Privacy Policy

Who is responsible

The controller of the personal data this policy covers is the Georgian individual entrepreneur named in the seller details at the end of this page.

Questions about personal data and requests go to hello@reconge.com.

What this policy covers

This policy covers the personal data Reconge processes for its own purposes: on the site reconge.com, in requests to join the waitlist, in correspondence, in the accounts of the service and in its telemetry and product analytics.

The data inside the files customers upload for reconciliation is processed on the customers' instructions. The Data Processing Agreement governs that processing.

Data we process

For each category: what it holds, why, where it comes from, the legal basis, who receives it and how long it is kept. The services and countries are listed under recipients and transfers, the periods under retention.

Providing data: a user's e-mail address and display name are required to create an account, and the data of the acceptance records are required for an organization to accept the Terms; without them the account is not created and the organization cannot accept the Terms. For the waitlist form, the work e-mail address is required and the accounting system is optional. Writing to the contact address and sending the pilot feedback are voluntary; without the sender's address Reconge cannot reply. The technical data of requests and visits (server logs, telemetry, product analytics and visits to reconge.com) arise when the service or the site is used. The session cookie is required to sign in; the other browser entries keep the language and the interface settings.

Account data

• Data: the e-mail address, display name, password hash, interface language and onboarding state of the customer's users; the organization's name and its members; the answers and the optional text of the pilot feedback form that a user chooses to send; for a registration on app.reconge.com, the address and language of a registration waiting for confirmation, the user's statement of professional use and the record of the acceptance of demo access (the time, the language, and the version and SHA-256 hash of the Terms shown); the record of a password reset request while its link is unused and valid.
• Purpose: signing in, registration, confirming the address, resetting a password, recording which Terms a person accepted for demo access, showing who made a decision or an export, the interface language, the first-run guide and the pilot feedback.
• Source: the operator creates organizations and users at the customer's request, or a person registers on app.reconge.com; a user sends the pilot feedback.
• Recipients: the hosting provider of the service and, for the e-mails that confirm the address, tell that an account already exists or reset a password, Lettermint.

Legal basis: the important legitimate interest of Reconge and of the customer in providing the service the customer has contracted for and in knowing who acts in its account; where the user is personally the customer, such as an individual entrepreneur, the contract with that user.

Acceptance records

• Data: for each user who may accept the Terms for the customer's organization, whether the user represents the organization under the public registry, was named by such a person or, for an organization registered on app.reconge.com, confirmed in the service that they may represent it; the user's capacity; for a user confirmed or named from evidence, the names of the persons who confirmed or named the user, and the reference and date of their evidence; for each acceptance, the user who gave it, the time, the statements given, and the versions, languages and SHA-256 hashes of the documents accepted.
• Purpose: showing that the customer's organization accepted the Terms and the Data Processing Agreement, which versions it accepted, and who accepted them with what authority.
• Source: the operator records who may accept from the evidence the customer gives, or the user confirms it in the service; the service records each acceptance when it is given.
• Recipients: the hosting provider of the service.

Legal basis: Reconge's important legitimate interest in proving its agreements with customers and their terms.

Waitlist requests

• Data: from an e-mail, the sender's e-mail address and the name the e-mail carries, the accounting system the sender names and the rest of the message; from the waitlist form, the work e-mail address the visitor enters, the accounting system the visitor chooses, if any, the language of the page and the time the request is accepted. To limit the number of form requests, the server of the site holds the IP address of each one in its memory for at most 61 minutes and writes it nowhere.
• Purpose: contacting the sender about the pilot.
• Source: e-mail to the contact address, or the waitlist form while the home page of reconge.com shows it.
• Recipients: for an e-mail, Reconge's mailbox service and, for e-mails up to and including 25 October 2026, also Cloudflare, which received them and forwarded them to that service; for the form, the hosting provider of the service, Lettermint, which delivers the notification of each request, and the mailbox service. See the waitlist section.

Legal basis: steps the visitor asks for before a possible contract.

Reconge uses the IP address of a form request only to count the requests that come from one address and in total, in order to protect the form against abuse. The address stays in the memory of the server of the site, and a restart of the service empties it. Legal basis for this use: Reconge's important legitimate interest in keeping the form from being flooded with requests.

Correspondence

• Data: the sender's address and name and the content of the message.
• Purpose: answering customers, visitors and partners.
• Source: e-mail to the contact address, which Reconge's mailbox service receives; up to and including 25 October 2026 Cloudflare received it and forwarded it to that service.
• Recipients: the mailbox service and, for e-mails up to and including 25 October 2026, also Cloudflare.

Legal basis: Reconge's important legitimate interest in answering the messages it receives, or steps the sender asks for before a contract.

Server logs

• Data: the technical logs of the service on its host, including the requested address of each request to the service.
• Purpose: running the service and repairing faults.
• Source: the service itself.
• Recipients: the hosting provider of the service.

Legal basis: Reconge's important legitimate interest in running a working service.

Telemetry

• Data: counters, codes and durations of requests and runs and the type of each request, with no identifier of a user, an organization or a record of the service, no request address and no identification string of the user's browser (User-Agent). Telemetry recorded until the version of this policy of 28 October 2026 took effect also holds random identifiers of users, organizations and records of the service, the address of each request to the service and the User-Agent; telemetry recorded before 14 October 2026 may also hold the text of the error of a failed run, which can quote values, column names or the first rows of a customer's file.
• Purpose: finding faults and slow parts of the service.
• Source: the server of the service.
• Recipients: Pydantic Logfire.

Legal basis: Reconge's important legitimate interest in running a working service.

Product analytics

• Data: the events of using the product and counts, each event with a new random identifier and without a profile, so that events cannot be linked to a user or an organization. Events recorded until the version of this policy of 28 October 2026 took effect also hold random identifiers of users, organizations and records of the service.
• Purpose: understanding how the pilot is used.
• Source: the server of the service sends the events; no analytics script runs in the browser of the product.
• Recipients: PostHog (EU Cloud).

Legal basis: Reconge's important legitimate interest in improving the service during the pilot.

Visits to reconge.com

• Data: the visitor's IP address and the request for each page of reconge.com, which the server of the site receives to send the page; the server writes no log of page views.
• Purpose: sending the pages of reconge.com that the visitor opens.
• Source: the visitor's browser.
• Recipients: the hosting provider of the service.

Legal basis: Reconge's important legitimate interest in showing the pages of reconge.com to the visitors who open them.

Cookies and browser storage

• Data: the cookies and browser storage entries listed in the cookies section.
• Purpose: keeping the user signed in and remembering the language and the interface settings.
• Source: the user's browser.
• Recipients: the cookies reach only the service, with each request to it; the local storage entries stay in the user's browser.
• Retention: the session cookie until the user signs out or it expires; the other entries until they expire or the user clears them.

Legal basis: these entries are needed to provide the service the user asks for.

Waitlist

To join the waitlist, a visitor writes to hello@reconge.com and names the accounting system or, while the home page shows the waitlist form, enters a work e-mail address in it and may choose the accounting system. Reconge uses such a request only to contact the visitor about the pilot.

For the waitlist form, the work e-mail address is required and the accounting system is optional. Without an address, Reconge cannot send an invitation or reply.

An e-mail to the contact address goes to Reconge's mailbox at Proton Mail, a company in Switzerland. Up to and including 25 October 2026 it first reached Cloudflare, Inc., a company in the USA, which received e-mail for the contact address and forwarded it to that mailbox. A request from the form goes to the server of the site in Germany, which does not store it and hands one notification e-mail to Lettermint B.V., a company in the Netherlands; Lettermint delivers it to Reconge's mailbox at Proton Mail. The form's request and its notification do not pass through Cloudflare. The transfers section lists each transfer with its country.

A request is kept until the person is invited to the pilot or the request is declined, and no longer than 12 months after it arrives. Reconge deletes a request earlier once it is no longer needed. Lettermint and the mailbox service keep their own copies for the periods the retention section gives.

A visitor can withdraw a request at any time by writing to the contact address; the request is handled as the rights section describes.

Recipients

These services receive the personal data of this policy:

Transfers abroad

Data of this policy reaches companies or servers outside Georgia in these cases:

• hosting of the service: to the country of its servers, Germany; basis: the country is on the list of states with adequate data protection safeguards approved by Order No 007 of the Auditor General of 14 April 2026 (Article 37(1) and Article 38(2) of the Law on Personal Data Protection);
• telemetry recorded until the version of this policy of 28 October 2026 took effect: to Pydantic Services, Inc., a company in the USA, which keeps it in its EU region, by its statement in the Netherlands (Google Cloud); basis: the Netherlands is on the list of states with adequate data protection safeguards approved by Order No 007 of the Auditor General of 14 April 2026 (Article 37(1) and Article 38(2) of the Law on Personal Data Protection); the provider's data processing addendum also allows it to transfer the data to the USA, a state that is not on that list; telemetry recorded since then holds no identifier of a user, an organization or a record of the service, no request address and no identification string of the user's browser (User-Agent);
• product analytics: to PostHog, Inc., a company in the USA, which keeps it in its EU Cloud, hosted by its statement in Frankfurt, Germany; basis: Germany is on the list of states with adequate data protection safeguards approved by Order No 007 of the Auditor General of 14 April 2026 (Article 37(1) and Article 38(2) of the Law on Personal Data Protection); PostHog states that it processes the data outside the EU as well, including in the USA, a state that is not on that list, to provide its service; Reconge and PostHog have concluded a data processing agreement, which has been in force since 20 October 2026; events recorded since the version of this policy of 28 October 2026 took effect hold no identifier of a user, an organization or a record of the service, and each event carries a new random identifier without a profile;
• e-mails to the contact address up to and including 25 October 2026 and their routing records (the sender's and recipient's addresses, the subject), which are personal data: to Cloudflare, Inc., a company in the USA, which by its statement stores information primarily in the USA and the European Economic Area; this routing ended on 25 October 2026;
• DNS queries for the names of reconge.com (they can carry part of the visitor's IP address): to Cloudflare, Inc., as above; the query is composed and sent by the visitor's resolver directly to Cloudflare, and Reconge passes no data of the visitor to it;
• the aggregate DMARC reports (the IP addresses of the mail servers that sent e-mail in the name of reconge.com and the number of their messages): to Cloudflare, Inc., as above; since 28 October 2026 the DMARC record of reconge.com no longer names Cloudflare, and no new reports go to it;
• the notifications of the waitlist form and the e-mails of the service to its users: to Lettermint B.V., a company in the Netherlands, which by its data processing agreement processes and stores e-mails in the European Union; basis: the Netherlands and the other member states of the European Union are on the list of states with adequate data protection safeguards approved by Order No 007 of the Auditor General of 14 April 2026 (Article 37(1) and Article 38(2) of the Law on Personal Data Protection);
• the mailbox service: to Switzerland, Germany or Norway, where its servers are; basis: these countries are on the list of states with adequate data protection safeguards approved by Order No 007 of the Auditor General of 14 April 2026 (Article 37(1) and Article 38(2) of the Law on Personal Data Protection).

Retention and deletion

• Account data is kept while the customer's organization uses the service. When the organization is closed, on the customer's request or, for an organization registered on app.reconge.com that has never accepted the Terms, after 12 months in which none of its users signed in, the service closes the sign-in of every user and replaces their e-mail addresses and names with placeholders. The name and e-mail address of each user who accepted the Terms for the organization, and the organization's name, are kept with the acceptance records for three years after the closing and are then replaced too. A registration that is not confirmed stops working after 24 hours, and the service then deletes it automatically; a newer registration for the same address replaces it. A password reset link stops working after one hour, once it is used or when a newer link replaces it; the service deletes the record of a used link at once and that of an unused one automatically after the hour. The record of the acceptance of demo access is kept with the account data. Lettermint keeps its copies of the e-mails of the service for the periods given under recipients.
• The audit log records actions in the service with the random identifier of the user who took them; some of its entries also hold the e-mail and name of the user, file names and company names. The entries are kept after a reconciliation is deleted. When the organization is closed, the service removes the e-mail addresses, names, file names and company names from its entries, and the entries keep the actions, their time and random identifiers; an identifier then points to a named person only while that person's record is kept, as described above.
• The pilot feedback a user sends is kept in the service for as long as it is needed to evaluate the pilot, and is deleted when the organization is closed or when the user asks for the deletion of their data.
• Acceptance records and the records of who may accept are kept in the service, which never changes a value once it is recorded; the end of a user's authority to accept and the withdrawal of an acceptance are added to the record once. After the organization is closed, the records are kept for three years to prove the written agreement and who accepted it, the period of limitation of contractual claims (Article 129(1) of the Civil Code of Georgia); then the service replaces the names, e-mail addresses and references to evidence in them with placeholders.
• The operator deletes a copy of a reconciliation made for a customer's support request by hand within 30 days after the request is resolved, and earlier once the copy is no longer needed for that request. During the pilot Reconge makes no copies for research.
• Waitlist requests are kept until the person is invited to the pilot or the request is declined, and no longer than 12 months after they arrive. Correspondence about an ordinary request is deleted from the mailbox within 30 days after the request is resolved; correspondence that the law requires Reconge to keep is kept for the period that law sets. The mailbox service keeps backups for up to 30 days, and a deleted message remains in them until they expire. By its statement, Lettermint keeps the notification of a form request with its addresses for 28 days, its delivery events for up to 90 days and copies in its backups for up to 14 days after it deletes them, and it states that these periods cannot be configured.
• Server logs are limited by size: the log of each part of the service keeps at most three files of 10 MB, and the oldest is overwritten; a log also starts anew when its part of the service is recreated by an update.
• Telemetry is kept for 30 days; product analytics by PostHog: available for one year on its free plan, by its statement, and PostHog does not state when it deletes older events; at Cloudflare, by its statement: the statistics of DNS queries are available for 31 days, the addresses and subject of the e-mails to the contact address up to and including 25 October 2026 are retained for the past 31 days, and Cloudflare does not state when it deletes them.
• Backups are made daily and kept about 15 days. Data deleted in the service stays in the backups until they expire.

What the service deletes: a customer can delete a reconciliation together with its files, runs, results and decisions, and Reconge closes the customer's organization on its request, as the Data Processing Agreement describes.

Anyone whose data this policy covers can ask for its deletion through the contact address. The request is handled as the rights section describes. For a user of the service, the service closes the user's sign-in, replaces the user's e-mail address and name with placeholders, deletes the user's pilot feedback and removes the user's e-mail address and name from the audit log. For a user who accepted the Terms for an organization, the service closes the sign-in, and the name and e-mail address stay with the acceptance records for as long as those are kept, as described above.

Cookies and browser storage

Neither the product at app.reconge.com nor the site reconge.com loads an analytics script in the browser.

reconge.com sets no cookies. In the browser's local storage it keeps only the language a visitor chooses (lang). Neither reconge.com nor app.reconge.com uses cookies or local storage for analytics or advertising.

Your rights

Under the law of Georgia you have the right to be informed about the processing of your data, to access it and receive a copy, to have it rectified, updated or completed, to have it deleted or its processing stopped, to have it blocked, to receive it in a structured form where the law provides for it, to withdraw consent where the processing relies on consent, and not to be subject to a decision based solely on automated processing, including profiling, that has legal or other significant effects for you.

To use a right, write to hello@reconge.com. Reconge replies within the time limits set by the Law on Personal Data Protection: within 10 working days of a request; for information about processing and for access or copies, in special cases this period may be extended by up to 10 working days with reasons and immediate notice of the extension; a decision to block data is communicated within 3 working days.

You may also apply to the State Audit Office of Georgia, which supervises the protection of personal data, or to a court.

Protection of data

• Each organization sees only its own data.
• Connections to the service use HTTPS.
• Passwords are stored only as a one-way hash.
• Backups are made daily and kept about 15 days.

The measures for the data in customers' files are described in the Data Processing Agreement.

Changes to this policy

Reconge may update this policy. Reconge publishes each new version on this page.

The version date at the top of this page shows the version in force.