applies the following data protection principles:
- Lawfulness & purpose limitation — data is processed only to deliver the contracted service (financial reconciliation / FinOps).
- Data minimization — only the financial/ERP/billing records and limited user identity data necessary for the service are ingested.
- Accuracy — data reflects the source systems it is synchronized from.
- Storage limitation — data is retained only as long as needed (see Data Retention & Disposal Policy).
- Integrity & confidentiality — data is protected by encryption, tenant isolation, and access control (see Encryption and Access Control policies).
- Accountability — processing activities are recorded.
4. Categories of data processed¶
- Customer/tenant financial and accounting records: invoices, bills, subscriptions, payments, bank transactions, and vendor/customer master data.
- Integration credentials (encrypted).
- Limited user identity data of the customer's own users (name, email).
5. Records of Processing Activities (RoPA)¶
Processing and synchronization activity is recorded by the platform (sync history, audit, and revision logs). The register below records the processing Revzio performs as processor:
| # | Processing activity | Purpose | Data categories | Subprocessors | Retention |
|---|---|---|---|---|---|
| 1 | Financial / ERP reconciliation & sync | Deliver the contracted FinOps / reconciliation service | Invoices, bills, subscriptions, payments, bank transactions, vendor/customer master data | Supabase (database); customer ERP / billing systems (Zoho, QuickBooks, NetSuite, Oracle, Stripe) | Duration of engagement; deleted on termination |
| 2 | Document extraction & field mapping | AI-assisted extraction / mapping of uploaded documents | Contract / invoice text, vendor details | OpenAI, Google (Gemini) — paid tier, data not used for model training | Duration of engagement |
| 3 | User authentication & identity | Platform account access | Name, email | Google (auth), Supabase | Duration of the account |
The register is reviewed on any change to processing activities or subprocessors.
6. Data subject rights¶
The platform isolates tenant data (Row-Level Security) so that data for a specific customer or individual can be located, exported, or deleted on request, enabling Revzio to support the controller in fulfilling data-subject access, rectification, and erasure requests.
7. Data Protection Impact Assessments (DPIA)¶
As a processor acting on controller instructions, high-risk processing assessment is primarily the controller's responsibility. Revzio will conduct or contribute to DPIAs where its processing warrants it; a DPIA procedure is being established. (Planned.)
8. Subprocessors¶
Personal data may be processed via vetted subprocessors under data-processing agreements. See the Subprocessor Register and Third-Party Risk Management Policy.
9. International transfers & breach¶
Where data is transferred across borders, appropriate safeguards are applied per the customer agreement. Personal-data breaches are handled under the Incident Response Plan, including notification to the controller without undue delay.
Revision history¶
| Version | Date | Author | Change | Approved by |
|---|---|---|---|---|
| 1.0 | 2026-06-11 | Puneet Gupta | Initial draft | Puneet Gupta (Co-Founder) |