Privacy Policy
We built ClairFlo to handle your most sensitive business data. Here is what actually matters:
- We never train our AI on your financial data. Your transactions, journal entries, and ledger data are yours. They are used only to provide the service to you.
- We never sell your data. Not to data brokers, not to advertisers, not to anyone. We are a software company, not a data monetization company.
- You can delete everything. At any time, with 30 days' notice, we will purge your data from all systems and provide a written confirmation.
- You own your financial data. Full export in standard formats (CSV, JSON, QuickBooks import) is available at any time, free of charge.
- We are regulated by PIPEDA (federal Canada) and Quebec Law 25. You have specific rights under both. They are listed below in plain language.
1. Who We Are
Khaiba Platforms, Inc. ("Khaiba," "we," "our," or "us") is a corporation incorporated under the Canada Business Corporations Act, with its registered office in Toronto, Ontario, Canada. We operate the ClairFlo financial operations platform accessible at clairflo.com and related subdomains.
For the purpose of Canadian privacy law, Khaiba Platforms, Inc. is the organization responsible for personal information under PIPEDA, and the person in charge of the protection of personal information under Quebec Law 25.
Privacy Officer
2. Information We Collect
2.1 Information You Provide Directly
- Account registration: Name, email address, company name, role, jurisdiction.
- Beta application: Role, company information, transaction volume, current accounting software, and any additional information you choose to provide.
- Communications: When you contact us by email or through the platform, we retain those communications.
- Billing information: When the platform moves to paid tiers, payment instrument details are collected by our payment processor (Stripe) and not stored on our servers. We retain transaction records, not payment credentials.
2.2 Financial and Business Data (Your Data)
This is the core operational data you entrust to us. It includes:
- Bank account transaction history ingested via Plaid or direct import
- Invoice and bill data, including vendor and customer names and amounts
- Journal entries, trial balances, and chart of accounts data
- Payroll data ingested via ADP or other connected services
- Email content and attachments processed through the AP/AR email handler
- Documents uploaded via OCR pipeline (receipts, invoices, contracts)
This data belongs to you. We process it solely to provide the ClairFlo service. See Section 3.3 on AI training for our explicit commitment.
2.3 Technical and Usage Data
- Log data: IP address, browser type, pages visited, timestamps, error reports
- Device identifiers and session tokens
- Feature usage telemetry (which modules you use, how often, performance metrics)
- API access logs with request metadata (not payload content)
2.4 Information From Third Parties
- Connected integrations: When you connect Plaid, QuickBooks, Xero, Shopify, Stripe, or other providers, we receive data from those services according to the permissions you grant.
- OAuth identity providers: If you authenticate via Google or Microsoft, we receive your name and email from that provider.
3. How We Use Your Information
3.1 Providing and Improving the Service
- Processing financial events through the ClairFlo pipeline (classification, reconciliation, compliance)
- Generating journal entries, reports, and audit materials
- Operating the practice management, treasury, and compliance modules
- Sending transactional communications (receipts, alerts, beta feedback requests)
- Diagnosing and resolving technical issues
- Measuring and improving platform performance
3.2 Legal Bases for Processing (PIPEDA / Quebec Law 25)
Under PIPEDA, we collect, use, and disclose personal information with your consent (which you give when you accept these terms and connect your data sources) and where necessary to fulfil our contractual obligations to you.
Where we rely on legitimate interests (such as maintaining security logs), we conduct a balancing test and document it. You have the right to object to legitimate-interest processing — see Section 6.
3.3 AI Training — Our Explicit Commitment
We do not use your financial data, transaction history, journal entries, or any business-specific information to train, fine-tune, or improve our AI models. ClairFlo's machine learning models are trained on anonymized synthetic data and publicly available accounting datasets.
When you correct an AI classification or reconciliation match, that correction is used to personalize ClairFlo's behavior for your account only — it is stored in your tenant's episodic memory and is never shared across tenants or used for cross-customer model improvement.
3.4 Communications
We may send:
- Service communications (required): account confirmations, security alerts, data breach notifications, material changes to these terms. You cannot opt out of these.
- Product updates (optional): new feature announcements, beta program updates. You can unsubscribe at any time.
- Marketing (optional, with separate consent): promotional content. We will not send this without explicit opt-in.
4. Sharing and Disclosure
We do not sell personal information. We do not rent, trade, or monetize your data in any form. The following are the only circumstances under which your information leaves our systems:
4.1 Subprocessors
We use the following third-party services to operate the platform. Each is contractually bound to data processing standards consistent with PIPEDA. The complete and current list is maintained in our Subprocessor Register below.
4.2 Legal Compliance
We may disclose your information where required by law, including under:
- A valid court order, subpoena, or search warrant from a Canadian court
- FINTRAC reporting obligations (where applicable)
- CRA requirements under the Income Tax Act
Where legally permitted, we will notify you before complying with such a request. We will never voluntarily disclose your data to law enforcement absent legal compulsion.
4.3 Business Transfers
If Khaiba Platforms, Inc. is acquired, merged, or undergoes a change of control, your information may be transferred to the successor entity. We will provide 60 days' notice and the right to delete your data before the transfer occurs. [COUNSEL REVIEW: Verify Ontario PIPEDA requirements for business transfer notification timing]
5. Data Retention
| Data Type | Retention Period |
|---|---|
| Financial transaction data | 7 years from creation (Canadian CRA requirement for business records) |
| Account registration data | Duration of account + 1 year post-deletion |
| Audit logs and access records | 2 years |
| Security incident records | 5 years |
| Communication records | 3 years |
| AML/STR records | 5 years (FINTRAC requirement) |
| Beta program application data | 2 years post-beta |
When you delete your account, we delete or anonymize all data not subject to mandatory retention within 30 days, and provide written confirmation.
6. Your Rights
Under PIPEDA and Quebec Law 25, you have the following rights. To exercise any of them, contact privacy@clairflo.com. We respond within 30 days.
6.1 Right of Access
You have the right to know what personal information we hold about you and to receive a copy in a portable format. Your financial data is available for export at any time through the platform interface (Settings → Data Export) in CSV and JSON formats, at no charge.
6.2 Right to Correction
You have the right to correct inaccurate personal information. For account information, you can update it directly in the platform. For data you dispute, contact us and we will investigate and correct within 30 days.
6.3 Right to Deletion
You have the right to request deletion of your personal information, subject to our legal retention obligations (Section 5). Deletion requests for financial records we are required by law to retain will result in access being removed — the data will be isolated and inaccessible — rather than destroyed.
6.4 Right to Withdraw Consent
Where we process your information based on consent, you may withdraw that consent at any time. Withdrawal may affect our ability to provide the service.
6.5 Right to Algorithmic Transparency (Quebec Law 25)
Where ClairFlo makes automated decisions about your financial data (such as transaction classifications), you have the right to know that automated decision-making is occurring, the general logic applied, and to have a human review any decision that significantly affects you. Reach us at privacy@clairflo.com to request human review of any automated decision.
6.6 Right to Complain
If you are unsatisfied with our handling of your information, you have the right to complain to the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca, or, if you are in Quebec, to the Commission d'accès à l'information (CAI) at cai.gouv.qc.ca.
7. Cross-Border Data Transfers
Khaiba Platforms, Inc. is incorporated and primarily operated in Canada. We use cloud infrastructure and subprocessors located in both Canada and the United States. When your data is processed in the United States, it may be subject to access by US law enforcement under US law (including the CLOUD Act).
We mitigate this risk through: (a) data encryption at rest and in transit using keys that subprocessors cannot access; (b) contractual data processing agreements with all US subprocessors; and (c) a preference for Canadian data residency where available (AWS Canada Central, MongoDB Atlas Canada). [COUNSEL REVIEW: Confirm current data residency configuration with infrastructure team]
8. Cookies and Tracking
We use cookies and similar technologies for:
- Strictly necessary cookies: Authentication session tokens, CSRF protection. These cannot be disabled without breaking the service.
- Functional cookies: User preferences (language, display settings). Can be cleared through browser settings.
- Analytics cookies: Aggregate usage data to understand how the platform is used. We use self-hosted analytics (Plausible or equivalent) that does not involve third-party tracking pixels. [COUNSEL REVIEW: Confirm analytics vendor and PIPEDA/Law 25 compliance]
We do not use advertising cookies, behavioural tracking pixels, or third-party retargeting technologies.
9. Subprocessor Register
Current as of the effective date above. We will provide 30 days' notice via email before adding new subprocessors that process personal information.
| Subprocessor | Purpose | Data Location |
|---|---|---|
| Amazon Web Services (AWS) | Cloud infrastructure, S3 evidence storage, Textract OCR | Canada (ca-central-1) |
| MongoDB Atlas | Primary document database | Canada |
| Plaid Technologies | Bank account connectivity and transaction import | United States |
| Stripe Inc. | Payment processing (billing subscriptions) | United States |
| SendGrid (Twilio) | Transactional email delivery | United States |
| Anthropic / OpenAI | LLM inference for AI agents (data transmitted is anonymized/pseudonymized context windows only; no raw financial data) | United States |
| Pinecone | Vector embedding storage for episodic memory | United States |
| Hedera Hashgraph | Blockchain audit proof anchoring (hashes only — no personal data) | Distributed network |
LLM subprocessor note: When ClairFlo's AI agents process your transactions, we submit structured, pseudonymized context windows to LLM providers — not your raw financial data. Vendor names and amounts are included in classification requests. Your account name, personal identifiers, and banking credentials are never transmitted to LLM APIs. [COUNSEL REVIEW: Verify this data minimization approach with privacy counsel and document in DPA]
10. Changes to This Policy
We will notify you by email at least 30 days before making material changes to this policy. Non-material changes (correcting typos, clarifying existing practices) will be updated without notice. The current version is always available at https://clairflo.com/privacy. The version history is maintained in our GitHub repository at [COUNSEL REVIEW: Insert repo link].
Terms of Service
- Your data is yours. We claim no ownership over your financial data. You can export and delete it at any time.
- We provide a software service, not financial or legal advice. ClairFlo automates accounting tasks. It does not replace a qualified accountant, auditor, or tax advisor.
- During beta, there is no SLA. We work hard to keep things running, but we cannot guarantee uptime during this testing period.
- Our liability is limited to the fees you paid us in the 12 months before the claim. During the free beta, this means our liability cap is zero — a significant limitation.
- Ontario law governs. Any dispute is heard in Ontario courts.
1. Definitions
| Term | Meaning |
|---|---|
| "Agreement" | These Terms of Service, together with the Privacy Policy, Beta Program Agreement (where applicable), and any Order Form or subscription plan. |
| "Customer Data" | All financial, business, and personal information you import into, create within, or transmit through the ClairFlo platform, including transaction data, journal entries, documents, and reports. |
| "ClairFlo Platform" | The web application, APIs, and related services operated by Khaiba Platforms, Inc. and accessible at clairflo.com and related subdomains. |
| "Authorized User" | Any individual (employee, contractor, or accountant) you grant access to your ClairFlo account. |
| "Beta Period" | The period during which the ClairFlo Platform is designated as "Beta" in the interface, currently ongoing and expected to end no later than [COUNSEL REVIEW: Insert target date]. |
2. Account Registration and Access
2.1 Eligibility
To create an ClairFlo account, you must: (a) be at least 18 years of age; (b) have the legal authority to enter into contracts on behalf of any business entity you register; and (c) provide accurate and complete registration information.
2.2 Account Security
You are responsible for maintaining the confidentiality of your credentials and for all activities that occur under your account. You must notify us immediately at security@clairflo.com if you suspect unauthorized access. We will not be liable for losses caused by unauthorized access resulting from your failure to protect your credentials.
2.3 Authorized Users
You may grant access to Authorized Users within your organization. You are responsible for their compliance with this Agreement and for revoking access promptly when they no longer have authorization.
2.4 Acceptable Use
You agree not to:
- Use the platform for any unlawful purpose, including money laundering, tax evasion, or financial fraud
- Attempt to reverse-engineer, decompile, or extract source code from the platform
- Use automated means to access the platform in a manner that exceeds reasonable usage or adversely affects performance for other users
- Transmit malicious code, spam, or content that violates any third party's rights
- Resell, sublicense, or commercially distribute access to the platform without our prior written consent
- Attempt to probe, scan, or test the vulnerability of the platform or bypass security measures
3. Your Data — Ownership, License, and Portability
3.1 You Own Your Data
We claim no ownership rights in Customer Data. Your financial data is yours. By using the platform, you grant Khaiba Platforms, Inc. a limited, non-exclusive, non-transferable license to process Customer Data solely for the purpose of providing the ClairFlo service to you.
3.2 Data Portability
You may export your Customer Data at any time through the platform interface. Export formats include CSV, JSON, and QuickBooks-compatible import files. Export is available free of charge and without restriction throughout the term of your account.
3.3 Data Deletion
Upon account termination, we will delete or anonymize Customer Data within 30 days, subject to retention obligations described in the Privacy Policy (Section 5). We will provide written confirmation of deletion upon request.
3.4 Aggregated Anonymized Data
We may generate aggregate, anonymized statistical data (such as industry benchmarks or platform performance metrics) from Customer Data. This data does not identify you or your business. We may use such data to improve the platform and publish industry reports. No personal or business-identifiable information is included. [COUNSEL REVIEW: Confirm this is consistent with Privacy Policy commitments and PIPEDA requirements]
4. Service Availability and Beta Terms
4.1 Beta Service Level
During the Beta Period, we provide the platform on an "as-is" and "as-available" basis. We do not guarantee any specific uptime, response time, or service level during the beta. We will endeavour to maintain 99% availability but make no binding commitment to this figure during the Beta Period.
4.2 Feature Changes
During the Beta Period, we may modify, add, or remove platform features without prior notice. We will communicate significant changes through the platform interface and by email where reasonably practicable.
4.3 Production Service Levels
Following the Beta Period, Khaiba Platforms, Inc. intends to offer a formal Service Level Agreement (SLA) with defined uptime commitments and support response times. Beta participants will receive advance notice of these terms before they take effect.
5. Payment and Pricing
5.1 Beta Program — No Charge
Access to the ClairFlo Platform during the Beta Period is provided free of charge. No credit card is required to participate in the beta program.
5.2 Post-Beta Pricing
Following the Beta Period, Khaiba Platforms, Inc. will offer subscription plans on a monthly or annual basis. Beta participants will receive: (a) at least 60 days' advance notice before any charges commence; (b) a 50% discount on their first year of subscription, as stated in the Beta Program Agreement; and (c) the right to cancel before any charge is made.
5.3 Taxes
Subscription fees are exclusive of applicable taxes. GST/HST will be added to invoices for Canadian customers in accordance with applicable law.
6. Intellectual Property
6.1 Khaiba Platforms, Inc. IP
The ClairFlo platform, including its software, algorithms, AI models, design elements, documentation, and all intellectual property embodied therein, is owned by Khaiba Platforms, Inc. and protected by Canadian and international intellectual property laws. This Agreement grants you a limited right to use the platform — it does not transfer any ownership rights.
6.2 Feedback
If you provide feedback, suggestions, or ideas regarding the platform ("Feedback"), you grant Khaiba Platforms, Inc. a perpetual, irrevocable, worldwide, royalty-free license to use, incorporate, and commercialize that Feedback without restriction and without compensation to you. See the Beta Program Agreement for additional details.
6.3 No Reverse Engineering
You may not reverse engineer, decompile, disassemble, or attempt to derive the source code or underlying algorithms of the ClairFlo platform.
7. Disclaimers — Not Financial, Legal, or Tax Advice
IMPORTANT. ClairFlo automates accounting tasks. Khaiba Platforms, Inc. is not a licensed accounting firm, legal practice, or financial advisory firm. Nothing in the ClairFlo platform constitutes financial advice, tax advice, legal advice, or investment advice.
Specifically:
- AI-generated journal entries, classifications, and tax calculations must be reviewed and approved by a qualified accounting professional before reliance.
- Compliance calculations (GST/HST, payroll remittances, SR&ED claims) are provided for informational purposes and must be verified by a qualified accountant or tax advisor before filing.
- ClairFlo's financial forecasting and cash flow projections are estimates based on historical data and do not constitute financial advice.
- ClairFlo does not guarantee that its compliance outputs will be accepted by the Canada Revenue Agency, the IRS, or any other tax authority.
Use of the ClairFlo platform does not create an accountant-client, lawyer-client, or advisor-client relationship between you and Khaiba Platforms, Inc.
8. Limitation of Liability
8.1 Exclusion of Consequential Damages
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, KHAIBA PLATFORMS, INC. WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING LOSS OF PROFITS, LOSS OF DATA, LOSS OF GOODWILL, BUSINESS INTERRUPTION, OR COST OF SUBSTITUTE SERVICES, ARISING OUT OF OR IN CONNECTION WITH THIS AGREEMENT OR THE PLATFORM, REGARDLESS OF THE THEORY OF LIABILITY AND EVEN IF KHAIBA PLATFORMS, INC. HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
8.2 Aggregate Cap
Khaiba Platforms, Inc.'s total aggregate liability to you for all claims arising under or in connection with this Agreement will not exceed the greater of: (a) the total fees paid by you to Khaiba Platforms, Inc. in the twelve (12) months immediately preceding the event giving rise to the claim; or (b) CAD $100.00. During the Beta Period, when the service is provided free of charge, our aggregate liability is limited to CAD $100.00.
[COUNSEL REVIEW]: Liability caps in consumer-facing SaaS contracts are subject to scrutiny under Ontario's Consumer Protection Act and the Quebec Consumer Protection Act. If any end-users are "consumers" (individuals using ClairFlo for personal, family, or household purposes), additional protections may apply that override contractual limitations. Counsel should advise on the appropriate cap structure and whether exclusions need carve-outs for gross negligence, willful misconduct, or data breaches.
8.3 Essential Basis
The limitations in this section are a fundamental part of the basis of the bargain between Khaiba Platforms, Inc. and you. Khaiba Platforms, Inc. would not provide the platform absent these limitations.
9. Indemnification
You will defend, indemnify, and hold harmless Khaiba Platforms, Inc. and its officers, directors, employees, and contractors from any claims, damages, losses, and expenses (including reasonable legal fees) arising from or related to: (a) your use of the platform in violation of this Agreement; (b) Customer Data you provide to the platform; or (c) your violation of any applicable law, including privacy laws.
10. Term, Termination, and Suspension
10.1 Term
This Agreement begins when you create an account and continues until terminated by either party.
10.2 Termination by You
You may terminate your account at any time by contacting support@clairflo.com or through the account settings interface. Upon termination, we will process your data deletion request per Section 3.3.
10.3 Termination by Khaiba Platforms, Inc.
Khaiba Platforms, Inc. may terminate your account immediately (without notice) for material breach of this Agreement, including fraudulent use, violation of the acceptable use policy, or non-payment of fees after the Beta Period. For less severe violations, we will provide 14 days' written notice and an opportunity to cure before terminating.
10.4 Effect of Termination
Upon termination, your access to the platform ceases immediately. Your right to export data survives for 30 days post-termination. Sections 3 (Your Data), 6 (IP), 7 (Disclaimers), 8 (Liability), 9 (Indemnification), and 11 (Disputes) survive termination.
11. Governing Law and Dispute Resolution
11.1 Governing Law
This Agreement is governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to conflict of laws principles.
11.2 Dispute Resolution
Before initiating formal proceedings, you agree to contact us at legal@clairflo.com and attempt to resolve the dispute informally for 30 days. If informal resolution fails, disputes will be resolved by binding arbitration administered by the ADR Institute of Canada under its Arbitration Rules, with proceedings conducted in English in Toronto, Ontario. [COUNSEL REVIEW: Assess whether mandatory arbitration is enforceable in Ontario for consumer contracts; consider whether a small claims court carve-out is appropriate]
11.3 Class Action Waiver
All disputes must be brought in an individual capacity only, and not as a plaintiff or class member in any purported class action. [COUNSEL REVIEW: Class action waivers have limited enforceability in Canadian courts — counsel must advise on viability]
12. General Provisions
Entire Agreement: This Agreement constitutes the entire agreement between the parties regarding its subject matter and supersedes all prior agreements.
Severability: If any provision is found unenforceable, it will be modified to the minimum extent necessary to make it enforceable. The remaining provisions remain in full force.
Waiver: Our failure to enforce any provision does not constitute a waiver of that provision.
Assignment: You may not assign this Agreement without our written consent. Khaiba Platforms, Inc. may assign this Agreement in connection with a merger, acquisition, or sale of all or substantially all of its assets.
Notices: Notices to Khaiba Platforms, Inc. must be sent to legal@clairflo.com. Notices to you will be sent to the email address on your account.
Beta Program Agreement
- Confidentiality — both ways. You keep unreleased ClairFlo features confidential. We keep your business information confidential. Neither party discloses the other's proprietary information.
- Your feedback helps us build better software. If you tell us something is broken or suggest an improvement, we can use that feedback to improve ClairFlo. You don't get paid for this, but that's why the beta is free.
- 30 minutes per month. We ask for one structured feedback call monthly. That's the commitment beyond just using the platform.
- Either party can end this. You can leave at any time. We can end the beta program or remove participants who aren't engaged.
1. Purpose and Nature of the Beta Program
Khaiba Platforms, Inc. is inviting a limited number of businesses and accounting professionals ("Beta Participants" or "you") to access and test the ClairFlo Platform prior to its general commercial release. The beta program serves two purposes: to allow Beta Participants to begin realizing value from ClairFlo early, and to allow us to identify and resolve issues before broad deployment.
The ClairFlo Platform during the Beta Period is in active development. It may contain errors, operate at reduced performance, and undergo significant changes. Participation is voluntary and carries the risks inherent in using pre-release software.
2. Beta Participant Benefits
In consideration for your participation and feedback, we provide:
- Full platform access: Access to the complete ClairFlo Platform including all modules (AP, AR, treasury, practice management, compliance, analytics) without feature restrictions during the Beta Period.
- No-cost access: The ClairFlo Platform is provided free of charge during the Beta Period. No payment, credit card, or financial commitment is required.
- Pricing lock: Upon the conclusion of the Beta Period, Beta Participants who choose to continue will receive a 50% discount on their first 12 months of subscription, with the applicable tier rate locked at the publicly announced pricing at time of launch. This discount does not apply to per-transaction or usage-based charges that may be introduced at launch.
- Roadmap influence: Beta Participants will have a structured opportunity to submit feature requests and vote on roadmap priorities. Khaiba Platforms, Inc. makes no binding commitment to implement any specific request.
- Onboarding session: we will provide a 60-minute configuration session for each Beta Participant, conducted by a member of the founding team.
- Direct access: Beta Participants will have direct Slack channel access to the ClairFlo engineering and product staff during the Beta Period.
3. Beta Participant Obligations
In exchange for the benefits described in Section 2, you agree to:
- Connect real data: Connect at least one live data source (bank account via Plaid, accounting software via OAuth, or equivalent) within 14 days of account activation. Testing with synthetic or demo data is permitted alongside real data but cannot be the sole data source.
- Active use: Use the platform operationally for at least 30 consecutive days. "Operational use" means processing actual financial events through the platform, not merely logging in.
- Structured feedback: Participate in one 20-minute structured feedback call per month. These are conducted by video conference and recorded with your consent for internal use.
- Bug reporting: Report bugs, errors, and unexpected behaviors through the designated feedback channel promptly upon discovery.
- Honest feedback: Provide candid and constructive feedback, including negative feedback. The purpose of the beta is to find problems.
Khaiba Platforms, Inc. may remove Beta Participants who consistently fail to meet these obligations after providing written notice and a 7-day opportunity to re-engage.
4. Mutual Confidentiality
4.1 Khaiba Platforms, Inc. confidential information
During and after the Beta Period, you agree to keep the following information confidential and not to disclose it to any third party without our prior written consent:
- Unreleased features, algorithms, architecture, and technical details of the ClairFlo Platform
- Information shared in feedback calls, Slack, or other communications that we designate as confidential
- Beta pricing, business terms, and any non-public commercial information
- Security vulnerabilities or weaknesses you discover in the platform
Confidentiality obligations do not apply to information that: (a) is or becomes publicly available without your breach; (b) you independently developed without using our confidential information; or (c) you are required to disclose by law (in which case you must notify us promptly if legally permitted).
You may disclose Our confidential information to your employees or contractors who need to know it for the purpose of evaluating or using the platform, provided they are bound by confidentiality obligations at least as protective as these.
4.2 Your Confidential Information
Khaiba Platforms, Inc. acknowledges that your Customer Data and business operations information are confidential. we will not disclose your Customer Data or business information except as permitted by the Privacy Policy and Terms of Service. Our obligation of confidentiality with respect to your Customer Data is perpetual.
4.3 Duration
Confidentiality obligations survive termination of this Agreement for a period of three (3) years, except that obligations relating to trade secrets continue for as long as the information remains a trade secret. [COUNSEL REVIEW: Assess appropriate duration for your specific competitive sensitivity]
5. Feedback License
You acknowledge that Khaiba Platforms, Inc. may receive feedback, suggestions, bug reports, and ideas from many Beta Participants simultaneously. To avoid any ambiguity about ownership of platform improvements, you agree that:
- All Feedback you provide to Khaiba Platforms, Inc. (whether in feedback calls, written submissions, Slack, email, or any other channel) is provided on a non-confidential basis.
- You grant Khaiba Platforms, Inc. a perpetual, irrevocable, worldwide, royalty-free, fully sublicensable license to use, reproduce, modify, create derivative works from, distribute, and commercialize any Feedback without restriction and without any compensation to you.
- Khaiba Platforms, Inc. is not obligated to implement any Feedback and retains sole discretion over product direction.
- You represent that you have the authority to provide the Feedback and that it does not infringe any third party's intellectual property rights.
This clause is standard in beta programs and is the reason the program is free. You're contributing to building something better — we're committed to honouring that contribution through the pricing benefit in Section 2.
6. Beta Data Handling
6.1 Data Use During Beta
Customer Data you provide during the Beta Period is handled according to the Privacy Policy and Terms of Service. We do not use Beta Participant Customer Data for AI model training. Beta data is subject to the same security controls as production data.
6.2 Data Continuity
we will use commercially reasonable efforts to maintain data continuity throughout the Beta Period. However, in the event of a significant platform issue, we may need to restore from backups, which could result in loss of data added after the most recent backup point. we will notify you promptly of any such event.
6.3 Transition to Production
If you choose to continue using ClairFlo after the Beta Period concludes, all Customer Data processed during the Beta Period will automatically be available in your production account. No data migration or re-import is required. Any data you accumulated during the Beta Period counts toward your full transaction history.
7. Beta Warranty Disclaimer
THE CLAIRFLO PLATFORM DURING THE BETA PERIOD IS PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED. KHAIBA PLATFORMS, INC. EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.
Specifically during the Beta Period, Khaiba Platforms, Inc. does not warrant that:
- The platform will be uninterrupted, error-free, or free from security vulnerabilities
- AI-generated classifications, journal entries, or compliance calculations are accurate
- Beta features will be included in the production release
- Data will be preserved in the event of a catastrophic system failure
You accept these risks as part of participating in a pre-release software program. We recommend maintaining your existing accounting records in parallel during the Beta Period.
8. Term and Termination
8.1 Beta Period Duration
The Beta Period begins on the date of your beta acceptance email and concludes when Khaiba Platforms, Inc. announces the general commercial release of the platform or otherwise notifies Beta Participants of the beta program's conclusion. we will provide at least 30 days' advance notice of the conclusion of the Beta Period.
8.2 Voluntary Withdrawal
You may withdraw from the Beta Program at any time by notifying us at beta@clairflo.com. Upon withdrawal, your access to the platform will cease, and your Customer Data will be handled per Section 6 of the Terms of Service.
8.3 Removal for Non-Participation
Khaiba Platforms, Inc. may remove Beta Participants who: (a) fail to connect any live data source within 21 days of account activation; (b) have not logged in for 30 or more consecutive days; or (c) consistently decline to participate in feedback calls without notice. we will provide 7 days' written notice before removal for non-participation.
8.4 Removal for Cause
Khaiba Platforms, Inc. may immediately terminate a Beta Participant's access for material breach of this Agreement, including but not limited to: disclosure of confidential information, use of the platform for unlawful purposes, or attempted circumvention of security measures.
9. General
This Beta Program Agreement is incorporated into and subject to the ClairFlo Terms of Service. In the event of a conflict between this Agreement and the Terms of Service, this Agreement controls with respect to the Beta Program. All other terms and conditions of the Terms of Service apply in full.
Beta Participant
Khaiba Platforms, Inc.
Note: For digital acceptance, we will confirm via email. Clickwrap acceptance at account creation constitutes a legally binding signature under Ontario's Electronic Commerce Act, 2000.
Security & Trust
- Your data is encrypted with keys you control and that our infrastructure providers cannot access.
- We use post-quantum cryptography — the same standard being adopted by NIST — which future-proofs against quantum computing threats relevant to sensitive financial records.
- Every database query is automatically scoped to your tenant. It is architecturally impossible for one customer to access another's data.
- Every action taken on your account — including by Khaiba engineers — is logged with a full audit trail. We cannot tamper with historical records.
- We will notify you within 72 hours of discovering a data breach affecting your information (as required by PIPEDA and Quebec Law 25).
1. Encryption
1.1 Data At Rest
All Customer Data stored in our databases and object storage is encrypted at rest using a layered approach:
- Infrastructure-level encryption: AWS S3 and MongoDB Atlas encrypt all stored data using AES-256-GCM. This protects against physical media theft.
- Application-level envelope encryption: Sensitive fields (financial amounts, personal identifiers, credentials) are additionally encrypted at the application layer before storage. Encryption keys are managed through AWS KMS, scoped per tenant.
- Post-quantum cryptography (Kyber768 KEM): Long-retention records — those kept for 5–7 years for regulatory compliance — are encrypted using hybrid classical + post-quantum key encapsulation. This ensures data stored today cannot be decrypted by future quantum computing capabilities ("harvest now, decrypt later" attacks). Signatures use Dilithium (NIST FIPS 204).
1.2 Data In Transit
- All communication between your browser and the ClairFlo platform uses TLS 1.3. TLS 1.0 and 1.1 are disabled.
- API endpoints enforce HTTPS with HSTS (HTTP Strict Transport Security) headers and a minimum validity period of 1 year.
- Internal service-to-service communication within the ClairFlo infrastructure uses mutual TLS (mTLS).
- Kafka event streams are encrypted in transit using TLS and authenticated using SASL/PLAIN.
1.3 Key Management
Encryption keys are managed through AWS KMS with the following controls: (a) per-tenant key isolation — your data is encrypted with a key unique to your tenant; (b) key rotation on an annual schedule; (c) all key access is logged in CloudTrail; (d) Khaiba staff cannot directly access your encryption keys without formal break-glass procedures that generate immutable audit records.
2. Access Controls and Tenant Isolation
2.1 Multi-Tenant Architecture
ClairFlo is built as a strict multi-tenant system. Every MongoDB query, Neo4j Cypher statement, and Redis operation is automatically scoped to a tenant_id extracted from a validated JWT token at the middleware layer. This is not an application-level filter — it is enforced at the database driver level, making cross-tenant data access architecturally impossible under normal operation.
2.2 Role-Based Access Control (RBAC)
Within your organization, access is governed by a five-role permission system enforced at every API endpoint via Open Policy Agent (OPA):
| Role | Access Level |
|---|---|
| Owner | Full access including billing, team management, data export, and deletion |
| Manager | Full accounting access, team oversight, client management (APME) |
| Staff | Operational accounting, time entry, assigned client access |
| Client | Portal access to their own financial data only |
| Auditor | Read-only access to all data within the tenant, no write permissions |
2.3 Segregation of Duties (SoD) Enforcement
ClairFlo enforces segregation of duties at the API middleware layer — not just as an application-level check. Six critical conflict pairs are blocked by default:
- VENDOR_CREATE + PAYMENT_RELEASE (ghost vendor protection)
- VENDOR_BANK_UPDATE + PAYMENT_INITIATE (BEC fraud protection)
- BILL_RECEIVE + BILL_APPROVE (AP approval integrity)
- CASH_RECEIPT_RECORD + CASH_RECEIPT_BANK (larceny prevention)
- PAYROLL_PREPARE + PAYROLL_APPROVE (payroll fraud prevention)
- JE_PREPARE + JE_POST (journal entry integrity)
2.4 Khaiba staff access to Customer Data
Khaiba engineers and staff have strictly limited access to Customer Data:
- Production database access requires formal approval, uses time-limited credentials, and generates an immutable audit record.
- "Break-glass" emergency access to production is logged, time-limited to 4 hours, and requires a second approver.
- Customer Data is never accessed for purposes other than troubleshooting reported issues, with your consent requested where possible.
- We do not conduct ad-hoc queries on Customer Data for business analysis, product development, or sales purposes.
Authentication
JWT tokens with 24-hour expiry. Session invalidation on logout. Magic-link authentication for client portal (no password storage for external users).
API Security
Rate limiting at API gateway level (Kong). Input validation and sanitization on all endpoints. OWASP Top 10 mitigations in code review checklist.
Anomaly Detection
Behavioral analytics on operator actions. Flags unusual access hours, velocity anomalies, and threshold-skirting patterns. Generates alerts for security review.
Audit Trail
Every state-changing action is logged with correlation ID, user ID, tenant ID, timestamp, and full before/after state. Logs are append-only and cannot be modified.
3. Infrastructure Security
3.1 Cloud Infrastructure
Khaiba Platforms, Inc. operates ClairFlo on Amazon Web Services, primarily in the Canada (Central) region (ca-central-1) for data residency. Production workloads run in a Virtual Private Cloud (VPC) with private subnets for all data-tier services. Database servers are not publicly accessible.
3.2 Network Security
- WAF (Web Application Firewall) at the Kong API gateway layer
- DDoS protection via AWS Shield Standard
- Network segmentation between public-facing services and internal data tier
- Security group rules following the principle of least privilege
3.3 Vulnerability Management
- Dependency scanning on every CI/CD pipeline run (automated via GitHub Dependabot)
- Container image scanning before deployment
- Quarterly penetration testing (scheduled for pre-production launch — [COUNSEL REVIEW: Insert current pen test status])
- Security review as a mandatory step in the pull request process
4. Incident Response
4.1 Breach Notification Timeline
In the event of a security incident affecting Customer Data:
| Timeframe | Action |
|---|---|
| 0–4 hours | Incident detected, response team activated, immediate containment measures |
| 4–24 hours | Scope assessment, evidence preservation, executive notification |
| 24–72 hours | Customer notification (as required by PIPEDA / Quebec Law 25), OPC / CAI notification if required |
| 72 hours + | Full investigation, root cause analysis, remediation, post-incident report |
We will provide affected customers with: (a) a description of what happened; (b) what data was involved; (c) what we have done to respond; (d) what you can do to protect yourself; and (e) our contact for questions.
4.2 Reporting a Security Issue
If you discover a security vulnerability in the ClairFlo platform, please report it responsibly to security@clairflo.com. We commit to:
- Acknowledging your report within 24 hours
- Providing a timeline for investigation within 7 days
- Crediting your responsible disclosure publicly (if you wish)
- Not pursuing legal action against good-faith security researchers
During the Beta Period, we are especially interested in reports of: authentication bypass, cross-tenant data access, injection vulnerabilities, and any issue that could allow access to Customer Data without authorization.
5. Backup and Disaster Recovery
- MongoDB: Continuous oplog backup via MongoDB Atlas. Point-in-time recovery to any second within the last 7 days. Daily snapshots retained for 30 days.
- Object storage (S3): Versioning enabled. Cross-region replication to a secondary AWS region. [COUNSEL REVIEW: Confirm secondary region and retention policy with infrastructure team]
- Recovery Time Objective (RTO): Target 4 hours for full service restoration from backup. Not an SLA during beta.
- Recovery Point Objective (RPO): Target maximum 1-hour data loss. Continuous backup means this is typically seconds for most failure scenarios.
6. Compliance Status
| Standard / Regulation | Status |
|---|---|
| PIPEDA (federal Canada) | Privacy Policy and data handling aligned. Legal review in progress. |
| Quebec Law 25 | Privacy impact assessment underway. Algorithmic transparency documentation in progress. |
| SOC 2 Type II | Planned for 6 months post-production launch. Not yet certified. |
| ISO 27001 | Under consideration. Not certified. |
| FINTRAC (PCMLTFA) | AML typology detection implemented. Compliance framework review required. [COUNSEL REVIEW] |
| WCAG 2.1 AA (Accessibility) | In progress. Platform not yet fully accessible. |
Beta participants: Khaiba Platforms, Inc. is not yet SOC 2 certified. If your organization requires SOC 2 or equivalent certification before connecting production financial data, please contact us at security@clairflo.com to discuss alternatives for your beta participation.