Privacy Policy
Effective date: 29 May 2025 | Last updated: 29 May 2025
This Policy replaces all previous versions.
1. Who we are
Cassia Limited (“Cassia AI”, “Cassia”, “we”, “us”) is a New Zealand incorporated company that builds an AI-powered bookkeeping assistant integrating with Xero and other accounting tools. We are the data controller for personal information collected via:
https://heycassia.com and all sub-domains;
the Cassia AI web and mobile applications;
customer-support channels (email, chat, voice notes); and
any other services that link to this Policy (collectively, the “Services”).
2. Scope & governing law
We comply with the Privacy Act 2020 and its 13 Information Privacy Principles. Where we process data about individuals located overseas, we also endeavour to meet comparable international standards (e.g., GDPR) where they apply. This Policy does not cover third-party sites or services you may access via our Services.
3. Information we collect
Category
Typical data elements
How we collect
Account & profile data
Full name, business name, email, phone, billing address, hashed passwords
During sign-up or profile edits
Bookkeeping data
Bank-transaction exports, chart-of-accounts codes, contact names, invoice details, reconciliation actions
Uploads you make or data pulled, under your instruction, from the Xero app
Usage & device data
IP address, browser type, device IDs, pages viewed, click-stream, keystroke timings
Automated logging, cookies, analytics
Support interactions
Emails, chat transcripts, call recordings
When you contact us
Payment data
Last 4 digits of card, expiry, billing history (processed by Stripe®)
Checkout & subscription management
Sensitive data: Cassia AI is designed for financial, not health or biometric, data. Please do not upload sensitive personal data (e.g., health or racial information). If we discover such data we will delete or anonymise it.
4. How and why we use your information
Purpose
Legal basis
Details
Provide, secure and maintain the Services
Contractual necessity
Create your account; import transactions; generate coding predictions; display dashboards; handle authentication
AI/Machine Learning model training & improvement
Legitimate interests (balanced)
We use transaction data to train statistical and large-language models that improve coding accuracy. You can opt out (§ 12). No customer data is sold or shared for unrelated model training.
Automated suggestions & human-in-the-loop decisions
Legitimate interests / contract
Cassia’s predictions are suggestions only; you retain final control. No legally significant decision is made solely by an algorithm.
Billing & account administration
Contract
Invoicing, subscription management, fraud prevention
Service communications
Legitimate interests
Product updates, security notices
Marketing (newsletters, webinars)
Consent
We send electronic marketing only if you opt-in; you may unsubscribe any time
Compliance & dispute resolution
Legal obligation
Meet tax, accounting, and law-enforcement requirements
5. Automated suggestions & configurable review window
Cassia AI generates account-code and contact suggestions using AI and machine-learning models. These suggestions are held in a review queue for a period that you control:
Review-window length. Each workspace admin may set a window anywhere between 12 and 48 hours. The countdown starts when a suggestion first appears in your Cassia dashboard.
Deemed acceptance. If no one in your workspace edits or rejects a suggestion before the window expires, it is automatically finalised and recorded as accepted. Cassia will then post the entry to Xero (or your chosen ledger) and log the action.
Human control at all times. You can override or roll back any automated entry, even after deem-acceptance, using the “Remove & Redo” function.
Right to an explanation. You may request:
the main data points the model considered; and
a manual review of any suggestion you believe is incorrect.
No legally significant decision is made solely by an algorithm until the review window you have chosen has elapsed.
6. Cookies & similar technologies
We use first-party cookies for authentication and preferences, and third-party analytics cookies (Google Analytics, Hotjar) to understand aggregate usage. Manage cookies in your browser. See our [Cookie Notice] for details.
7. Sharing & international transfers
We share data only with vetted service providers under confidentiality agreements:
Provider
Purpose
Google Cloud Platform
Primary cloud infrastructure
Google Cloud Platform
Model-training workloads
Google Cloud Platform
LLM inference
Stripe
Payment processing
Auth0
Authentication
Transfers outside New Zealand (including US and AU) are safeguarded by standard contractual clauses or equivalent protections. We may also disclose information if required by law, to prevent fraud or security threats, or in connection with a merger or acquisition.
8. Security
TLS 1.3 encryption in transit; AES-256 at rest
Audit logs for model and data-access events
If you believe your data has been compromised, email [email protected].
9. Retention & deletion
Data type
Retention period
Active customer bookkeeping data
Subscription life + 7 years
Model-training artefacts
Up to 7 years, then re-trained or deleted
Support tickets
7 years
Early deletion requests honoured where legally permissible.
10. Your privacy rights
Under the Privacy Act 2020 you can request access, correction, deletion, objection/restriction, and lodge complaints with the NZ Office of the Privacy Commissioner.
11. Marketing choices
Click “unsubscribe” in any marketing email or email [email protected].
12. Opt-out of model training
Email [email protected] with your workspace ID to exclude your uploaded data from future training runs (may reduce prediction accuracy).
13. Children
Cassia AI is intended for business users aged 18+. We do not knowingly collect data from minors.
14. Changes to this Policy
Material changes will be announced by email or in-app notice at least 14 days before they take effect.
15. Contact us
Privacy queries [email protected]
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