Compliance
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ISO 27001:2022
Payment Partners (independent controllers)
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Card acquiring and payment processing. Adyen N.V. is a credit institution established in the Netherlands and supervised by De Nederlandsche Bank. Its UK branch is registered on the FCA Financial Services Register as the UK branch of an overseas firm (firm reference number 779800), authorised since 6 September 2023 and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Adyen processes payer name, payment instrument details, transaction data, and device and IP data as an independent controller for the purposes of providing its payment services, meeting its own customer due diligence obligations, and preventing fraud. Adyen publishes a dedicated privacy statement for payers whose transactions it processes.
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Open banking account information and payment initiation services. Tink Financial Services Limited is established in England (company number 12347825) and authorised by the Financial Conduct Authority under the Payment Services Regulations 2017 (firm reference number 988456). The Tink entity licensed in the payer's jurisdiction provides the service, holds the relationship with the payer, and displays its own terms and privacy notice at the point the payer connects a bank account. Tink processes account holder name, account identifiers, balance and transaction data as an independent controller for that purpose.
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Payment processing and electronic money services. Adfin contracts under the Stripe Services Agreement with Stripe Payments Europe, Limited (Ireland) for platform and technology services, and with Stripe Payments UK, Ltd (company number 08480771), which is authorised by the Financial Conduct Authority as an electronic money institution under reference number 900461 and is the sole provider of the regulated payment services and the payment method acquirer. Stripe processes payer name, payment instrument details, and transaction data as an independent controller for the purposes of providing regulated payment services, meeting its own customer due diligence and safeguarding obligations, and preventing fraud. Stripe identifies its controlling entities per service in its Privacy Center.
Subprocessors
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Amazon Web Services
- Purpose
- Cloud provider
- Location
- EU
Cloud infrastructure and hosting: Amazon Web Services EMEA SARL (Luxembourg, LU).
Data processed: All categories of Customer personal data. Processing location: EU — eu-central-1 (Frankfurt, DE).
Transfer mechanism: No restricted transfer for hosted data. EU SCCs and the UK IDTA, incorporated via the AWS Data Processing Addendum, cover support access from outside the EEA and the UK.
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Auth0
- Purpose
- Identity provider
- Location
- EU
Authentication and identity management: Okta Identity Europe Limited (Dublin, IE), with onward processing by Okta, Inc. (US)
Data processed: Authentication data, email addresses, IP addresses, device identifiers.
Processing location: Auth0 tenant region is fixed at tenant creation: EU.
Transfer mechanism: EU SCCs and UK IDTA via the Okta DPA
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Datadog
- Purpose
- Observability and telemetry
- Location
- EU
Data processed: Application and infrastructure logs, traces and metrics, which may contain IP addresses, user identifiers and request metadata
Processing location: EU
Transfer mechanism: No restricted transfer for hosted data. EU SCCs and the UK IDTA, incorporated via the Datadog DPA, cover support access from outside the EEA and the UK.
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Intercom
- Purpose
- Customer support messaging and helpdesk
- Location
- EU
Intercom R&D Unlimited Company (Dublin, IE) with onward processing by Intercom, Inc. (US)
Data processed: Support conversation content, names, email addresses, IP addresses
Processing location: EU
Transfer mechanism: No restricted transfer for hosted data. EU SCCs and the UK IDTA, incorporated via the Intercom DPA, cover support access from outside the EEA and the UK.
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HubSpot
- Purpose
- Management of Adfin's own commercial relationships
- Location
- EU
HubSpot Ireland Limited (Dublin, IE), with onward processing by HubSpot, Inc. (US)
Adfin's role: Controller. HubSpot processes, on Adfin's instructions, the names and business contact details of individuals at customer and prospect organisations, correspondence with them, and records of the commercial relationship. HubSpot does not receive personal data that customers submit to Adfin for processing through the platform — no invoice, payer, transaction or bank account data reaches it.
Processing location: EU
Transfer mechanism: No restricted transfer for hosted data. EU Commission Standard Contractual Clauses and the UK International Data Transfer Addendum, incorporated via the HubSpot Data Processing Agreement, cover support and administrative access from outside the EEA and the UK.
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PostHog
- Purpose
- Product usage analytics and session replay
- Location
- EU
PostHog, Inc. (US)
Adfin's role: Controller. PostHog processes, on Adfin's instructions, platform usage events, activity logs and identifiers relating to users of the Adfin console. It does not receive personal data that customers submit to Adfin for processing through the platform.
Session replay: Enabled, with all input fields and all dynamic text masked in the browser before any data is transmitted. Only static interface copy such as button and menu labels is captured. Payer names, invoice lines, amounts, email addresses and bank account identifiers are replaced with placeholder characters at the point of capture and never reach PostHog. Masking operates on a default-deny basis — every text element is masked unless it appears on an allowlist of static interface copy — enforced in Adfin's application code and covered by automated tests.
Retention: Session recordings retained for 31 days
Processing location: EU
Transfer mechanism: PostHog Inc. (United States) is the contracting entity and processes as data importer. Transfers rely on the EU Commission Standard Contractual Clauses and the UK International Data Transfer Addendum incorporated via the PostHog Data Processing Agreement. PostHog Inc. is additionally certified under the EU-U.S. Data Privacy Framework, its UK Extension and the Swiss-U.S. Data Privacy Framework, in each case for non-HR data.
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OpenAI
- Purpose
- AI-assisted application features
- Location
- Multiple regions
OpenAI OpCo, LLC (US) processes UK data under OpenAI’s Data Processing Addendum. OpenAI Ireland Limited (IE) processes EEA and Swiss data where applicable.
Purpose: AI-assisted collections, customer communications, invoice and document processing, customer imports and matching, task classification, and referral assessment.
Data processed: Prompts and responses may contain customer and payer names, contact details, addresses, invoice files and their contents, payment request and balance details, bank account details shown on invoices, communication templates, and case descriptions.
Processing location: Multiple regions, including the United States. No UK or EU-only processing commitment is claimed.
Transfer mechanism: EU Standard Contractual Clauses, with the UK International Data Transfer Addendum for applicable UK restricted transfers, under the OpenAI Data Processing Addendum.
Model training: OpenAI does not use API inputs or outputs to train its models by default, unless the customer opts in.
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Anthropic
- Purpose
- AI-assisted application features
- Location
- Multiple regions
Anthropic Ireland, Limited (IE) is the contracting entity for UK customers. Anthropic group companies and subprocessors may process data in other regions.
Purpose: AI-assisted collections, customer communications, invoice and document processing, customer imports and matching, task classification, and referral assessment.
Data processed: Prompts and responses may contain customer and payer names, contact details, addresses, invoice files and their contents, payment request and balance details, bank account details shown on invoices, communication templates, and case descriptions.
Processing location: Anthropic may process API data in the US, Europe, Asia, and Australia. It stores API data in the US by default.
Transfer mechanism: EU Standard Contractual Clauses, with the UK International Data Transfer Addendum for applicable UK restricted transfers, under the Anthropic Data Processing Addendum.
Model training: Anthropic’s commercial terms do not permit model training on customer content submitted through its services.
Controls
Infrastructure security
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Unique account authentication enforced
The company requires authentication to systems and applications to use unique username and password or authorized Secure Socket Shell (SSH) keys.
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Unique network system authentication enforced
The company requires authentication to the "production network" to use unique usernames and passwords or authorized Secure Socket Shell (SSH) keys.
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Remote access MFA enforced
The company's production systems can only be remotely accessed by authorized employees possessing a valid multi-factor authentication (MFA) method.
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Remote access encrypted enforced
The company's production systems can only be remotely accessed by authorized employees via an approved encrypted connection.
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Intrusion detection system utilized
The company uses an intrusion detection system to provide continuous monitoring of the company's network and early detection of potential security breaches.
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Network segmentation implemented
The company's network is segmented to prevent unauthorized access to customer data.
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Access control procedures established
The company's access control policy documents the requirements for the following access control functions:
- adding new users;
- modifying users; and/or
- removing an existing user's access.
Organizational security
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Employee background checks performed
The company performs background checks on new employees.
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Code of Conduct acknowledged by employees and enforced
The company requires employees to acknowledge a code of conduct at the time of hire. Employees who violate the code of conduct are subject to disciplinary actions in accordance with a disciplinary policy.
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Confidentiality Agreement acknowledged by employees
The company requires employees to sign a confidentiality agreement during onboarding.
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MDM system utilized
The company has a mobile device management (MDM) system in place to centrally manage mobile devices supporting the service.
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Code of Conduct acknowledged by contractors
The company requires contractor agreements to include a code of conduct or reference to the company code of conduct.
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Confidentiality Agreement acknowledged by contractors
The company requires contractors to sign a confidentiality agreement at the time of engagement.
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Security awareness training implemented
The company requires employees to complete security awareness training within thirty days of hire and at least annually thereafter.
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Asset disposal procedures utilized
The company has electronic media containing confidential information purged or destroyed in accordance with best practices, and certificates of destruction are issued for each device destroyed.
Product security
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Control self-assessments conducted
The company performs control self-assessments at least annually to gain assurance that controls are in place and operating effectively. Corrective actions are taken based on relevant findings. If the company has committed to an SLA for a finding, the corrective action is completed within that SLA.
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Vulnerability and system monitoring procedures established
The company's formal policies outline the requirements for the following functions related to IT / Engineering:
- vulnerability management;
- system monitoring.
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Data encryption utilized
The company's datastores housing sensitive customer data are encrypted at rest.
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Penetration testing performed
The company's penetration testing is performed at least annually. A remediation plan is developed and changes are implemented to remediate vulnerabilities in accordance with SLAs.
Internal security procedures
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Continuity and Disaster Recovery plans established
The company has Business Continuity and Disaster Recovery Plans in place that outline communication plans in order to maintain information security continuity in the event of the unavailability of key personnel.
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Continuity and Disaster Recovery plans tested
The company has a documented Business Continuity/Disaster Recovery (BC/DR) plan and tests it at least annually.
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Configuration management system established
The company has a configuration management procedure in place to ensure that system configurations are deployed consistently throughout the environment.
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Development lifecycle established
The company has a formal systems development life cycle (SDLC) methodology in place that governs the development, acquisition, implementation, changes (including emergency changes), and maintenance of information systems and related technology requirements.
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Management roles and responsibilities defined
The company management has established defined roles and responsibilities to oversee the design and implementation of information security controls.
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Organization structure documented
The company maintains an organizational chart that describes the organizational structure and reporting lines.
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Security policies established and reviewed
The company's information security policies and procedures are documented and reviewed at least annually.
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Access reviews conducted
The company conducts access reviews at least quarterly for the in-scope system components to help ensure that access is restricted appropriately. Required changes are tracked to completion.
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Access requests required
The company ensures that user access to in-scope system components is based on job role and function or requires a documented access request form and manager approval prior to access being provisioned.
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Incident response plan tested
The company tests their incident response plan at least annually.
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Incident response policies established
The company has security and privacy incident response policies and procedures that are documented and communicated to authorized users.
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Risk management program established
The company has a documented risk management program in place that includes guidance on the identification of potential threats, rating the significance of the risks associated with the identified threats, and mitigation strategies for those risks.
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Backup processes established
The company's data backup policy documents requirements for backup and recovery of customer data.
Data and privacy
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Data retention procedures established
The company has formal retention and disposal procedures in place to guide the secure retention and disposal of company and customer data.
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Data classification policy established
The company has a data classification policy in place to help ensure that confidential data is properly secured and restricted to authorized personnel.